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Re: [RTTY] RM-11708

To: rtty@contesting.com
Subject: Re: [RTTY] RM-11708
From: "Joe Subich, W4TV" <lists@subich.com>
Date: Fri, 29 Jul 2016 09:49:24 -0400
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>

> leave in place "named emissions" or whatever the term is

§97.309   RTTY and data emission codes.

(a) Where authorized by §§97.305(c) and 97.307(f) of the part, an amateur station may transmit a RTTY or data emission using the following specified digital codes:

(1) The 5-unit, start-stop, International Telegraph Alphabet No. 2, code defined in ITU-T Recommendation F.1, Division C (commonly known as “Baudot”).

(2) The 7-unit code specified in ITU-R Recommendations M.476-5 and M.625-3 (commonly known as “AMTOR”).

(3) The 7-unit, International Alphabet No. 5, code defined in IT--T Recommendation T.50 (commonly known as “ASCII”).

(4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.

(b) Where authorized by §§97.305(c) and 97.307(f), a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a Regional Director to assure compliance with the FCC Rules, a station must:

(1) Cease the transmission using the unspecified digital code;

(2) Restrict transmissions of any digital code to the extent instructed;

(3) Maintain a record, convertible to the original information, of all digital communications transmitted.

We want to hear from the public with respect to increasing symbol
ratealone.

The point that needs to be made is that symbol rate can not be
increased independent of bandwidth.  Increasing the symbol rate
will automatically increase the occupied bandwidth (and potential
QRM to traditional users).

The Commission really needs to abolish the outdated concept of
Voice/Image vs. RTTY/DATA.  Once that concept rooted in the 1920's
is eliminated simply apply a maximum bandwidth of 400 Hz in the
current "RTTY/DATA" allocations (sufficient for 45.45/75 baud
RTTY, PSK31/63/125, PACTOR (1), and the "narrow" versions of
Olivia/MFSK/Contestia/DominoEX/etc.) and a bandwidth limitation
of 2.7 KHz (as is the case on 60Meters) in the rest of the HF
bands (with a specific exception for traditional double sideband
AM).

Eliminating the outdated Voice/Image vs. RTTY/DATA distinction is
not a blanket bandwidth limit but protects users of traditional
narrow bandwidth modes while allowing continued development of
higher speed/wider bandwidth digital modes in the "wide" segments
of the bands (with the exception of 30 meters).
segments.

73,

   ... Joe, W4TV



On 7/29/2016 9:20 AM, Al Kozakiewicz wrote:
Did I miss something?

What I read was:

Tentatively, yes to drop symbol rate limitation.
No to a blanket bandwidth limitation and leave in place "named emissions" or 
whatever the term is, that specify allowed modes.
We want to hear from the public with respect to increasing symbol rate alone.

Al
AB2ZY

________________________________________
From: RTTY <rtty-bounces@contesting.com> on behalf of Jim AC0E <ham@odsgc.net>
Sent: Friday, July 29, 2016 8:14 AM
To: Ron Kolarik; rtty@contesting.com
Subject: Re: [RTTY] RM-11708

Ron,

Appears we may be screwed and the winlink folks could prevail.

I can't believe the commercial folks have not made a peep about this
issue as it flies directly out of their pocketbook.
It also will  set up a company with a closed system to be the big winner..

I'm so disheartend  about this issue and the Feds in general and Dave,
K1ZZ, for, apparently,  helping promote this BS.

See you the bands while we still can operate. So much for working to
have cleans signals and NOT create harmful interference.

Jim AC0E


On 7/28/2016 3:51 PM, Ron Kolarik wrote:
RM-11708 has advanced to NPRM status, WTB 16-239, you may access
it from the FCC ECFS site. 60 day comment period, 90 day reply to
comments.

Please read and understand what the FCC is requesting for comments before
commenting.

Ron K0IDT

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--
James Douglass AC0E
PO Box 506
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620.272.7620 cell/text



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