[RTTY] ARRL attack on current RTTY users

RLVZ at aol.com RLVZ at aol.com
Sat Nov 23 13:43:34 EST 2013


I'm wondering if the ARRL solicits the comments of it's  Members before 
they file a Proposal with the FCC?  I'm a long time ARRL  Member and read QST 
but I don't remember the ARRL asking it's Members for  recommendations about 
bandwidths.  I would hope that the  ARRL would seek comments from it's 
Members, and then giver serious  consideration to those comments, before the ARRL 
 files Proposals with the FCC on our behalf.  (if they don't, we need  to 
get after them to do so)
 
73,
Dick- K9OM
 
 
 
 
 
In a message dated 11/23/2013 1:24:54 P.M. Eastern Standard Time,  
rtty-request at contesting.com writes:

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Today's Topics:

1. Re: ARRL attack  on current RTTY users (Joe Subich, W4TV)
2. Re: ARRL attack on  current RTTY users (Kok Chen)
3. Re: ARRL attack on current  RTTY users (Don Hill AA5AU)
4. Re: ARRL attack on current RTTY  users (Jeff Blaine)
5. Re: ARRL attack on current RTTY users  (Kok  Chen)


----------------------------------------------------------------------

Message:  1
Date: Sat, 23 Nov 2013 12:38:35 -0500
From: "Joe Subich, W4TV"  <lists at subich.com>
To: rtty at contesting.com
Subject: Re: [RTTY]  ARRL attack on current RTTY users
Message-ID:  <5290E81B.1030107 at subich.com>
Content-Type: text/plain;  charset=ISO-8859-1; format=flowed


On 11/23/2013 11:00 AM, Kai  wrote:

> Summary:
> 1- The argument for 2800 Hz is not  substantiated by the ARRL, even
> with reference to 60m.
> 2-  Currently regs permit  RTTY parameters for up to 1500 Hz BW
>  ("Steam-RTTY" is 250 Hz).
> 3- Amateur practice must consider customary  RECEIVE bandwidths for
> digital modes (not just TX) which may be  impacted by wide-band
> transmissions

While amateur regulations  permit theoretical bandwidths of up to
1500 Hz, amateur *practice* has  overwhelmingly been to use transmit 
bandwidths of up to 300 - 500 Hz. I am  sure the overwhelming majority
of amateurs - both CW and digital operators  - expect the transmit
bandwidth to be in that range and not "push the  limits" of what is
permissible just as the overwhelming majority of voice  and image
mode operators expect transmitted bandwidth to be in the 2.8  KHz
range - *not* 6 KHz for double-sideband full carrier AM, the 5  KHz
of *some* infantile ESSB operators, or 5+ KHz of splatter from  some
over processed SSB and overdriven sweep tube amplifiers.

As to  "receive bandwidth" - that is not, and should not be, regulated. 
All of  the "traditional bandwidth" modes *can* be received using narrow
filters  (filters appropriate to the necessary bandwidth) if necessary.
However, it  makes complete sense to limit transmit bandwidth to values
compatible with  those actually used in order to minimize interference
in general due to the  relatively narrow bands available for traditional
"RTTY, data" modes and  their significant use - particularly 80, 30, and
17 meters where  "traditional bandwidth" modes are limited to less than
30 KHz by the  combination of band-plan and regulation and are subject
to significant  interference from unattended auto-responding systems.

73,

... Joe, W4TV


On 11/23/2013 11:00 AM, Kai wrote:
> Hi  Joe,
> I was referring to the future, not the past. We DO want to keep  the door
> open to innovation. That's why I agree that getting the baud  language out
> of the regs is good. But I also think that 2800 Hz BW is  a bit over the
> top,
> except perhaps up where "image" is  permitted. The number should be
> lower, but how low?
> Perhaps  this forum can home in on it.
>
> Again, to keep what we can do  today, (up to the 300 baud RTTY with up to
> 1000 Hz shift) would  require a bandwidth of
>        300+1.2(1000) = 1500  Hz. THAT is the current RTTY teleprinter
> mode limit
> So, the  question boils down to: do we want more restrictive regs?
>
> My  point about how we use PSK and JT modes was a bit more subtle. One has
>  to consider how those modes are used.
> Each of the TRANSMISSIONS are  indeed below at least 500 Hz. But PSK and
> JT were
> designed to  operating RECEIVING multiple users over a 2-4 kHz band.
> We all mostly  cooperate and that system works. It is because of the
> need for 2-4 kHz  "subbands" on RECEIVING the multiple PSK and JT
> signals, that
>  we would NOT want band-hogging 2800 Hz signals in the non-phone
>  non-image ranges.
> Common practice for PSK and JT type modes is to  operate at low transmit
> power.
> It's an argument against 2800.  And it is a argument that could be made
> to the  Commission.
>
> Oh, while I think of it, the 60 m band channels  are not a good example
> of where 2800 Hz
> is now permitted  because (1) they are channelized, and (2) modes like
> PSK and JT  (also
> CW) can not be operated according to standard amateur practice,  that is,
> anywhere in the channel,
> with the efficiency of  multiple users.
>
> Summary:
> 1- The argument for 2800 Hz  is not substantiated by the ARRL, even with
> reference to 60m.
>  2- Currently regs permit  RTTY parameters for up to 1500 Hz BW
>  ("Steam-RTTY" is 250 Hz).
> 3- Amateur practice must consider customary  RECEIVE bandwidths for
> digital modes (not just TX)
>   which may be impacted by wide-band  transmissions
>
> 73
> Kai, KE4PT
>
>
> On  11/23/2013 12:10 AM, Joe Subich, W4TV wrote:
>>
>> >  Additionally, modes like PSK31 (63 Hz necessary BW on TX) and JT65
>>  > (170 Hz BW on TX) are actually practiced by hams as multiple users  in
>> > a 2-4 kHz BW subband. Individual TX BWs are small, but  general usage
>> > is for multiple simultaneous decodes in a  contiguous BW. I guess that
>> > this is the kind of innovation  and usage that we don't want to shut
>> > ourselves out  of.
>>
>> Asking for a 500 Hz bandwidth limit in the current  "RTTY, data"
>> allocations below 30 MHz would not "shut out" any of  the modes
>> like PSK31, JT65, JT9, WSPR or QRSS ... I doubt that 500  Hz would
>> shut out PSK63, PSK125 or some of the narrower MFSK modes  either.
>> These narrow modes - traditional RTTY at 45.45 and 75  baud, PSK31,
>> JT65, JT9, WSPR and QRSS - represent well in excess  of 90% of all
>> HF digital operators and QSOs over the course of a  month or year.
>>
>> 300 Hz or 500 Hz is consistent with  "traditional radiotelepriner
>> bandwidths" which is what the FCC,  themselves, defined as the
>> criteria for establishing the 300 baud  limit in 1980.  It is also
>> compatible with the overwhelming  majority of *all* amateur activity
>> (including CW) in the spectrum  allocated for "RTTY, data" operation.
>> I think it is incumbent on  both the general digital operator and CW
>> operators to convince the  FCC that we *still* want the bandwidth to
>> be consistent with  "traditional teleprinter bandwidths" and that
>> there is no  overwhelming need for wider bandwidth.
>>
>> Again, if ARRL  can justify a real need (which is doubtful due to
>> the overwhelming  use of narrow bandwidth modes) for wider data
>> modes, they should  petition the Commission to authorize "RTTY, data"
>> modes in the  current "phone, image" portions 75, 40, 20, 17, 15, 12
>> and 10  meters with a bandwidth of "up to" 2.8 KHz - comparable to
>> the  bandwidth of "phone, image" modes.
>>
>>  73,
>>
>>    ... Joe,  W4TV
>>
>>
>> On 11/22/2013 5:00 PM, Kai  wrote:
>>> EXACTLY!  I've brought this up obliquely before,  but in more detail
>>> here:
>>>
>>> BW  limit means "occupied BW" defined as  less than 0.5% of power  is
>>> below and less than 0.5% power is above the bandwidth.  There is also
>>> necessary BW. See the regs, see 47 CFR 2.202 (a)  and (b). In the case
>>> of two tone amateur RTTY (or using Chen's  affectation "steam RTTY"),
>>> that means the BW=B+1.2S where B is  the baud rate and S is the shift.
>>> The common 45.45B 170S works  out to 249.45 = 250 Hz necessary BW.
>>>
>>> So 1000 S  at 300 B works out to be 1500 Hz necessary BW. That is a
>>> nice  possible limit since it parrots the current regs for RTTY as  300
>>> baud limit and max 1000 Hz shift. I won't debate whether  that is
>>> needed or even used, but it is currently  permitted.
>>>
>>> The lowest order  PACTOR-III  SL1 mode has 100+1.2(840) = 1108 Hz
>>> necessary BW, the highest  order PACTOR-III SL6 is 100+1.2(2040)= 2448
>>> Hz. There are four  levels in between. The lowest order PACTOR fits in
>>> the 1500  BW.
>>>
>>> The FCC/NTIA and ITU-R publish guide lines  on computing required BWs.
>>> See US 47 CFR 2.201-2.202-emission  designators, modulations and
>>> necessary BW. Our 47 CFR 97  points to that.
>>>
>>> We indeed need to be careful  about what we ask for!
>>>
>>> Additionally, modes  like PSK31 (63 Hz necessary BW on TX) and JT65
>>> (170 Hz BW on  TX) are actually practiced by hams as multiple users in
>>> a 2-4  kHz BW subband. Individual TX BWs are small, but general usage
>>>  is for multiple simultaneous decodes in a contiguous BW. I guess  that
>>> this is the kind of innovation and usage that we don't  want to shut
>>> ourselves out of.
>>>
>>>  73 Kai, KE4PT
>>>
>>> On 11/22/2013 2:51 PM, Bill  Turner wrote:
>>>> I am a little surprised that no one has  brought up the question of
>>>>  measuring bandwidth. We  need to be careful what we ask for - we
>>>> just might get  it.
>>>>
>>>> If the FCC should establish a  bandwidth limit of 500 Hz, what
>>>> exactly does that mean?  Does that mean that all tones AND SIDEBANDS
>>>> must be within  the 500 Hz? Or does it mean that the shift of a
>>>> signal  must be within 500 Hz but the sidebands can be outside 500
>>>>  Hz?  And if the latter, how many dB down must they  be?
>>>>
>>>> You may recall that the "real"  bandwidth of a 170 Hz shift RTTY
>>>> signal is approximately  300 Hz because of the sidebands.  Given
>>>> that, what is  the real bandwidth of a mode that claims to occupy
>>>> 500 Hz,  such as Olivia 500/16?
>>>>
>>>> This needs to  be settled before the rule is made by the FCC,
>>>> otherwise  chaos will surely follow.
>>>>
>>>> 73, Bill  W6WRT _______________________________________________ RTTY
>>>>  mailing list RTTY at contesting.com
>>>>  http://lists.contesting.com/mailman/listinfo/rtty
>>>>
>>>  _______________________________________________ RTTY mailing  list
>>> RTTY at contesting.com
>>>  http://lists.contesting.com/mailman/listinfo/rtty
>>>
>>  _______________________________________________
>> RTTY mailing  list
>> RTTY at contesting.com
>>  http://lists.contesting.com/mailman/listinfo/rtty
>>
>  _______________________________________________
> RTTY mailing  list
> RTTY at contesting.com
>  http://lists.contesting.com/mailman/listinfo/rtty
>


------------------------------

Message:  2
Date: Sat, 23 Nov 2013 10:02:31 -0800
From: Kok Chen  <chen at mac.com>
To: k.siwiak at ieee.org
Cc:  rtty at contesting.com
Subject: Re: [RTTY] ARRL attack on current RTTY  users
Message-ID:  <9E4E08FA-E4EA-49A2-8A40-734800E7333E at mac.com>
Content-Type:  text/plain; charset=us-ascii


On Nov 23, 2013, at 8:00 AM, Kai  wrote:

> Again, to keep what we can do today, (up to the 300 baud  RTTY with up to
> 1000 Hz shift) would require a bandwidth  of
>      300+1.2(1000) = 1500 Hz. THAT is the current  RTTY teleprinter mode 
limit

That is actually a darn good suggestion,  and does not deviate from what we 
can do today on FSK with the current  regulations.

I.e., the narrowest 2 tone FSK bandwidth you can get by  using the maximum 
symbol rate and FSK shift that is allowed from the existing  regulations.

This would include 850 Hz RTTY shift too, which will allow  good 
experimentation to further study selective fading.

Mind if I  plagiarize that to include in my own comments to the FCC?

P.S.  It  would also de-legalize Pactor III and create a different 
religious war.   (Pactor III is 2K20J2D emission.)

73
Chen,  W7AY



------------------------------

Message: 3
Date:  Sat, 23 Nov 2013 12:04:57 -0600
From: "Don Hill AA5AU"  <aa5au at bellsouth.net>
To: <rtty at contesting.com>
Subject: Re:  [RTTY] ARRL attack on current RTTY users
Message-ID:  <000e01cee876$85caabc0$91600340$@net>
Content-Type: text/plain;   charset="us-ascii"

I don't think we should be asking the FCC for  a specified bandwidth limit 
at this time. Our actions should be geared toward  getting
the FCC to dismiss the ARRL proposal.

Don  AA5AU

-----Original Message-----
From: RTTY  [mailto:rtty-bounces at contesting.com] On Behalf Of Kai
Sent: Saturday,  November 23, 2013 10:01 AM
To: rtty at contesting.com
Subject: Re: [RTTY]  ARRL attack on current RTTY users

Hi Joe,
I was referring to the  future, not the past. We DO want to keep the door 
open to innovation. That's  why I agree that getting the
baud language out of the regs is good. But I  also think that 2800 Hz BW is 
a bit over the top, except perhaps up where  "image" is
permitted. The number should be lower, but how low?
Perhaps  this forum can home in on it.

Again, to keep what we can do today, (up  to the 300 baud RTTY with up to
1000 Hz shift) would require a bandwidth  of
300+1.2(1000) = 1500 Hz. THAT is the current  RTTY teleprinter mode limit 
So, the question boils down to: do we want  more
restrictive regs?

My point about how we use PSK and JT modes  was a bit more subtle. One has 
to consider how those modes are used.
Each  of the TRANSMISSIONS are indeed below at least 500 Hz. But PSK and JT 
were  designed to operating RECEIVING multiple users over
a 2-4 kHz band.
We  all mostly cooperate and that system works. It is because of the need 
for 2-4  kHz "subbands" on RECEIVING the multiple PSK and JT
signals, that we would  NOT want band-hogging 2800 Hz signals in the 
non-phone non-image  ranges.
Common practice for PSK and JT type modes is to operate at low  transmit 
power.
It's an argument against 2800. And it is a argument that  could be made to 
the Commission.

Oh, while I think of it, the 60 m band  channels are not a good example of 
where
2800 Hz
is now permitted  because (1) they are channelized, and (2) modes like PSK 
and JT (also
CW)  can not be operated according to standard amateur practice, that is, 
anywhere  in the channel, with the efficiency of  multiple
users.

Summary:
1- The argument for 2800 Hz is not  substantiated by the ARRL, even with 
reference to 60m.
2- Currently regs  permit  RTTY parameters for up to 1500 Hz BW 
("Steam-RTTY" is
250  Hz).
3- Amateur practice must consider customary RECEIVE bandwidths for  digital 
modes (not just TX)
which may be impacted by  wide-band transmissions

73
Kai, KE4PT


On 11/23/2013 12:10  AM, Joe Subich, W4TV wrote:
>
> > Additionally, modes like  PSK31 (63 Hz necessary BW on TX) and JT65
> > (170 Hz BW on TX) are  actually practiced by hams as multiple users in
> > a 2-4 kHz BW  subband. Individual TX BWs are small, but general usage
> > is for  multiple simultaneous decodes in a contiguous BW. I guess that
> >  this is the kind of innovation and usage that we don't want to shut
>  > ourselves out of.
>
> Asking for a 500 Hz bandwidth limit in  the current "RTTY, data"
> allocations below 30 MHz would not "shut out"  any of the modes
> like PSK31, JT65, JT9, WSPR or QRSS ... I doubt that  500 Hz would
> shut out PSK63, PSK125 or some of the narrower MFSK modes  either.
> These narrow modes - traditional RTTY at 45.45 and 75 baud,  PSK31,
> JT65, JT9, WSPR and QRSS - represent well in excess of 90% of  all
> HF digital operators and QSOs over the course of a month or  year.
>
> 300 Hz or 500 Hz is consistent with "traditional  radiotelepriner
> bandwidths" which is what the FCC, themselves, defined  as the
> criteria for establishing the 300 baud limit in 1980.  It  is also
> compatible with the overwhelming majority of *all* amateur  activity
> (including CW) in the spectrum allocated for "RTTY, data"  operation.
> I think it is incumbent on both the general digital  operator and CW
> operators to convince the FCC that we *still* want the  bandwidth to
> be consistent with "traditional teleprinter bandwidths"  and that
> there is no overwhelming need for wider  bandwidth.
>
> Again, if ARRL can justify a real need (which is  doubtful due to
> the overwhelming use of narrow bandwidth modes) for  wider data
> modes, they should petition the Commission to authorize  "RTTY, data"
> modes in the current "phone, image" portions 75, 40, 20,  17, 15, 12
> and 10 meters with a bandwidth of "up to" 2.8 KHz -  comparable to
> the bandwidth of "phone, image" modes.
>
>  73,
>
>    ... Joe, W4TV
>
>
> On  11/22/2013 5:00 PM, Kai wrote:
>> EXACTLY!  I've brought this up  obliquely before, but in more detail
>> here:
>>
>>  BW limit means "occupied BW" defined as  less than 0.5% of power  is
>> below and less than 0.5% power is above the bandwidth. There is  also
>> necessary BW. See the regs, see 47 CFR 2.202 (a) and (b). In  the case
>> of two tone amateur RTTY (or using Chen's affectation  "steam RTTY"),
>> that means the BW=B+1.2S where B is the baud rate  and S is the shift.
>> The common 45.45B 170S works out to 249.45 =  250 Hz necessary BW.
>>
>> So 1000 S at 300 B works out to  be 1500 Hz necessary BW. That is a
>> nice possible limit since it  parrots the current regs for RTTY as 300
>> baud limit and max 1000  Hz shift. I won't debate whether that is
>> needed or even used, but  it is currently permitted.
>>
>> The lowest order   PACTOR-III SL1 mode has 100+1.2(840) = 1108 Hz
>> necessary BW, the  highest order PACTOR-III SL6 is 100+1.2(2040)= 2448
>> Hz. There are  four levels in between. The lowest order PACTOR fits in
>> the 1500  BW.
>>
>> The FCC/NTIA and ITU-R publish guide lines on  computing required BWs.
>> See US 47 CFR 2.201-2.202-emission  designators, modulations and
>> necessary BW. Our 47 CFR 97 points to  that.
>>
>> We indeed need to be careful about what we ask  for!
>>
>> Additionally, modes like PSK31 (63 Hz necessary  BW on TX) and JT65
>> (170 Hz BW on TX) are actually practiced by  hams as multiple users in
>> a 2-4 kHz BW subband. Individual TX BWs  are small, but general usage
>> is for multiple simultaneous decodes  in a contiguous BW. I guess that
>> this is the kind of innovation  and usage that we don't want to shut
>> ourselves out  of.
>>
>> 73 Kai, KE4PT
>>
>> On  11/22/2013 2:51 PM, Bill Turner wrote:
>>> I am a little surprised  that no one has brought up the question of
>>>  measuring  bandwidth. We need to be careful what we ask for - we
>>> just  might get it.
>>>
>>> If the FCC should establish a  bandwidth limit of 500 Hz, what
>>> exactly does that mean? Does  that mean that all tones AND SIDEBANDS
>>> must be within the 500  Hz? Or does it mean that the shift of a
>>> signal must be within  500 Hz but the sidebands can be outside 500
>>> Hz?  And if  the latter, how many dB down must they be?
>>>
>>> You  may recall that the "real" bandwidth of a 170 Hz shift RTTY
>>>  signal is approximately 300 Hz because of the sidebands.   Given
>>> that, what is the real bandwidth of a mode that claims  to occupy
>>> 500 Hz, such as Olivia  500/16?
>>>
>>> This needs to be settled before the  rule is made by the FCC,
>>> otherwise chaos will surely  follow.
>>>
>>> 73, Bill W6WRT  _______________________________________________ RTTY
>>> mailing  list RTTY at contesting.com
>>>  http://lists.contesting.com/mailman/listinfo/rtty
>>>
>>  _______________________________________________ RTTY mailing list
>>  RTTY at contesting.com
>>  http://lists.contesting.com/mailman/listinfo/rtty
>>
>  _______________________________________________
> RTTY mailing  list
> RTTY at contesting.com
>  http://lists.contesting.com/mailman/listinfo/rtty
>
_______________________________________________
RTTY  mailing  list
RTTY at contesting.com
http://lists.contesting.com/mailman/listinfo/rtty



------------------------------

Message:  4
Date: Sat, 23 Nov 2013 12:13:59 -0600
From: "Jeff Blaine"  <keepwalking188 at yahoo.com>
To: "Kok Chen" <chen at mac.com>,   <k.siwiak at ieee.org>
Cc: rtty at contesting.com
Subject: Re:  [RTTY] ARRL attack on current RTTY users
Message-ID:  <73AAB052483041959164959B7EE155C0 at w520>
Content-Type: text/plain;  format=flowed; charset="iso-8859-1";
reply-type=original

The guys promoting the winlink/pactor 4 stuff keep  talking about improved 
emcom support.  But I'm not sure how these two  items tie together.

Can someone explain how the emcom needs are not met  with the currently 
supported modes?   I have seen a lot of MARS  related winlink comments but 
that group has a different focus than the  general ham population.  Not to 
mention MARS has it's own set of  dedicated  frequencies.

73/jeff/ac0c
www.ac0c.com
alpha-charlie-zero-charlie

-----Original  Message----- 
From: Kok Chen
Sent: Saturday, November 23, 2013 12:02  PM
To: k.siwiak at ieee.org
Cc: rtty at contesting.com
Subject: Re: [RTTY]  ARRL attack on current RTTY users


On Nov 23, 2013, at 8:00 AM, Kai  wrote:

> Again, to keep what we can do today, (up to the 300 baud  RTTY with up to
> 1000 Hz shift) would require a bandwidth  of
>      300+1.2(1000) = 1500 Hz. THAT is the current  RTTY teleprinter mode 
> limit

That is actually a darn good  suggestion, and does not deviate from what we 
can do today on FSK with the  current regulations.

I.e., the narrowest 2 tone FSK bandwidth you can  get by using the maximum 
symbol rate and FSK shift that is allowed from  the existing regulations.

This would include 850 Hz RTTY shift too,  which will allow good 
experimentation to further study selective  fading.

Mind if I plagiarize that to include in my own comments to the  FCC?

P.S.  It would also de-legalize Pactor III and create a  different 
religious 
war.  (Pactor III is 2K20J2D  emission.)

73
Chen,  W7AY

_______________________________________________
RTTY mailing  list
RTTY at contesting.com
http://lists.contesting.com/mailman/listinfo/rtty  



------------------------------

Message: 5
Date: Sat,  23 Nov 2013 10:24:04 -0800
From: Kok Chen <chen at mac.com>
To: Don  Hill AA5AU <aa5au at bellsouth.net>
Cc: rtty at contesting.com
Subject:  Re: [RTTY] ARRL attack on current RTTY users
Message-ID:  <1AF1350A-56BB-4875-9C98-1DDEBE022A1F at mac.com>
Content-Type:  text/plain; charset=us-ascii


On Nov 23, 2013, at 10:04 AM, Don Hill  AA5AU wrote:

> I don't think we should be asking the FCC for a  specified bandwidth 
limit at this time. Our actions should be geared toward  getting
> the FCC to dismiss the ARRL proposal.

Correct,  Don.  But if you read my earlier posting, the ARRL is *also* 
sneakily  proposing a change to expand the bandwidth in their proposed change to 
97.307  (f) (3).

I don't know who drafted in that change, and even the Board of  Directors 
may not be aware of that sleight of hand.  All the propaganda  from HQ is 
about changing symbol rates, but they had to sneak that bandwidth  item in.  
Nothing to do with symbol rates, but very detrimental to  digital subbands.

If you write to your director, be sure to mention  that they need to 
carefully read the petition, especially the 2.8 kHz part, to  be sure that they 
know what they had signed up to.

73
Chen,  W7AY



------------------------------

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