[RTTY] Error in RM-11708

[Joe Subich, W4TV]

On 11/27/2013 3:23 AM, Don Hill AA5AU wrote:
 > 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.

If there is another section that specifically permits bandwidths
beyond 500 Hz for "computer communications," I hope someone will
provide a reference - and not base their argument on the weak
justification on /Mark Miller/ which spoke to changing the rules
not *enforcing* existing rules.

I can believe that nobody noticed the existing limit as ARRL is correct
in that there are no explicit limitations on data in 97.307 although
there are implicit limits based on shift and baud rate.  Other than
97.3(c)(2), the only explicit bandwidth limit on data modes is the one
in 97.221 related to "automatic operation" outside the subbands. One
would not necessarily look to the definition for emission standards but
they are there for both modulation types and bandwidth.

 > What's the catch????

As far as I can tell, the only argument would be that the "500 Hz"
language applies only to those modulation designators having 'C'
as the third character (i.e., Facsimile [still images]) but that
is a stretch.

I hope that others opposed to this spectrum grab will file comments
soon.  As of this morning the Winlink sympathizers (maritime radio
users, Winlink developers, etc.) strongly outnumber the number of
"no wideband" comments

73,

    ... Joe, W4TV


On 11/27/2013 3:23 AM, Don Hill AA5AU wrote:
> 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
> to500 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
>
> _______________________________________________
> RTTY mailing list
> RTTY at contesting.com
> http://lists.contesting.com/mailman/listinfo/rtty
>
>