[RTTY] RM-11708 FAQ posted

[Kai]

I'm not going to pursue this pointless debate. It's up to the FCC now.
73
Kai, KE4PT

On 2/27/2014 3:34 PM, Joe Subich, W4TV wrote:
>
> 97.307(f) is not the only limitation on data modes ...
>
> 97.3(c)(2) specifically limits image modes when transmitted as data
> to 500 Hz.  This is where the Commission specifically told ARRL that
> is was not going to eliminate the separation of wideband modes from
> narrow band modes - or put another way, it was not going to eliminate
> the traditional protections of narrow band modes from interference by
> wide band modes.
>
> *Nothing* in the progress of technology has reduced or eliminated the
> need to protect narrow band modes from wideband modes just as nothing
> in automotive technology has eliminated the need to protect children
> in school zones from highway speeds.  If you want 2.8 KHz data take
> it to that spectrum where wideband modes are already permitted.
>
> 73,
>
>    ... Joe, W4TV
>
>
> On 2/27/2014 3:10 PM, Kai wrote:
>> Currently, and applying broadly to the FCC term "RTTY",  97.307(f)  -
>> "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. "
>> That means two-tone FSK RTTY at up to 300 baud and up to 1000 Hz shift
>> is permitted, and has a bandwidth of 1500 Hz* (not 500 Hz).  Digital
>> emissions that do are not subject to the "or for frequency-shift keying,
>> the frequency shift between mark and space must not exceed 1 kHz"
>> restriction of 97.307(f) are subject ONLY to the 300 baud restriction
>> (there are several ham digital non-voice modulations in use with up to
>> about 2400 Hz BW today: G-TOR, PacTor, Clover are specifically listed by
>> the FCC; there are more). If one choses to, and has a good reason to,
>> one could legally occupy, as I stated, in the 100's of kHz.
>>
>> So many of us see and understand that the technology has outpaced the
>> out dated 97.307(f), since it restricts the bandwidth of two-tone FSK
>> RTTY ONLY, and not any other digital modulation. But the 300 baud limit
>> can render many other digital modulations very spectrum inefficient (but
>> not illegal) without limiting their bandwidth.
>>
>> RM 11708 seeks to replace that 97.307(f) phrase with "The authorized
>> bandwidth is 2.8 kHz."
>>
>> *See US CFR 2.202 for bandwidth calculation of two tone FSK RTTY:   BW =
>> BaudRate + 1.2Shift = 300+1.2(1000) = 1500 Hz.
>>
>> -Kai, KE4PT
>>
>>
>> On 2/27/2014 11:25 AM, Joe Subich, W4TV wrote:
>>>
>>> Were we to see some lid or lids fire up with 300 KHz wide signals on
>>> 10 meters - or 200 KHz wide signals on 160 meters - ARRL and the FCC
>>> would quickly scramble to impose a bandwidth limit.  2.8 KHz in the
>>> spectrum traditionally reserved for bandwidths 500 Hz and less is just
>>> as bad as 200 or 300 KHz- as the punch line of the old joke goes:
>>> "Young Lady, we have already determined what you are - now we're only
>>> haggling over price."
>>>
>>> And before you try to argue again that 500 Hz is not the de facto
>>> standard, read *the Commission's *own words* at footnote 89, page 12 of
>>> http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-149A1.pdf in
>>> which they forcefully *rejected* ARRL's request that *image* modes not
>>> be restricted to 500 Hz bandwidth in the "data" allocations.  Note:
>>> even *analog* image modes are permitted in the "data" allocations as
>>> long as their bandwidth is less that 500 Hz.
>>>
>>> As far back as 2006 the Commission made it absolutely clear to ARRL
>>> what they would accept and what they would not accept.  ARRL's Board of
>>> Directors, CEO and Counsel are quite simply incompetent and dishonest
>>> in their handling of this matter.  Had they simply requested that RTTY
>>> and Data modes as defined in 97.3(c)(7) and 97.3(c)(2) be added to the
>>> emission types where voice and image emission re already permitted and
>>> the 500 Hz limit currently in 97.3(2)(2) be extended to all data modes
>>> below 30 MHz where voice and image are *not* currently permitted, this
>>> matter would be completely non-controversial.  The rules currently limit
>>> non-voice modes to 2.8 KHz (single channel) or 6 KHz (multiplexed) in
>>> the "voice/image" segments - there would be no need to impose a special
>>> limitation.
>>>
>>> The Commission would have gladly made the *minor* changes - which would
>>> prevent the doomsday scenario both you and the ARRL are using to panic
>>> amateurs to support a *bad* proposal which will ultimately destroy
>>> narrow band modes.  If you don't believe that allowing 2.8 KHz data will
>>> destroy the narrow band modes, just wait and see how quickly ALE, STANAG
>>> and other 2.8 KHz "data" modes carrying primarily digital voice start to
>>> pour into the "data allocations" once wideband modes are "blessed" by
>>> this proposal - their advocates are salivating on the sidelines right
>>> now.
>>>
>>> 73,
>>>
>>>    ... Joe, W4TV
>>>
>>>
>>> On 2/27/2014 10:53 AM, Kai wrote:
>>>> Ron,
>>>> Answer:
>>>> Wide bandwidths are not prohibited under today's rules. Bandwidths of up
>>>> to 200 kHz depending on the MF-HF ham band (300 kHz at 10m band) are
>>>> *permitted* today in the digital sections of our bands. Under RM-11708
>>>> there would be a limit of 2.8 kHz, a massive DECREASE in the allowed BW
>>>> for Data/Digital modes.
>>>>
>>>> Band plans like we have already, and courteous operation (like most of
>>>> the RTTY community) are very good ideas.
>>>>
>>>> 73
>>>> Kai, KE4PT
>>>>
>>>>
>>>> On 2/27/2014 1:53 AM, Ron Kolarik wrote:
>>>>> Yup, trust us. This is what one question/answer should look like
>>>>>
>>>>> Q. Did ARRL evaluate the potential for interference to RTTY, CW and
>>>>> narrow bandwidth data modes that could result from an increase in
>>>>> wider-bandwidth data stations? A. Yes. we asked K5RAV and the rest of
>>>>> the ad hoc digital committee and they thought it was
>>>>> okey dokey fine. We'll put a bandplan in after we get enough
>>>>> complaints, we want a bandplan not regulation, it's easier to ignore a
>>>>> bandplan if no one can identify a station or content and
>>>>> no pesky regulations that carry the weight of law.
>>>>>
>>>>> The rest isn't much better and the cynic in me says I should provide
>>>>> new answers
>>>>> to all the questions and send them to Sumner but he has a history of
>>>>> ignoring input.
>>>>>
>>>>> Ron K0IDT
>>>>>
>>>>>
>>>>>
>>>>> ----- Original Message ----- From: "Mark" <n2qt at yahoo.com>
>>>>> To: "Ron Kolarik" <rkolarik at neb.rr.com>
>>>>> Cc: "RTTY" <rtty at contesting.com>
>>>>> Sent: Wednesday, February 26, 2014 10:53 AM
>>>>> Subject: Re: [RTTY] RM-11708 FAQ posted
>>>>>
>>>>>
>>>>> Basically, a "trust us". And if it goes all wrong, well something can
>>>>> be done eventually...
>>>>>
>>>>> Mark. N2QT
>>>>>
>>>>>
>>>>> _______________________________________________
>>>
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