[RTTY] Director response

[Joe Subich, W4TV]

> As currently written Part 97 only allows unspecified codes on one
> band, 1.25m and 100kHz bw. 97.307(f)(13) and the way the appendix to
> RM-11708 is worded it would apply to everything.

No, 97.307(f)(5) allows "A RTTY, data or multiplexed emission using an
unspecified digital code under the limitations listed in §97.309(b) of
this part" on 6 and 2 meters.  97.307(f)(6) allows "A RTTY, data or
multiplexed emission using an unspecified digital code under the
limitations listed in §97.309(b) of this part" on 1.25 meters and 70
cm.  97.307(f)(7) allows "A RTTY, data or multiplexed emission using an
unspecified digital code under the limitations listed in §97.309(b) of
this part" on 33 cm to 1 mm and above 275 GHz.

For reference - a *specified* digital code includes any code that is
publicly documented.  See 97.309(4):

(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.

However, where a code is not publicly documented its use is prohibited
at HF and it is this restriction that ARRL seeks to overturn by this
sneak attack.   Eliminating the prohibition on "unspecified" (a.k.a,
"undocumented") codes would allow the use of "undocumented" codes as
back door encryption (another goal of the Winlink group).

73,

    ... Joe, W4TV


On 11/26/2013 6:18 PM, Ron Kolarik wrote:
> Okay guys I'm still having delays getting mail from the list and the reply
> from Kai hasn't showed up yet.
>
> As currently written Part 97 only allows unspecified codes on one band,
> 1.25m and 100kHz bw. 97.307(f)(13) and the way the appendix to RM-11708
> is worded it would apply to everything.
>
> Ron
> K0IDT
>
>
> ----- Original Message ----- From: "Kok Chen" <chen at mac.com>
> To: "Joe Subich, W4TV" <lists at subich.com>
> Cc: <rtty at contesting.com>
> Sent: Tuesday, November 26, 2013 4:22 PM
> Subject: Re: [RTTY] Director response
>
>
>
> On Nov 26, 2013, at 2:11 PM, Joe Subich, W4TV wrote:
>
>>>
>>> The CURRENT regs already have that "unspecified code" language in
>>> 97.307. The ARRL proposal does not have a "drafting error".
>>
>> That is *incorrect*.  97.307(f)(3) currently says:
>>
>> (3) Only a RTTY or data emission using a specified digital code listed
>> in §97.309(a) of this part may be transmitted. The symbol rate must
>> not exceed 300 bauds, or for frequency-shift keying, the frequency
>> shift between mark and space must not exceed 1 kHz.
>
> The Appendix in ARRL's petition supports what Joe just said.
>
> The copy I have of Part 97 (published ARRL 2007) says the same thing.
>
> Has 97.307 been changed since then?
>
> 73
> Chen, W7AY
>
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