[RTTY] RM-11708 FAQ posted

Joe Subich, W4TV lists at subich.com
Thu Feb 27 16:32:16 EST 2014


Then stop being a shill for the commercial interests that want to
destroy traditional amateur radio.

73,

    ... Joe, W4TV


On 2/27/2014 3:51 PM, Kai wrote:
> 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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