[RTTY] Error in RM-11708

[Don Hill AA5AU]

Joe, you are absolutely correct in the definition of "data" in FCC rules. It's hard to believe that by definition "data" is actually
defined as having 500 Hz bandwidth limit and no one ever noticed it until Joe just discovered it. There has to be some exception as
to why Pactor 3 and other modes exceeding 500 Hz are in existence today on HF.

Pactor 3 is data. It's ITU designator is 2K20J2D.

It can't be so simple as to say "this is it", data on HF is limited to 500 Hz and those using modes exceeding this limit are in
violation of the rules.

Tell me it isn't true (actually tell me it is true because I'm enjoying it).

What's the catch????

Don AA5AU

-----Original Message-----
From: RTTY [mailto:rtty-bounces at contesting.com] On Behalf Of Joe Subich, W4TV
Sent: Wednesday, November 27, 2013 12:17 AM
To: RTTY Reflector
Subject: [RTTY] Error in RM-11708


The entire premise of RM-11708 is flawed.  There *is* a limit on occupied bandwidth for digital modes at HF.  That limit is found in
the very definition of "data" - see section 97.3(c)(2) which
reads:

> (2) Data. Telemetry, telecommand and computer communications emissions 
> having (i) designators with A, C, D, F, G, H, J or R as the first 
> symbol, 1 as the second symbol, and D as the third symbol;
> (ii) emission J2D; and (iii) emissions A1C, F1C, F2C, J2C, and J3C 
> having *an occupied bandwidth of 500 Hz or less* when transmitted on 
> an amateur service frequency below 30 MHz.  Only a digital code of a 
> type specifically authorized in this part may be transmitted.

[54 FR 25857, June 20, 1989]

Where "data" is listed as an authorized emission type in section 97.305 for *any* frequency below 30 MHz, "data" carries the
limitation from 97.3(c)(2).

Based on this, ARRL is not asking for a limit where none presently exists - they are proposing a *massive increase* in permitted
bandwidth with no justification.  Further, it would appear that PACTOR III and its 2200 Hz bandwidth is actually illegal and ARRL
should be asking the Commission to enforce the current rules - not reward those who continue to flaut them.

73,

   ... Joe, W4TV

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