New ARRL petition

[W3MIV]

The League is considering the filing of a new petition challenging some of the changes in the R&O that will become effective on December 15.

From the website: Quote[/b] ]The ARRL Board is discussing the possibility of a petition to reconsider several items in the R&O.



I recommend that all League members send a comment to bandwidth@arrl.org opposing such a submission if the intention is to seek relief against the prohibition of PacTOR III on HF.

I think we have a responsibility to let the League know that the FCC decision was a good one, and that we would like to see it stand. I plan to oppose any petition filed to change that prohibition, and I recommend we all stick tightly together on this.

Email the League today and tell them to leave well enough alone where PacTOR III is concerned.

73

[n5rfx]

I have a peition waiting if they do, and if it seems acceptable to the amateur radio community. I would like comments.

http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_1.htm

73,

Mark N5RFX

[w8cbc]

My thoughts...

I think the main problem is with wideband digital stations not checking adequately for a clear frequency before transmitting. Instead of banning the mode, I suggest more stringent rules concerning identification when it is used. How about a Morse ID in CW, 20 WPM or slower, at the end of each transmission? Then we can know who just blatted out a contact and take whatever measures are necessary to deal with it. The rules concerning interference are already in place. A spate of enforcement letters might help to make these operators more considerate.

[K3UD]

It looks like the ARRL is still going all out for the Yacht and RV owners who do not want to use paid commercial email services. Somehow I think that the FCC knows better since it was not specifically addressed in the R&O.

73
George
K3UD

[W3MIV]

Quote[/b] (w8cbc @ Nov. 16 2006,12:53)]My thoughts...

I think the main problem is with wideband digital stations not checking adequately for a clear frequency before transmitting. #Instead of banning the mode, I suggest more stringent rules concerning identification when it is used. #How about a Morse ID in CW, 20 WPM or slower, at the end of each transmission? #Then we can know who just blatted out a contact and take whatever measures are necessary to deal with it. #The rules concerning interference are already in place. #A spate of enforcement letters might help to make these operators more considerate.
While that may seem a reasonable solution for phone or CW, it will not work with other digital modes. You cannot read a CW ID in PSK or MFSK or Hellschreiber, any of which are as susceptible of interference by wide-mode digital stuff as are CW or phone.

And the current R&O does not ban PacTOR -- it only limites its bandwidth.

73

[WA2ZDY]

Quote[/b] (w8cbc @ Nov. 16 2006,11:53)]Instead of banning the mode, I suggest more stringent . . .
enforcement of the rules regarding third party traffic not being a tool to circumvent normal commercial communication systems. (Yeah, that rule I can't find now. Grrrrrrrrrrrrrrr . . .)

[N5PVL]

It's more of the old Ignorance/Arrogance mix that the ARRL has picked up from its association with TAPR.

Apparently the bunch we have at ARRL HQ must have fallen off of the learning curve when it came to learning how to deal with the FCC - or with the U.S. amateur radio community for that matter.

Totally clueless - and totally arrogant at the same time.

[ky5u]

Quote[/b] (n5rfx @ Nov. 16 2006,09:26)]I have a peition waiting if they do, and if it seems acceptable to the amateur radio community. I would like comments.

http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_1.htm

73,

Mark N5RFX
I read it Mark and it seems what this does is: Amateurs rejected data apps in the phone bands, so this simply tries to get wideband (larger than 500Hz) allowed in the CW subbands. You avoid this outright by saying 2.2kHz bandwidth versus 3.3kHz so that makes it narrowband. The effect is still the same in that legacy modes are put upon by a small number of users. I guess you feel you have a better chance with 30% of Amateurs who use CW than the 90% who use phone to get this over.

Here is my suggestion: Suggest this for the upper 25kHz of the RTTY/Data subband only. That would migrate this wideband data (larger than 500Hz) use away from CW/PSK users and meet your requirement. I suspect there would be little opposition.

[KD6NIG]

I guess the ARRL may be going for the old child way of getting something they want:

Pester the parent so much that they get it for the child, so the child will just be quiet about it, because they are sick of hearing it.

We'll see if it works.

[W3MIV]

Quote[/b] (KD6NIG @ Nov. 16 2006,15:58)]Pester the parent so much that they get it for the child, so the child will just be quiet about it, because they are sick of hearing it.
It seems to have worked for the NCT children. Maybe.

[ab0wr]

Quote[/b] (n5rfx @ Nov. 16 2006,09:26)]I have a peition waiting if they do, and if it seems acceptable to the amateur radio community. #I would like comments.

http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_1.htm

73,

Mark N5RFX
Mark,

A couple of comments.

1. I truly dislike the use of occupied bandwidth for regulation purposes. If you are going to enumerate ITU emission designators in the regulations, use of necessary bandwidth should be all that is required. Even the necessary bandwidth for a PIII signal is usually shown as 2.2khz so it is obvious that although some people will play games with baud rates they can't hide the bandwidth.

2. In your Paragraph 9, I would point out that AFSK *does* require the use of linear amplifiers. AFSK *is* a SSB transmission and you can get just as much intermod on a SSB signal generated from tones out of a computer sound card as you can from the tones out of a D-104 mic.

Linearity is not as important on an FSK signal but whenever you are "instantaneously" changing the frequency in a transmitter you are probably generating some kind of modulation envelope and it would be better in following stages if amplification were done using linear amplifiers in order to minimize spurious products.

3. I do like you having pointed out how the "baud" rule is being played with today in order to generate a loophole for wide bandwidth data signals. It would make much more sense for the FCC to transition to using bits/sec as the proper metric for non-FSK signals. It is this measure, more than anything, that determines the bandwidth needed to carry those types of signal. Use of the ITU designators leads right down this road.

I'll continue to read your proposal and think about it. It isn't something that can be absorbed in a few minutes!

tim ab0wr

[n5rfx]

Quote[/b] (AG4YO @ Nov. 15 2006,13:29)]Here is my suggestion: Suggest this for the upper 25kHz of the RTTY/Data subband only. That would migrate this wideband data (larger than 500Hz) use away from CW/PSK users and meet your requirement. I suspect there would be little opposition.
Charlie,

Thanks. Ok, so there would be a 500Hz subband and another subband. So what should be the bandwidth of the other subband? Should be 1.5 KHz as 97.307(f)(3) suggests or would it be 2.2 KHz to allow Pactor III. I prefer the 1.5 KHz.

Right now I don't see a need to submit this petition. The only reason I wrote the petition in the first place was if the FCC only enacted what I had asked for in the 04-140 petition. Since they decided to limit J2D also, and I saw this was very popular, I wanted to be prepared if the FCC came back and changed the J2D clause not to include 500 Hz. In other words I had a petition ready that could be used to reestablish a bandwidth limit on all modes used in the RTTY/Data subbands. The only reason for 1.5 KHz is because it would not allow Pactor III, but would allow some of the wider keyboard modes like Olivia, MT63, etc , and 1.5 KHz has a foundation in part 97. In fact I had an inclination to make the entire subband 500Hz. The reason I didn't is that in reading the objections to enumerating bandwidths, one of the arguments used is how does the average Amateur measure the bandwidth? I saw many analogies to measuring power, and this argument revolves around the fact that the average ham uses 100 watts, so since the legal limit is 1500 Watts, you do not need to accurately measure power. Bandwidth could work the same way. 1.5 KHz is supported in 97.307(f)(3), it is much wider than most average hams will use in the subband, so accurate measurement will not be required and it still does not allow Pactor III. I went into great detail about this in the petition. I am ok with 500 Hz, but it can be argued that it will be too difficult to measure accurately. I was trying to neutralize objection, but I think you looked at it only as a way to increase bandwidth. That is why I need opinions.

Let me see if I get some other comments, and let me know about your opinion of the other bandwidth.

73,

Mark N5RFX

[n5rfx]

Quote[/b] (ab0wr @ Nov. 15 2006,14:26)]A couple of comments.

1. I truly dislike the use of occupied bandwidth for regulation purposes. If you are going to enumerate ITU emission designators in the regulations, use of necessary bandwidth should be all that is required. Even the necessary bandwidth for a PIII signal is usually shown as 2.2khz so it is obvious that although some people will play games with baud rates they can't hide the bandwidth.

2. In your Paragraph 9, I would point out that AFSK *does* require the use of linear amplifiers. AFSK *is* a SSB transmission and you can get just as much intermod on a SSB signal generated from tones out of a computer sound card as you can from the tones out of a D-104 mic.

Linearity is not as important on an FSK signal but whenever you are "instantaneously" changing the frequency in a transmitter you are probably generating some kind of modulation envelope and it would be better in following stages if amplification were done using linear amplifiers in order to minimize spurious products.

3. I do like you having pointed out how the "baud" rule is being played with today in order to generate a loophole for wide bandwidth data signals. It would make much more sense for the FCC to transition to using bits/sec as the proper metric for non-FSK signals. It is this measure, more than anything, that determines the bandwidth needed to carry those types of signal. Use of the ITU designators leads right down this road.

I'll continue to read your proposal and think about it. It isn't something that can be absorbed in a few minutes!

tim ab0wr
Tim,

The occupied bandwidth vs. necessary bandwidth enumeration is a dilemma for me and I thought long and hard about which one to use. I must have changed that a dozen times, so necessary bandwidth is not a problem for me. I would like to hear more arguments on which one to use.

I have to disagree with you about your AFSK comment. If you are using only one tone at at a time, you do not need linear amplification anywhere. FSK does not require linear amplification. Intermodulation cannot exist when there is only one tone. Harmonics can exist, but not intermodulaton, but I won't get bogged down there, the only reason for the argument is that if you use FSK or AFSK and not multiple parallel tones, your risk of intermodulation is significantly reduced. The argument is used to alleviate concerns about the need to measure bandwidths by the average Amateur. If the average Amateur takes some steps to properly adjust their equipment, intermodulation will not be an issue.

I am glad you picked up on number 3. That is the primary argument in the petition. Because of the intentional circumvention of 97.307(f)(3) and 97.307(f)(4), the narrow bandwidth nature of the RTTY/Data subbands had been lost. That is not the case now with the J2D clause.

With J2D being limited to 500 Hz, that circumvention has been pretty much eliminated, so there is no need for this petition now, but I can guarantee you there will be petitions filed that will try to make arguments to lift the 500Hz limitation on J2D. Maybe this petition is needed, maybe it is not, I just threw it out for comments and I do appreciate you comments Tim.

73,

Mark N5RFX

[ky5u]

Again, I don't care whether it is 1.5 or 2.2 as long as it is in the upper 25kHz of the rtty/data subband. And "upper" means higher in frequency as in close to the phone bands.

You're arguing how many chickens you can fit in the trunk of a VW Beetle and losing sight of the fact that the car is parked on the active runway at a busy airport.

[kc7mrq]

Quote[/b] ] It looks like the ARRL is still going all out for the Yacht and RV owners who do not want to use paid commercial email services. Somehow I think that the FCC knows better since it was not specifically addressed in the R&O.

73
George
K3UD


Of course they are going all out to support that segment George. Once a mainstay, they will find some way to impose the USF tax onto it. http://www.qrz.com/iB_html/non-cgi/emoticons/tounge.gif

Corey

[n5rfx]

Quote[/b] (AG4YO @ Nov. 15 2006,15:08)]Again, I don't care whether it is 1.5 or 2.2 as long as it is in the upper 25kHz of the rtty/data subband. And "upper" means higher in frequency as in close to the phone bands.

You're arguing how many chickens you can fit in the trunk of a VW Beetle and losing sight of the fact that the car is parked on the active runway at a busy airport.
Charlie,

Thanks for the clairification. How about the wider bandwidth where the automatic subbands are now?

Try this freq. chart. (http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_2_appendix_a.htm)

73,

Mark N5RFX

[w8cbc]

Quote[/b] (W3MIV @ Nov. 16 2006,17:13)]While that may seem a reasonable solution for phone or CW, it will not work with other digital modes. You cannot read a CW ID in PSK or MFSK or Hellschreiber, any of which are as susceptible of interference by wide-mode digital stuff as are CW or phone.

And the current R&O does not ban PacTOR -- it only limites its bandwidth.

73
Good points.

I'd thought that pactor 3 needed the wide bandwidth but I guess I was mistaken on that. At any rate, it appears to me that it's the damned fire-away-without-checking operations that are causing all these problems more than the bandwidth involved.

I get you about other digital modes not reading a CW ID. Still, someone who's just been bombed out by one of these things could switch on the audio, change modes, whatever, to read the ID - or perhaps programme something in to read it on the display. I dunno. I don't do digital myself. I would think it possible though.

As to bandwidth - if all 80-metre digital signals are to be confined within the lower 100 kc, I'd definitely want a narrow limit. I can see there'll be some nasty QRM wars going on down there otherwise.

[wd0ct]

Has anyone asked Dr. Phil what he thinks about all this?

[W3MIV]

Quote[/b] (w8cbc @ Nov. 16 2006,18:22)]I'd thought that pactor 3 needed the wide bandwidth but I guess I was mistaken on that.
PacTOR III does need a wide bandwidth, but PacTOR does not have to use level III to be an effective commo tool. Limiting the bandwidth to 500Hz permits PacTOR II operation, which should prove sufficient for most HF work.

Captain Queeg may have to wait a few seconds longer for the pictures of Britney to arrive on his computer, but he should survive that.

http://www.qrz.com/iB_html/non-cgi/emoticons/biggrin.gif

[N5PVL]

N5RFX says:
Quote[/b] ]
How about the wider bandwidth where the automatic subbands are now? #

How about a 500 Hz bandwidth limit for digital signals on HF?

The next few weeks will be a barrel of laughs as ARRL and TAPR folks wriggle around like fresh-caught fish, trying one last weasel way after another to circumvent the letter and spirit of PART97 as restructured by the new R&O.

And the FCC is having none of it. http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif

[ab0wr]

n5rfxQuote[/b] ]I have to disagree with you about your AFSK comment. If you are using only one tone at at a time, you do not need linear amplification anywhere. FSK does not require linear amplification. Intermodulation cannot exist when there is only one tone. Harmonics can exist, but not intermodulaton, but I won't get bogged down there, the only reason for the argument is that if you use FSK or AFSK and not multiple parallel tones, your risk of intermodulation is significantly reduced.

I will agree that once the tone *transition* is done that you will not have intermod since you won't have anything to create mixing products. But during that transition you *will* have other frequencies in play (unless you always transition frequencies at a zero crossing and I don't believe that is a necessary condition for AFSK). Think of it as imposing the back end of a square wave on one tone and the leading edge of a square wave on the other tone. You will see a multiplicity of frequencies involved that, in a non-linear amp, can generate all kinds of intermod.

I would agree with a statement that the intermod may be less in an AFSK or FSK transmitter because you don't have continuous multiple tones that can intermix but I still believe that linear amp stages will be the cleanest way to go.

tim ab0wr

[WA0LYK]

Quote[/b] (ab0wr @ Nov. 16 2006,13:26)]Quote[/b] (n5rfx @ Nov. 16 2006,09:26)]I have a peition waiting if they do, and if it seems acceptable to the amateur radio community. I would like comments.

http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_1.htm

73,

Mark N5RFX
Mark,

A couple of comments.

1. I truly dislike the use of occupied bandwidth for regulation purposes.

3. I do like you having pointed out how the "baud" rule is being played with today in order to generate a loophole for wide bandwidth data signals. It would make much more sense for the FCC to transition to using bits/sec as the proper metric for non-FSK signals. It is this measure, more than anything, that determines the bandwidth needed to carry those types of signal. Use of the ITU designators leads right down this road.

I'll continue to read your proposal and think about it. It isn't something that can be absorbed in a few minutes!

tim ab0wr
Mark,

Let me agree 100% with Tim. I do not agree that any regulation needs to have an occupied bandwidth specified in amateur applications. I DON'T like the new 97.3©(2) that defines 500 Hz as an "occupied bandwidth". If I get the chance to comment on a new petition, I will certainly include a request to change this to "calculated necessary bandwidth".

It seems to me that 97.3(a)(8) will come into play here and we WILL have bandwidth police pointing out violations. In addition, with interference complaints it will be the accused ham who will have to make the measurements needed under 97.3(a)(8) to disprove an allegation with this type of regulation. We've never had to do this before and I detest the need to do it going forward.

I think it would be much better to base the bandwidth "limits" upon the modulation techniques used for any given mode and specify a necessary bandwidth maximum. Part 97 has other paragraphs that can be used to deal with folks whose transmitters are not working correctly and have wider signals than the necessary bandwidth would normally need.

Lastly, I think the FCC "chickened" out on making a ruling on the winlink 2000 so called "service". This ruling effectively eliminates using p3 in this service making it much less attractive. We've never had such a service that operated 24/7/365 with multiple frequencies on the ham bands before and this ruling helps eliminate this service plus any copy cats that would take even more space. I think it puts experimentation and ham-to-ham contacts back into the priority position and this is a good thing.

One last comment, this ruling doesn't eliminate the ability to use p3 altogether. If one uses it in a keyboard to keyboard mode, i.e. J2B, it should be legal.

Jim
WA0LYK

[n5rfx]

Quote[/b] (WA0LYK @ Nov. 15 2006,18:52)]One last comment, this ruling doesn't eliminate the ability to use p3 altogether. If one uses it in a keyboard to keyboard mode, i.e. J2B, it should be legal.
Yes, any of the keyboard B modes should be ok, like Olivia, MT63, Contestia, and RTTYM. That word needs to get out, because there is some misinformation at http://www.arrl.org/news/stories/2006/11/15/100/?nc=1 regarding two of those modes.

73,

Mark N5RFX

[n5rfx]

Quote[/b] (N5PVL @ Nov. 15 2006,17:49)]How about a 500 Hz bandwidth limit for digital signals on HF?
I certainly think it would be generally well received, but I think the 1k keyboard modes like Olivia and MT63 would be missed. The FCC did the right thing by including J2D in the list of 500 Hz maximum occupied bandwidth modes, and it does leave the B modes available. I don't think the circumvention of 97.307(f)(3) and 97.307(f)(4) will be a problem with these modes, but there is still the possibility of abuse. There should be some pretty interesting petitions coming up, and as you said in another post, some good buys on PTC II's too.

I know there is a lot of pressure being put on the staffers at the FCC right now from Amateurs that are not happy about this ruling, so we need to support these guys as much as we can.

73,

Mark N5RFX

[n5rfx]

Quote[/b] (WA0LYK @ Nov. 15 2006,18:52)]It seems to me that 97.3(a)(8) will come into play here and we WILL have bandwidth police pointing out violations. In addition, with interference complaints it will be the accused ham who will have to make the measurements needed under 97.3(a)(8) to disprove an allegation with this type of regulation. We've never had to do this before and I detest the need to do it going forward.
I agree with your concern Jim and that is one reason why I chose 1.5 KHz as the maximum occupied bandwidth.

From my paragraph 8:
Quote[/b] ]Some Amateur radio operators may be concerned about how to measure occupied bandwidth. Those Amateur radio operators that do not have the necessary equipment to measure occupied bandwidth, can continue to operate using modes that use a fraction of the authorized maximum occupied bandwidth. RTTY emissions using the 5-unit, start-stop, International Telegraph Alphabet No. 2, code defined in ITU-T Recommendation F.1, Division C (commonly known as "Baudot") with a shift of 170 Hz and a Baud rate of 45.5, will occupy less than 500 Hz, and can easily meet the maximum bandwidth requirements proposed in this petition. There are other examples: MFSK16, PSK31, AMTOR, Olivia, and MT63 just to name a few, all have necessary bandwidths that will yield occupied bandwidths well within the proposed limits.

Having knowledge of our occupied bandwidth is not new. The fact is that we are given the requirement to measure occupied bandwidth in 2 places: 97.221©(2) which has been depreciated by the R&O and 97.303(s). When using AFSK modes, occupied bandwidth will simply be your necessary bandwidth +/- your transmitters frequency tolerance. When using PSK modes that approach the 500 Hz limit, reducing your transmitter power by 40 to 60% and careful attention to your transmitter input audio levels should keep your occupied bandwidth very close to your necessary bandwidth. RTTY, MFSK16, PSK31, and PSK63 operators have little to worry about. Similarly in a related requirement, we are required to have knowledge of our spurious emissions by 97.307(d) and I think this is where the larger concerns arise.

But...I don't have a problem with enumerating necessary bandwidth, it is just that occupied bandwidth is the norm in part 97 and it is always simpler to explain things from the viewpoint of the status quo.

73,

Mark N5RFX

[PE1RDW]

It looks like not only ARRL is trying to get the 500 hz limit removed on J2D.
The winlink2000 group has started a whine campaign urging everyone to write to the congresmen fcc etc. to fix it, they even go as far as trying to get the agenties that they first got to fund their winlink stations to also write to the fcc etc.

[ab0wr]

Quote[/b] (PE1RDW @ Nov. 17 2006,02:34)]It looks like not only ARRL is trying to get the 500 hz limit removed on J2D.
The winlink2000 group has started a whine campaign urging everyone to write to the congresmen fcc etc. to fix it, they even go as far as trying to get the agenties that they first got to fund their winlink stations to also write to the fcc etc.
Are you surprised?

The ARRL is trying to scare people into thinking that J2B modes are going to be made illegal as well in order to stir up the FUD factor (Fear, Uncertainty, Doubt) and generate more opposition.

They should be ashamed!

tim ab0wr

[AC0H]

Quote[/b] ]I get you about other digital modes not reading a CW ID. #Still, someone who's just been bombed out by one of these things could switch on the audio, change modes, whatever, to read the ID - or perhaps programme something in to read it on the display. #I dunno. #I don't do digital myself. #I would think it possible though.

Not with a proprietary system.
Pactor II and III are proprietary to SCS and they aren't allowing anybody to write software to decode it with a sound card. Seems they want you to pony up the kilobuck for their modem, which doesn't do any other digital modes.

How many CW or narrow mode digi ops are going to do that so they can police the unruly Pactor ops?

[n5rfx]

Quote[/b] (ab0wr @ Nov. 16 2006,06:53)]Are you surprised?

The ARRL is trying to scare people into thinking that J2B modes are going to be made illegal as well in order to stir up the FUD factor (Fear, Uncertainty, Doubt) and generate more opposition.
Good answer Tim, this should be spread far and wide!

73,

Mark N5RFX

[W3MIV]

Quote[/b] (n5rfx @ Nov. 17 2006,10:11)]Quote[/b] (ab0wr @ Nov. 16 2006,06:53)]Are you surprised?

The ARRL is trying to scare people into thinking that J2B modes are going to be made illegal as well in order to stir up the FUD factor (Fear, Uncertainty, Doubt) and generate more opposition.
Good answer Tim, this should be spread far and wide!

73,

Mark N5RFX
As I stated in the lead post, one of the best things any of us can do is email the League and state clearly your opposition to changing what the FCC has mandated in the R&O.

Flood them with emails; it may or may not do any good, but it will put them on notice as to how many members feel about the potential for wide-bandwidth digital interference.

Also, emails to Directors are in order here. Phone them if you have their number and let them know just how you feel about this issue.

[ky5u]

Quote[/b] (n5rfx @ Nov. 16 2006,15:09)]Quote[/b] (AG4YO @ Nov. 15 2006,15:08)]Again, I don't care whether it is 1.5 or 2.2 as long as it is in the upper 25kHz of the rtty/data subband. And "upper" means higher in frequency as in close to the phone bands.

You're arguing how many chickens you can fit in the trunk of a VW Beetle and losing sight of the fact that the car is parked on the active runway at a busy airport.
Charlie,

Thanks for the clairification. How about the wider bandwidth where the automatic subbands are now?

Try this freq. chart. (http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_2_appendix_a.htm)

73,

Mark N5RFX
Alot better Mark. This sets gravitational places for modes without specifying the modes themselves. I also think you should specify as wide a bandwidth as the area you set aside will accomodate for "wide" data. Up to 9kHz even in the areas you specify. Lets ensure the digital folks can cut loose and do their thing in these allocations.

[ky5u]

Quote[/b] (wd0ct @ Nov. 16 2006,16:16)]Has anyone asked Dr. Phil what he thinks about all this?
No more of your Phil-landering!

[N5PVL]

Note how at this late date, no news item about the R&O being published in the federal register has made to the NEWS section here at QRZ.

[KD6NIG]

Quote[/b] (wd0ct @ Nov. 16 2006,16:16)]Has anyone asked Dr. Phil what he thinks about all this?
He thinks we're all nuts.

But if we could also tell him about how we're cheating on our wives with a few other women, or anything like that, he'll fly us in, pay our hotel, and pay us for our appearance on his show.

Otherwise though, we're all nuts and he's leaving it at that http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif

[W3MIV]

Quote[/b] (N5PVL @ Nov. 17 2006,13:06)]Note how at this late date, no news item about the R&O being published in the federal register has made to the NEWS section here at QRZ.
Are we to assume a conspiracy?

Are we to presume Fred is in collusion with the folks at ARRL, TAPR and WinLink?

http://www.qrz.com/iB_html/non-cgi/emoticons/rock.gif

[KD6NIG]

Quote[/b] (PE1RDW @ Nov. 17 2006,02:34)]It looks like not only ARRL is trying to get the 500 hz limit removed on J2D.
The winlink2000 group has started a whine campaign urging everyone to write to the congresmen fcc etc. to fix it, they even go as far as trying to get the agenties that they first got to fund their winlink stations to also write to the fcc etc.
Well, yeah, the pocketbook argument always works. If they can't get this passed, there are a lot of $1000 modems out there that are going to become useless to people.

And I don't see the ARRL or anyone else offering refunds on them.

I guess, worst case, it would make a good doorstop http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif

[W3MIV]

Quote[/b] (KD6NIG @ Nov. 17 2006,13:15)]Quote[/b] (PE1RDW @ Nov. 17 2006,02:34)]It looks like not only ARRL is trying to get the 500 hz limit removed on J2D.
The winlink2000 group has started a whine campaign urging everyone to write to the congresmen fcc etc. to fix it, they even go as far as trying to get the agenties that they first got to fund their winlink stations to also write to the fcc etc.
Well, yeah, the pocketbook argument always works. #If they can't get this passed, there are a lot of $1000 modems out there that are going to become useless to people.

And I don't see the ARRL or anyone else offering refunds on them.

I guess, worst case, it would make a good doorstop http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif
I don't see why they would become "useless;" one would simply have to limit them to PacTOR I or PacTOR II operation.

I have no idea how easy or difficult that may be, since I do not own a modem (I use only soundcard digital modes) and don't plan to acquire one no matter how steep the discount.

Even were it to become "useless," there is nothing new or unusual about that. The computer has put a whole lot of gear out to pasture over the past score of years.

The only ones who may be sucking air, it would seem, will be the folks at SCS who will have to punt the majority of their sales to the commercial market, if they have not already dones so.

[n5rfx]

Quote[/b] (AG4YO @ Nov. 16 2006,09:11)]I also think you should specify as wide a bandwidth as the area you set aside will accomodate for "wide" data. Up to 9kHz even in the areas you specify. Lets ensure the digital folks can cut loose and do their thing in these allocations.
I suppose no bandwidth enumeration is needed for the areas which are now the automatic subbands, just like the Phone/Image subbands. Here is another look at the frequency chart. Also I replaced occupied bandwidth with necessary bandwidth.

possible compromise frequency chart (http://home.comcast.net/~mdmiller7/arrl_alt/fcc_pet_digital_3_apendix_a.htm)

[N5PVL]

AG4YO says:
Quote[/b] ]
I also think you should specify as wide a bandwidth as the area you set aside will accomodate for "wide" data. #Up to 9kHz even in the areas you specify. #Lets ensure the digital folks can cut loose and do their thing in these allocations.

How many do you figure will "cut loose" if a single QSO takes up the entire allocation, Charlie?

The 500 Hz limit for data modes is just fine as it stands.

We do not need a TAPR-sponsored "compromise" that screws things up for the majority of the affected hams so that a tiny minority will get their way despite good sense and good operating practice.

Haven't we had enough of that kind of thinking?

[ky5u]

Quote[/b] (N5PVL @ Nov. 17 2006,10:42)]AG4YO says:
Quote[/b] ]
I also think you should specify as wide a bandwidth as the area you set aside will accomodate for "wide" data. Up to 9kHz even in the areas you specify. Lets ensure the digital folks can cut loose and do their thing in these allocations.

How many do you figure will "cut loose" if a single QSO takes up the entire allocation, Charlie?

The 500 Hz limit for data modes is just fine as it stands.

We do not need a TAPR-sponsored "compromise" that screws things up for the majority of the affected hams so that a tiny minority will get their way despite good sense and good operating practice.

Haven't we had enough of that kind of thinking?
Charles,

We differ in opinion. I believe we should encourage experimentation with a plan like Mark is now suggesting where wideband use has its own area. They can practice getting along with each other too which may help them get along with the rest of us better.

I have said all along that I am not anti-digital, I am anti-interference with legacy modes.


Mark,

I see what you're trying to do. An easy solution to fix the problem. I like where you are now.

[N5PVL]

If interference to digital users by a tiny minority of diehard "HF Hinternet" Lids is part of your agenda Charlie, then yes we most definately have differing opinions.

Sheesh! #http://www.qrz.com/iB_html/non-cgi/emoticons/rock.gif

Nice that the FCC has good sense about the true value of the "HF Hinternet" concept and the string of bogus proposals it has engendered during the last few years.

I suppose that ignoring one more of the dozens of whine-o-grams they'll be reading this month will not stretch the commissioners too much so Mark's suggestions are not really much of a problem.

The commission appears to be quite clear about their intentions and I seriously doubt that one more whine from the people who have made a fashion out of flouting the PART97 regulations for years is going to make much of an impression upon them.

Hence the need to get somebody from SPAR involved in joining the "Hinternet" chorus. - They get extra points for turning somebody who was involved in SPAR's response to the bandwidth segmentation proposal.

[ad4mg]

I tend to agree with Charlie. #Interference mitigation is the solution to the problem most folks have with automatic pactor stations. #Put them somewhere where they have to learn to play well together, and where they can bother only each other, and the problem is solved.

There is ample room for everyone if the spectrum is wisely utilized. #It is just as selfish to deny others room to operate as it is for them to attempt to run rampant throughout the limited available spectrum.

I'll add that I still do not approve of Winlink's promoting the use of their service to replace already available commercial services offering the same service, for a fee. #That gives them (WL2K) the appearance of being a bunch of rich cheapskates.

FWIW.

[n5rfx]

AG4YO:
Quote[/b] ] have said all along that I am not anti-digital, I am anti-interference with legacy modes.
Mark,
I see what you're trying to do. An easy solution to fix the problem. I like where you are now.

Charlie, thanks for the input. I will be looking for more input as we learn what other groups do.



N5PVL:
Quote[/b] ]Hence the need to get somebody from SPAR involved in joining the "Hinternet" chorus. - They get extra points for turning somebody who was involved in SPAR's response to the bandwidth segmentation proposal.

Charles, this is not a contest. I hope that we have to do nothing but I am a realist and am positive that one or more petitions will be filed. We will just have to wait and see.

I appreciate all comments and concur with Albert that everyone needs to write their ARRL officials. Here is what I wrote:
Quote[/b] ]
Dear Sirs,

With respect to the Nov 16, 2006 news story at http://www.arrl.org/news/stories/2006/11/15/100/?nc=1 ,the ARRL Board should not file a petition to reconsider several items in the R&O with respect to the elimination of J2D emissions. The amateur radio community will be happy to see an end to PACTOR III at full capability. It is not entirely clear that other digital modes will be effectively rendered illegal below 30 MHz including Olivia and MT63 (when operated at bandwidths greater than 500 Hz), Other than the 10 meter band where is 1200-baud packet operated on HF?, Q15X25 and Clover 2000 are rarely used modes. Find out what your constituents want, and I think you will see that you should leave well enough alone.


I am not sure if my opinon is the popular one or the right one but it is my opinion.

73,

Mark N5RFX

[N5PVL]

Many moons ago, the FCC established the 300 baud limit for HF. At that time it was believed that setting a baudrate limit also set a bandwidth limit.

Since then, several outfits have flouted the intent of the 300 baud limitation by utilizing multiple carriers or tones ( within the same transmission ) that are individually are less than 300 baud but when utilized collectively can add up to quite a bit more.

Q15x25 mode for example utilizes 15 relatively slow PSK streams to achieve a virtual 2500 baud on HF. It is also close to 2600 Hz wide.

When you look at digital modes like Q15x25 and PACTOR III, you are seeing software that obviously goes far beyond the spirit and many would say the letter of the FCC's original 300 baud limit for HF.

This went on for years, engendering a culture that disparaged the PART97 regulations and actively worked to encourage all their fellow hams to join in defying them. Thus the wide HF modes became pet darlings of the digital elitists at TAPR who never got over the fact that nobody ever really liked amateur TCPIP in the 80's or 90's.

More recently, digital elitists decided to push the idea of an HF "Hinternet" to gullible ARRL HQ staffers with the results we have recently seen... - One moonbat "Hinternet" proposal after another to:

* Let wide digital modes run rampant on HF.

* Utilize ham freqs as a common carrier in competition with established commercial services.

* Eliminate content restrictions that protect us from porn and from cheapskate idiots using the ham bands to conduct business.

* Make peer-review by fellow amateurs virtually impossible if not impossible in fact.

* Introduce encryption to the ham bands so they can flout any remaining regulations with impunity.

So now the FCC finds a way to straighten out this mess without having to toss anybody into the pokey by clarifying the intent of the 300 baud rule with an accompanying 500 Hz limit for data transmissions.

This decision by the FCC was ingenious as it settled a number of troubling issues at the same time:

* The old 300 baud rule, so casually flouted, was reaffirmed and given some backbone with the 500 Hz bandwidth limit for data modes. This is quite generous if you note the bandwidth of the 300 baud Packet signal.

( Note that this limit affects "data modes", that is the automated or semi-automated systems, not keyboarders who may still enjoy MT63, Olivia, etc. despite the ARRL's lies. )

* WinLink2000 will be able to continue to operate with PACTOR II, but will no longer be able to "compete" with commercial services that may utilize PACTOR III. Note that all that is really being taken away is the ability to flout PART97 by engaging in such competition.

* The HF "Hinternet" concept with it's mindless proliferation of ultra-wideband digital modes all over HF has finally, definitively been put to rest.

* Software authors overseas attempting to influence U.S. amateur radio regulations by authoring software specifically designed to flout those regs have been rebuffed.

All amateurs should be breathing a big sigh of relief at this restructuring of PART97, which reaffirms the facts that our spectrum is not intended for commercial purposes and is not intended to become a part of the Internet. We are gently reminded that we are governed by protective regulations that we should honor, not attempt to undermine or flout.

The only ones getting hurt are those who have specifically worked against the very rules and regulations which protect and define amateur radio.

Everyone else, and that is by far the great majority of US hams only stand to benefit from this 500 Hz. limit on data transmissions.

[n5rfx]

Quote[/b] (N5PVL @ Nov. 16 2006,18:32)]* The old 300 baud rule, so casually flouted, was reaffirmed and given some backbone with the 500 Hz bandwidth limit for data modes. This is quite generous if you note the bandwidth of the 300 baud Packet signal.

( Note that this limit affects "data modes", that is the automated or semi-automated systems, not keyboarders who may still enjoy MT63, Olivia, etc. despite the ARRL's lies. )
Charles,

I agree with your analysis but I will point out that the 300 Baud rule is 300 Baud with a 1 kHz shift. That is 1.5 kHz not 500 Hz. 500 Hz is fine, but you can't look to the 300 Baud rule for justification. I hope the J2D rule can stand up to scrutiny.

73,

Mark N5RFX

[N5PVL]

On the waterfall display, 300 baud Packet looks to be around 200 Hz wide, and MT63 takes up 1000 Hz in its default mode.

There is a 500 Hz mode for MT63 that I have never tried out. If my experiences with the scalable 1000-3000 bps modem for Q15x25 mode are any guide, then the 500 Hz version of MT63 may perform better under poor band conditions, compensating for the lower data rate.

If they once had 300 baud Packet with a 1.5 kHz shift, they probably went over to a 200 Hz shift because it performed so much better. - I've never heard of 300 baud Packet with a 1.5 kHz shift though. I have a feeling that it would be a real bow-wow because it would make such a big fat target for interference.

Our most stubborn obstacle in trying to advance digital amateur radio in the US has been political, not technical. - The European Packet network proves that.

The 500 Hz data mode limit is much more than a technical limit. - It also definitively undermines the political faction that has been holding us back in the USA for decades. Far from placing us in a 'technology jail', it will in fact liberate the US digital community from some crippling misconceptions that have held back and retarded our progress for years.

The political fortunes of those who have propounded the HF 'Hinternet' will now decline, and they will be replaced by amateurs who are more interested in what you can do with radio than in what you can do with the ( yawn ) internet.

It's a good thing.

[N5PVL]

Letterman had it right ( for once ) ...

Dr. Phil is a blockhead.

[n5rfx]

Quote[/b] (N5PVL @ Nov. 16 2006,19:48)]If they once had 300 baud Packet with a 1.5 kHz shift, they probably went over to a 200 Hz shift because it performed so much better. - I've never heard of 300 baud Packet with a 1.5 kHz shift though. I have a feeling that it would be a real bow-wow because it would make such a big fat target for interference.
Charles,

A 300 baud 200 Hz shift packet gives you a necessary bandwidth of 540 Hz. The occupied bandwidth will be a little higher As far as I know there was never an actual 300 baud 1 or 1.5 KHz shift packet mode. What I was referring to is the regulation 97.3.(f)(3).
Quote[/b] ]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.
If you use the necessary bandwidth formula you will get 1.5 kHz.

The necessary bandwidth formula from Part 2.202

Bn=2M+2DK, M=B/2, K=1.2 (typically)

where

Bn = Necessary bandwidth in hertz

B = Modulation rate in bauds

M = Maximum modulation frequency in hertz

D = Peak frequency deviation, i.e., half the difference between the

maximum and minimum values of the instantaneous frequency.

K = An overall numerical factor which varies according to the emission

and which depends upon the allowable signal distortion.

73,

Mark N5RFX

[N5PVL]

Can you explain why only 200 Hz. or so of the 540 Hz. HF Packet signal shows up on the waterfall display?

Does it involve "dark RF" that can't easily be detected, like dark matter in the universe?

Excuse my ignorance; I'm just trying to figure out where that other 240 Hz went.

[n5rfx]

Charles,

Yes. When you frequency modulate a carrier, the necessary and occupied bandwidth will always be greater than the shift. The frequency spectrum of an actual FM signal has components extending out to infinite frequency, although they become negligibly small beyond a point. Another easy way to estimate bandwidth of an FM signal is to use Carson's bandwidth rule. This rule is expressed by the relation CBR = 2(Δf + f m) where CBR is the bandwidth requirement, Δf is the peak frequency deviation, and f m is the highest modulating frequency. Using this formula for our HF packet example Δf is 100 because deviation is half of the shift. f m would be 150, because the frequency would be half the baud rate. so 250 *2 is 500. But the occupied bandwidth is going to be greater.

I have some pictures for you. First is a waterfall display of a 300 baud 200 Hz shift packet signal.
300 baud 200 Hz shift AX.25 (http://home.comcast.net/~mdmiller7/imd/HF_Packet.jpg)
As you can see the occupied spectrum is greater than 200 Hz. A waterfall display is not a very good way to determine bandwidth. A spectrum analyzer is better.
Spectrum Analyzer/Occuiped Bandwidth 300 baud 200 Hz AX.25 (http://home.comcast.net/~mdmiller7/imd/SA_HF_Packet.jpg)
The occupied bandwidth is 810 Hz using the 26 dB down method. This is the method specified by the FCC. We will have to hope that AX.25 is not J2D.

73,

Mark N5RFX

[ab0wr]

I think you will find that at the time these limits were developed there were lots of commercial RTTY units still using 850hz shifts. I know some hams used these but I'm not sure just how popular they were. These units used vacuum tube oscillators and setting them accurately wasn't the easiest thing to do back then. I suspect the FCC settled on 1000hz as a compromise that almost everything would fit into. As Charles correctly pointed out, as soon as 170hz stuff became available it was jumped on both because it took up less bandwidth but it was also more noise immune.

As with much of the FCC regulations, these limits are holdovers from days long gone. If someone *really* wanted to write an *omnibus* petition it would need to modify a lot of the rules to bring them up to modern metrics.

Charles is also right about people flaunting the baud rate limit by using multiple tones. I think I may have even found some mathematical backup for this.

If you look at the Hartley-Shannon law it is based on a (1+s/n) factor where s is the maximum signal power and n is the noise power. In essence the s/n factor tells you how many divisions the "s" power can be broken into in order to send multiple bits per signal. Each division has to be just a little bit larger than the noise power or you won't be able to tell when the next "level" is being sent.

The H-S law says the amount of data you can send is related to the product of the bandwidth of the signal and the base2 log of the factor above.

If your signal all of a sudden becomes a multiplicity of sub-tones, then the power "s" in the factor above is no longer the maximum power of the signal but the average power of the signal - i.e. the total power of the signal divided by the number of tones being used (because you still need to be able to tell when a single tone changes state).

One of two results occur. Either the total information that can be sent goes down because (1+ s/n) goes down or the bandwidth required to send a specific amount of information goes up in order to maintain a specific data rate.

The true bottom line is that anyone who says "I am sending multiple tones at a rate less than X baud" is obfuscating the facts. Baud rate was never meant to describe anything more than a single signal, it was certainly not meant to describe a multiplicity of signals artificially conglomerated. The H-S law would seem to confirm this.

tim ab0wr

[N5PVL]

FM Packet has been tried on HF but it must not have worked out because they had already dropped it and moved on by the time I heard about it.

AX25 doesn't have a particular bandwidth. If 300 baud HF Packet turns out to be illegal under the reorganization, that means I get to play with new software, possibly a new mode. Somehow I doubt that will be the case though.

Note that while any idiot can diss HF Packet and many have for over a decade, nobody has come up with anything that handles the same tasks nearly as well, much less any better.

A combination of familiar HF Packet with HF Multicast protocol will allow us to do much more than is currently expected out of an HF digital network, outperforming the internet in some areas. Once we leave the "Hinternet" baggage behind and are no longer afraid to do things that look and function differently from the internet, I expect to see a wave of creativity arise that we should and could have seen ten years ago.

[n5rfx]

Quote[/b] (N5PVL @ Nov. 16 2006,23:37)]FM Packet has been tried on HF but it must not have worked out because they had already dropped it and moved on by the time I heard about it.
Charles,

Just to clarify, the displays were not F2 emissions, they were J2 emissions. AFSK is what is comming out of the TNC/soundcard, the SSB transmitter simply does a frequency translation. At the antenna you get FSK which is FM. I agree it is not F2 FM like we would find on 2 meters, but it is F1 FM.

I have not seen a CSMA protocol that beats AX.25 on HF. I have tried Q15X25 a couple of years ago, and was not impressed. We were able to go to 300 Baud 200 Hz shift AX.25 and communicate pretty well. I saw some work adding FEC to AX.25, but have not tried it on HF. I think that would be interesting to test.

73,

Mark N5RFX

[kb3mng]

Quote[/b] (N5PVL @ Nov. 17 2006,17:32)]When you look at digital modes like Q15x25 and PACTOR III, you are seeing software that obviously goes far beyond the spirit and many would say the letter of the FCC's original 300 baud limit for HF.
What definition of "baud" do you use to reach that conclusion? I have always known "baud" to mean "1 potential signal transition per second". As long as the transitions occur no more than 300 times per second (no matter how many bits are transmitted by each transition), doesn't that signal meet the requirements?

[N5PVL]

KB3MMG asks:
Quote[/b] ]
What definition of "baud" do you use to reach that conclusion? #I have always known "baud" to mean "1 potential signal transition per second". #As long as the transitions occur no more than 300 times per second (no matter how many bits are transmitted by each transition), doesn't that signal meet the requirements?

Apparently not.

You'd have to take the wayback machine to get a good sense of what was going on back in the eighties with digital ham radio. ( I think we are talking about the early eighties, but it could have been the late seventies without surprising me at all. )

At any rate, I wasn't there and can't say what definition of baud rate the FCC was using. The one thing that we can be certain of is that the FCC interpretation of the matter, whatever it may be, is the only one that signifies.

One thing I am curious about is whether the 300 baud rule is still there. - Was it superceded by the 500 Hz. rule, or do they work in tandem?

[ab0wr]

Quote[/b] (kb3mng @ Nov. 18 2006,00:39)]Quote[/b] (N5PVL @ Nov. 17 2006,17:32)]When you look at digital modes like Q15x25 and PACTOR III, you are seeing software that obviously goes far beyond the spirit and many would say the letter of the FCC's original 300 baud limit for HF.
What definition of "baud" do you use to reach that conclusion? #I have always known "baud" to mean "1 potential signal transition per second". #As long as the transitions occur no more than 300 times per second (no matter how many bits are transmitted by each transition), doesn't that signal meet the requirements?
If you have a modem putting out 1000 tones into your microphone attached to your SSB transmitter, with each tone transitioning at 100 baud, do you have a 100 baud signal? Or do you have a 1000 x 100 = 100000 baud signal?

Certainly the bandwidth for 1 tone at 100baud is much different than for 1000 tones each signaling at 100 baud.

The FCC was using the baud rate limit of 300baud to try and set a *bandwidth* limit on signals in the amateur bands. At the time the FCC was doing this multi-tone modems weren't in use on the ham bands (if they even existed at all). Almost all digital signals were FSK using ONE signal or were pure off/on systems. In this scenario the baud rate is closely tied to the bandwidth the signal uses.

If you take a multi-tone modem, however, and conglomerate the tones and call it ONE symbol then you are sending ONE symbol per second (i.e. ONE baud) even though your bandwidth may be 20khz (e.g. 1000 tone modem with 200hz channels).

You have just lost any relationship between baud rate and bandwidth -- i.e. you have found a *loophole* in the regulations.

It is this that Charles was addressing. For instance, Pactor III uses 18 tones. As long as you call all 18 tones ONE symbol and use a base transition rate of 100baud you meet the FCC regs even though you have a 2.2khz bandwidth signal (100 baud -> 2.2khz). If, on the other hand, you count each tone separately you are signaling at 18 tones x 100 baud/tone = 1800 baud (1800baud -> 2.2khz). This is a much closer estimation of the actual bandwidth used for the signal.

There are two ways to handle this. 1) require that baud rate calculations be on a per-signal basis which would require each tone to be considered separately (e.g. a 1000 tone modem at 100 baud per tone would equal 100000 baud) or 2) move to a straight bandwidth metric.

The FCC seems to be moving to a bandwidth metric and they haven't left much doubt as to what they consider to be a proper bandwidth in the narrow-band portions of the HF amateur spectrum -- at least when the communications involve sending images or data. This won't affect the 0.9% (that's .009) of HF amateurs that use keyboard-to-keyboard communications on a digital basis which is considered to be direct automatic printing telegraphy and is not considered to be "data". It *will* significantly affect the 0.1% (that's .001) of HF amateurs who are into using wideband, multi-tone signals to pass computer data (i.e. internet access links) into their computers.

tim ab0wr

[ab0wr]

Quote[/b] (n5rfx @ Nov. 17 2006,23:19)]Quote[/b] (N5PVL @ Nov. 16 2006,23:37)]FM Packet has been tried on HF but it must not have worked out because they had already dropped it and moved on by the time I heard about it.
Charles,

Just to clarify, the displays were not F2 emissions, they were J2 emissions. #AFSK is what is comming out of the TNC/soundcard, the SSB transmitter simply does a frequency translation. #At the antenna you get FSK which is FM. #I agree it is not F2 FM like we would find on 2 meters, but it is F1 FM.

I have not seen a CSMA protocol that beats AX.25 on HF. #I have tried Q15X25 a couple of years ago, and was not impressed. #We were able to go to 300 Baud 200 Hz shift AX.25 and communicate pretty well. #I saw some work adding FEC to AX.25, but have not tried it on HF. #I think that would be interesting to test.

73,

Mark N5RFX
Wait a minute. You are implying that J2 and F1 are the same. They are not.

When I run HF packet I use straight FSK (F1), not AFSK (J2). My icom 751a has FSK oscillators which are used in the RTTY mode. These same oscillators work fine for HF packet. In fact, I have them tuned for a 200hz shift which makes them less efficient on RTTY but right on for HF packet and Pactor 1.

J2 may look like F1 but it isn't the same. If it was, all you would have to do to get around the new regs is to call your signal an F1D emission instead of a J2D emission. F1D is not in the list of emissions that are limited to 500hz. #

tim ab0wr

[n5rfx]

Quote[/b] (ab0wr @ Nov. 17 2006,06:54)]Wait a minute. You are implying that J2 and F1 are the same....They are not.
J2 may look like F1 but it isn't the same. If it was, all you would have to do to get around the new regs is to call your signal an F1D emission instead of a J2D emission. F1D is not in the list of emissions that are limited to 500hz.

tim ab0wr
I am not implying, it is a fact. F1 and J2 can be exactly the same emission. Properly adjusted AFSK using J2 is indistinguishable from FSK F1.

73,

Mark N5RFX

[ky5u]

Quote[/b] (N5PVL @ Nov. 18 2006,04:36)]You'd have to take the wayback machine to get a good sense of what was going on back in the eighties with digital ham radio. ( I think we are talking about the early eighties, but it could have been the late seventies without surprising me at all. )

At any rate, I wasn't there and can't say what definition of baud rate the FCC was using. The one thing that we can be certain of is that the FCC interpretation of the matter, whatever it may be, is the only one that signifies.
I believe you've hit on the issue, Charles. My belief is that the FCC was interested in occupied bandwidth and the 300 baud limit was their calculation of what would occupy an acceptably small footprint. Enter today's renaissance man, the digital knothead, with his creative interpretation of the rules. To them if you have a multi-carrier signal (like OFDM) that is 25kHz wide but you only vary each carrier on and off within the definition of 300 baud then, by golly, you're legal! It's just goofy. That is why I would support a specific segregated area like the automatic subband for them to run free in their BVDs, smelling the wildflowers, and petting little furry bunnies.

There are "fer' shure" a subset of digital people who tend to view capital punishment as assisted suicide where legacy modes are concerned. I believe a much larger group just wanting to dabble and experiment and simply want the FCC to spell out what they can and can't do legally.

[n5rfx]

Quote[/b] (AG4YO @ Nov. 17 2006,07:36)]My belief is that the FCC was interested in occupied bandwidth and the 300 baud limit was their calculation of what would occupy an acceptably small footprint.
Charlie,

That is correct. They chose 300 baud with a 1000 Hz shift. When using the necessary bandwidth calculations in Part 2.202 the bandwidth is 1500 Hz. I am not sure when that Baud rate and shift were first codified. The oldest Part 97 text that I have is from 1987 and it was there then. Not surprisingly, the only non-CW digital emission authorized was F1B.

I generated a 300 baud 1000 Hz shift transmission last night and looked at it on a spectrum analyzer, the occupied bandwidth was around 2 kHz.

73,

Mark N5RFX

[W3MIV]

Quote[/b] (AG4YO @ Nov. 18 2006,09:36)]There are "fer' shure" a subset of digital people who tend to view capital punishment as assisted suicide where legacy modes are concerned. #I believe a much larger group just wanting to dabble and experiment and simply want the FCC to spell out what they can and can't do legally.
While you are probably right, Charlie, I think you are standing in the tracks trying to hold back an approaching freight train.

All of this seems a carefully crafted effort on the part of the FCC, and I don't think they are looking to satisfy users of legacy modes -- either current or future -- any more than they are worried about cutting into Advanced frequency privileges or the current users of some wideband digital modes.

I believe they have a "vision" of where they want to go, and that they are going to move us there -- kicking and screaming if needs be.

73

[ky5u]

Quote[/b] (W3MIV @ Nov. 18 2006,07:03)]Quote[/b] (AG4YO @ Nov. 18 2006,09:36)]There are "fer' shure" a subset of digital people who tend to view capital punishment as assisted suicide where legacy modes are concerned. I believe a much larger group just wanting to dabble and experiment and simply want the FCC to spell out what they can and can't do legally.
While you are probably right, Charlie, I think you are standing in the tracks trying to hold back an approaching freight train.

All of this seems a carefully crafted effort on the part of the FCC, and I don't think they are looking to satisfy users of legacy modes -- either current or future -- any more than they are worried about cutting into Advanced frequency privileges or the current users of some wideband digital modes.

I believe they have a "vision" of where they want to go, and that they are going to move us there -- kicking and screaming if needs be.

73
If the rules are fair and consider today's use patterns, then that would be all we could reasonably expect.

[W3MIV]

Quote[/b] (AG4YO @ Nov. 18 2006,10:08)]If the rules are fair and consider today's use patterns, then that would be all we could reasonably expect.
Ay, an' there's the rub.

My view is that they are looking to some future use patterns that they perceive to be considerably different than those current.

I believe their view is of burgeoning phone, especially SSB, and growing digital data modes in the years just ahead, and alas, slowly shrinking CW ops. Like it or not, it is a reasonable prediction on their part, given their stated intentions.

As to how "fair" it is, I doubt that they really view the issue from that perspective, which ultimately is highly subjective in itself. I'd be willing to bet that Waterman, Poor & Co think this R&O is grossly "unfair," while I consider it to be eminently just.

What we need to do is be prepared to do all we can to make the League hold the current line and not go crying to the FCC to make changes that will only muddy the waters and possibly make things worse for us.

73

[N5PVL]

AG4YO says:
Quote[/b] ]
That is why I would support a specific segregated area like the automatic subband for them to run free in their BVDs, smelling the wildflowers, and petting little furry bunnies. #

Charlie, you are forgetting that the hams who currently occupy the automated sub-bands are just as deserving of considerate operating behavior as anyone else.

Ever since the announcement of the recent FCC R&O, I have been looking at this kind of deliberate interference (http://www.uspacket.org/pqrm.htm) every single day, several times a day on the 20 meter autoforwarding network I participate in. The signals I have been seeing have been precisely centered up on the working Packet net. There is a chance that this could be unintentional, but I believe that most will agree that it is a very slim one.

If we could depend upon these Lids to "run free in their BVDs, smelling the wildflowers, and petting little furry bunnies" well then I would not have any problem with that except for the valuable spectrum going to waste. Instead, what we get is ongoing, deliberate interference of ongoing nets hosting half a dozen or more Packet ops at a time - by Hinternet Lids running the German PACTOR II and III modes.

If they are doing this now, when they can go just about anywhere in the digital portion of the bands, what would you expect to happen when they are limited to the narrow bits of spectrum set aside for automated systems, as you suggest?

Do you imagine that these career Lids are suddenly going to become good, considerate neighbors?

Once again, you are forgetting that the hams who currently occupy the automated sub-bands are just as deserving of considerate operating behavior as anyone else.

The reason they are so easy to overlook is that they never crash anybody's QSO or try to take up more than their fair share of spectrum. - The idea of those fine amateurs being penalized for that, just in order to appease career Lids ( QSO-busters ) seems wrong to me, somehow.

Silly me!

Hey, since you are sure that these ops will be good neighbors, why not host them in the CW segment? My feeling is that if you do not want these Hinternet Lids in your own backyard, trying to put them in your neighbor's yard instead is not the civilized solution.

This reminds me of the fellow who denied the fact that gun-owning neighbors protected his no-gun household from violence. When asked to prominently display a "Gun-Free Home" sign on his property, he wisely declined.

Why not just go with what the FCC has decided, giving the Hinternet Lids no place to go on HF at all, letting them play their games on VHF and higher where they can't interfere with the global HF community? The FCC has the laws of physics on their side on this one, followed by PART97 and the rules of good, considerate operating practice.

All you have is a nebulous wish to appease the very barbarians who have generated much of the divisiveness and controversy we have had to deal with in the last couple of years.

Sorry OM, but no sale! #- I'll gladly give a fellow ham a break any time - unless he is an inconsiderate Lid.

After you have called the exterminator, do you go to a nearby dumpster and collect a few roaches to distribute in your home, in order to be fair to the cockroach community?

[NN4RH]

Can someone clarify something for me (... just asking this is probably a mistake and will do everything but clarify things!) - and I'll also preface this by noting that I do not follow the technical arguments being made. Anyway ...

I get the impression that at least a few people believe that Pactor III or at least certain implementations of it that's in use by Winlink has been illegal all along.

Has anyone ever actually filed a formal complaint with the FCC on the legality of Pactor III?

If so, what did the FCC actually say about it?

If not, why not?

[N5PVL]

NN4RH:

The present R&O expresses the FCC's opinion quite clearly. Whatever ambiguity existed before about PACTOR III's legality has certainly been resolved now.

I know that the FCC received numerous reports of PACTOR III QRM from PSK31 users and some RTTY and Packet users, as these modes were ( and are ) hit the hardest by PACTOR interference. I have seen PACTOR stations intentionally target active Packet QSO's more times than I have cared to record, as I have a waterfall display of the net frequency I operate on, going full-time. Trying to report all of that would sure keep a fellow busy, especially if you don't have the $1,000.00 modem that is required in order to copy their ID's.

I do not know of any attempt to file a formal complaint with the FCC on the legality of Pactor III... If the ARRL were not totally off-mission, they would have been the ones to handle that chore. - They didn't, and now daddy has had to spank!

[W3MIV]

Quote[/b] (N5PVL @ Nov. 18 2006,12:25)]NN4RH:

The present R&O expresses the FCC's opinion quite clearly. Whatever ambiguity existed before about PACTOR III's legality has certainly been resolved now.
I don't think that's quite accurate, Charles. The big complaint about the legality of PacTOR III was the issue of coding, and whether or not it was "published" in the manner that most of us understood the Rules to require.

In that context, neither PacTOR II nor III would fit the "legal" definition of open publication that lots of posters have asserted as the proper interpretation of the Rules. To my knowledge, that issue has never been clarified to the satisfaction of most of the hams who have argued that PacTOR II and III do not meet the requirement.

I think that all we can now state with certainty is that the Commission seems to recognize the potential for serious interference, a situation that is bad enough now and can only get worse if 05-235 becomes the R&O that many fear.

It would, indeed, be very helpful to everyone were the FCC to make a declarative statement with regard to the status of the proprietary SCS code used, but I wouldn't hold my breath.

73

[N5PVL]

W3MIV says:
Quote[/b] ]
I don't think that's quite accurate, Charles. The big complaint about the legality of PacTOR III was the issue of coding, and whether or not it was "published" in the manner that most of us understood the Rules to require.


I never mentioned that issue and as far as I know, yours is the first mention of it in this topic. Maybe I missed it somewhere, I dunno. - At any rate, I was thinking about the bandwidth issue and the 300 baud rule, not the proprietary nature of SCS's soft/firmware.

Don't feel bad about it though... There are so many legal issues associated with WinLink and PACTOR III that it is hard to keep track of which one is currently being discussed.

My personal opinion is that proprietary software and hardware has its place for the obvious reasons involving development costs. I don't like it, but I understand why it is there. None of this has any bearing upon the issue of legality, though. Our difficulty almost exclusively arises from software written overseas where the rules are not the same as ours, where they exist at all.

Because of this, the ARRL should assist the ham community in actively self-policing in order to avoid illegal operation, not be a part of the gang who flouts the FCC regulations, as they stand today with ARESCOM and WL2K.

They're supposed to be mature enough to try to affect changes by working with the system, Albert. Instead they have aligned themselves with frustrated hooligans who try to affect change through deliberately flouting the PART97 regulations and thumbing their noses at the FCC.

Right now, freshly chastised, they are soberly considering the idea of standing in unison, facing the winds of change while they take a good long pee.

[n5rfx]

Quote[/b] (NN4RH @ Nov. 17 2006,10:02)]I get the impression that at least a few people believe that Pactor III or at least certain implementations of it that's in use by Winlink has been illegal all along.

Has anyone ever actually filed a formal complaint with the FCC on the legality of Pactor III?

If so, what did the FCC actually say about it?

If not, why not?
Most of the complaints have been interference complaints which brought about this response from Riley Hollingsworth "no Amateur Radio stations are exempt from the requirement to avoid unnecessarily interfering with ongoing communications. It is very important for all stations, including automated ones, to realize that they are responsible for any interference caused when they come on top of existing communications,"

Another common complaint is the fact that the protocol is closed and is not publicly documented and cannot be monitored so that the ARS can be self policing. 97.309(a)(4) is cited. The FCC issued DA 95-2106 on October 11, 1995 and stated "the technical characteristics of CLOVER, G-TOR, and PACTOR have been documented publicly for use by amateur operators, and commercial products are readily available that facilitate the transmission and reception of communications incorporating these codes. Including CLOVER, G-TOR, and PACTOR in the rules will not conflict with our objective of preventing the use of codes or ciphers intended to obscure the meaning of the communication. It appears that the primary emphasis is on the intention of obscuring meaning, and that it is up to the operators controlling the transmission to police themselves. That is sort of like the fox guarding the hen house.

The discussion on this thread revolves around the intention of 97.307(f)(3), specifically "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." Most of us here agree that the intention of 97.307(f)(3) was to set a maximum bandwidth, without enumerating a bandwidth. There is historical evidence to support this claim. What most of us are struggling with is what is the appropriate enumerated bandwidth. I used the necessary bandwidth formula and came up with 1.5 kHz. I measured a 300 baud 1000 Hz shift FSK signal and found it to have an occupied bandwidth of around 2K. Some here like 500 Hz. I do too for some emissions, but I have been pointing out that traditional 300 baud 200 Hz AX.25 will not meet that standard.

I am glad to hash this out before going to the FCC, to see where most folks stand.

73,

Mark N5RFX

[N5PVL]

N5RFX says:
Quote[/b] ]
What most of us are struggling with is what is the appropriate enumerated bandwidth. #I used the necessary bandwidth formula and came up with 1.5 kHz.

I think that you used the logic that you found was necessary to support your position. The struggle you mention arises from the fact that there are several different ways to look at the FCC's intent, way back in the 70's or eighties.

My feeling on this is that the FCC's clear intent today holds a lot more water than anybody's speculation about a rule from decades ago, that is famous for being ambiguous.

[w5alt]

For what it's worth, the recent R&O seems to squeeze both digital and CW into a smaller segment on several bands, therefore making the issue of spectrum efficiency and bandwidth of digital signals more important. I don't claim to know what the optimum rule should be, but it would seem that something in either the rules or a workable bandplan is needed to avoid the inevitable QRM issues that will arise.

I think that a 500 Hz bandwidth is reasonable for most HF operations, but at the same time I wouldn't want to inhibit experimentation with wider digital bandwidths where it makes sense. Some obvious cases, that admittedly are not currently being used would be the development of techniques that use a wider bandwidth, but allow signals to be interleaved thereby achieving more spectrum efficiency.

It seems that the best way to avoid the inevitable QRM and yet allow reasonable experimentation would be to define a sub-band where wider signals are permitted. Unfortunately I don't see where those sub-bands could be allocated without further restricting existing operations and modes. Perhaps a 20 kHz band at the top of the current CW/digital bands would be reasonable, but I'm sure there would be complaints from existing users.

I just don't see an easy solution given the rules set forth in the current R&O.

73,
Walt, W5ALT

[n5rfx]

Quote[/b] (N5PVL @ Nov. 17 2006,11:32)]My feeling on this is that the FCC's clear intent today holds a lot more water than anybody's speculation about a rule from decades ago, that is famous for being ambiguous.
Where did the 500 Hz maximum occupied bandwidth come from?

73,

Mark N5RFX

[ab0wr]

Quote[/b] (n5rfx @ Nov. 18 2006,06:22)]Quote[/b] (ab0wr @ Nov. 17 2006,06:54)]Wait a minute. You are implying that J2 and F1 are the same....They are not.
J2 may look like F1 but it isn't the same. If it was, all you would have to do to get around the new regs is to call your signal an F1D emission instead of a J2D emission. F1D is not in the list of emissions that are limited to 500hz. #

tim ab0wr
I am not implying, it is a fact. #F1 and J2 can be exactly the same emission. #Properly adjusted AFSK using J2 is indistinguishable from FSK F1.

73,

Mark N5RFX
Mark,

I disagree.

They may look the same on the receive end. They are NOT the same on the transmitter end.

It is the TRANSMITTER end that determines the emission type, not a picture on a spectrum analyzer at the receive end.

You cannot arbitrarily define J2D as F1D in order to get around the new FCC rules.

tim ab0wr

[N5PVL]

N5RFX asks:
Quote[/b] ]
Where did the 500 Hz maximum occupied bandwidth come from?

I would guess that it came from a desire to set the US digital community back onto a more appropriate path.

Just about all of the proponents of wide data modes on HF today are "Hinternet" devotees of one stripe or another, and the FCC has made it quite clear that it does not support the Hinternet vision in any particular.

Some will not be observant enough to take the hint, but I do believe that most of the present group of Hinternet devotees will soon experience a loss of interest and move on to do other, better things.

I say "better" because those who can see no better thing for Ham Radio than to pretend it is the internet have such a paltry, uninspiring vision for this great hobby.

Instead of trying to turn our spectrum into a third-rate imitation of the internet they might ask themselves:

"What other group made up of private individuals has both the authority and means to build and maintain an independent global digital network?"

Why these so-called "digital elitites" are too brain-dead to get excited about this singular opportunity is hard to figure, but the really hard part to understand is why they would bother to actively oppose this vision, as if its success would harm them somehow.

Such opposition is not just small-minded; It is mean spirited as well, and in no way resembles the behavior we like to associate with amateur radio.

Bunch of Luddites, clinging to the familiar internet and afraid to do anything different. - THAT would require (shudder ) independent, original thinking! - Horrors!

The FCC folks have sat back and watched this kind of silliness going on for years, and it looks like they finally got their fill of it.

Thus the 500 Hz limit on data modes.

[n5rfx]

Quote[/b] (ab0wr @ Nov. 17 2006,14:41)]Quote[/b] (n5rfx @ Nov. 18 2006,06:22)][quote=ab0wr,Nov. 17 2006,06:54]Wait a minute. You are implying that J2 and F1 are the same....They are not.
J2 may look like F1 but it isn't the same. If it was, all you would have to do to get around the new regs is to call your signal an F1D emission instead of a J2D emission. F1D is not in the list of emissions that are limited to 500hz.

tim ab0wr
I am not implying, it is a fact. F1 and J2 can be exactly the same emission. Properly adjusted AFSK using J2 is indistinguishable from FSK F1.

73,

Mark,

I disagree.

They may look the same on the receive end. They are NOT the same on the transmitter end.

It is the TRANSMITTER end that determines the emission type, not a picture on a spectrum analyzer at the receive end.

You cannot arbitrarily define J2D as F1D in order to get around the new FCC rules.

tim ab0wr
Tim,
I gave a reasoned explanation based on principle, so calling my statement arbitrary leads me to believe that there is another reason for your argument. I was explaining how the packet emissions that I tested on 20 meters were indeed FM. Using AFSK and J2 I can produce an F1 signal at the output of my J2 transmitter. I was using this explanation to show why the bandwidth of the emission was greater than the 200 Hz shift by using Carson's rule and a particular necessary bandwidth formula in part 2.

Notwithstanding a proclivity against Pactor III, why make the distinction between F1 and J2 when the emission looks the same at the receive end?

73,

Mark N5RFX

[N5PVL]

Quote[/b] ]
§ 97.3 Definitions.
* * * * *
© * * *
(2) Data. Telemetry, telecommand and
computer communications emissions
having designators with A, C, D, F, G,
H, J or R as the first symbol; 1 as the
second symbol; D as the third symbol,
and emissions A1C, F1C, F2C, J2C, J3C,
and J2D 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.
* * * * *


For reference, here is the 'data' section of the new R&O.

[n5rfx]

Quote[/b] (N5PVL @ Nov. 17 2006,14:59)]The FCC folks have sat back and watched this kind of silliness going on for years, and it looks like they finally got their fill of it.

Thus the 500 Hz limit on data modes.
Charles,

Fair enough. I am sure you saw the sentence in the R&O that read "We understand ARRL's concern, but we note that eliminating or relaxing the bandwidth limitation would de facto eliminate the separation of narrow bandwidth
and wide bandwidth emissions." If you notice there is a reference to footnote 88. Did you read that footnote and the document to which it refers?

73,

Mark N5RFX

[ab0wr]

Quote[/b] (n5rfx @ Nov. 18 2006,15:41)]Quote[/b] (ab0wr @ Nov. 17 2006,14:41)]Quote[/b] (n5rfx @ Nov. 18 2006,06:22)][quote=ab0wr,Nov. 17 2006,06:54]Wait a minute. You are implying that J2 and F1 are the same....They are not.
J2 may look like F1 but it isn't the same. If it was, all you would have to do to get around the new regs is to call your signal an F1D emission instead of a J2D emission. F1D is not in the list of emissions that are limited to 500hz. #

tim ab0wr
I am not implying, it is a fact. #F1 and J2 can be exactly the same emission. #Properly adjusted AFSK using J2 is indistinguishable from FSK F1.

73,

Mark,

I disagree.

They may look the same on the receive end. They are NOT the same on the transmitter end.

It is the TRANSMITTER end that determines the emission type, not a picture on a spectrum analyzer at the receive end.

You cannot arbitrarily define J2D as F1D in order to get around the new FCC rules.

tim ab0wr
Tim,
I gave a reasoned explanation based on principle, so calling my statement arbitrary leads me to believe that there is another reason for your argument. I was explaining how the packet emissions that I tested on 20 meters were indeed FM. #Using AFSK and J2 I can produce an F1 signal at the output of my J2 transmitter. #I was using this explanation to show why the bandwidth of the emission was greater than the 200 Hz shift by using Carson's rule and a particular #necessary bandwidth formula in part 2.

Notwithstanding a proclivity against Pactor III, why make the distinction between F1 and J2 when the emission looks the same at the receive end?

73,

Mark N5RFX
It isn't a proclivity against just Pactor III but against any wideband J2D signals used as internet access links.

When I used the noun "You" I didn't mean the singular "you" but the objective "you" meaning no one in particular.

J2D means an amplitude modulated ssb, supressed carrier signal modulated by a sub-carrier.

F1D means an frequency modulated signal NOT using a sub-carrier.

While they may "look" the same, they are not the same.

They have different designs in the transmitter chains, different types of spurious emissions, and different requirements for the amplifier chains.

An N0D signal or an A1A signal durig tuneup would look just like an F1D signal in idle mode. Does that make them the same?

F1D and J2D can NOT be the same emission. As you have pointed out yourself -- they have different intermod characteristics. If they "look" the same it is because of the limitations of the measuring equipment, not because the emissions are the same.

tim ab0wr

[n5rfx]

Tim,

Thanks for the explanation. In a non-chanellized environment using non-certified (type accepted) equipment, what is the importance of differentiating between J2 and F1 emissions?

73,

Mark N5RFX

[N5PVL]

It helps define the regulatory structure.

Remember that "feelings" have very little to do with the radio art.

As I predicted, the twisted, strained rationalizations we will be hearing during this next month are providing us all with hours of harmless fun.

I say "harmless" because such rationalizers will find that pulling the wool over their own eyes may be easy, but that doesn't necessarily extend to others. - Most particularly the FCC.

The impression I get is that you would literally say anything if you thought it would convince someone that the 500 Hz. limit on data modes needed to have just one little exception.

The TAPR folks have been using technical jargon in their arguements for years and its amazing how many times it turns out that they either willfully misrepresented the facts or had no actual aquaintance with them. More often than not we find that it is their own special way of blowing smoke. This goes hand in hand with the junk science, poorly considered nature of the recent "Hinternet" related proposals coming out of ARRL/TAPR.

Most of us are not as easily gulled as an ARRL executive or as easily dominated as an ARRL director, so do not expect the kind of results here that you might get with one of those.

[N5PVL]

N5RFX asks:
Quote[/b] ]
If you notice there is a reference to footnote 88. #Did you read that footnote and the document to which it refers?

No, I never did.

[kb3mng]

Quote[/b] (ab0wr @ Nov. 18 2006,05:35)]Quote[/b] (kb3mng @ Nov. 18 2006,00:39)]What definition of "baud" do you use to reach that conclusion? I have always known "baud" to mean "1 potential signal transition per second". As long as the transitions occur no more than 300 times per second (no matter how many bits are transmitted by each transition), doesn't that signal meet the requirements?
If you have a modem putting out 1000 tones into your microphone attached to your SSB transmitter, with each tone transitioning at 100 baud, do you have a 100 baud signal? Or do you have a 1000 x 100 = 100000 baud signal?
I would think the answer is clearly that you have a 100 baud signal. The term "baud" refers to the frequency of the transitions. It is only distantly related to bandwidth, just like it is only distantly related to bit rate.

In your example, the receiver could sample all 1000 tones simultaneously. Ignoring clock recovery, you would need to make those samples only 100 times per second. With 1000 bits per baud, there would be 100 000 bits per second coming out, though.

Quote[/b] ]The FCC was using the baud rate limit of 300baud to try and set a *bandwidth* limit on signals in the amateur bands. At the time the FCC was doing this multi-tone modems weren't in use on the ham bands (if they even existed at all).
That doesn't sound very smart on the part of the FCC. If they wanted to limit bandwidth, why didn't they just say so?

(The first opportunity I had to encounter a multi-tone modem was around 1979 or so, but it was a conventional telco application, not radio. I always thought the idea was pretty obvious though -- even Bell 103 has 4 tones in the bandwidth of a POTS line.)

Quote[/b] ]If you take a multi-tone modem, however, and conglomerate the tones and call it ONE symbol then you are sending ONE symbol per second (i.e. ONE baud) even though your bandwidth may be 20khz (e.g. 1000 tone modem with 200hz channels).

You have just lost any relationship between baud rate and bandwidth -- i.e. you have found a *loophole* in the regulations.

I don't see a loophole -- I see a badly written regulation. It was never clear to me that there was a relationship between baud rate and bandwidth -- it is too dependent on the modulation scheme you use. I could send the same tones over conventional SSB in 3 KHz or over a commercial FM transmitter in 150 KHz. Obviously quite a difference in bandwidth. http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif

I think that regulations should always explicitly say what they mean, rather than using circumlocution to try to achieve some effect indirectly.

If the intent is to limit the bandwidth of digital signals, the new regulation is an improvement. I can't say I'm that happy about their grammar, but at least they say what they mean.

[n5rfx]

N5PVL:
Quote[/b] ]The impression I get is that you would literally say anything if you thought it would convince someone that the 500 Hz. limit on data modes needed to have just one little exception.
I am just pointing out exceptions that already exist, and pointing out facts. Lets look at what the FCC says, not what we feel they say. In the current R&O the FCC says: "We believe that separation of emission types by bandwidth is accepted in the amateur service as a reasonable means to minimize interference on shared frequencies and bands." They also state: "the 500 Hz limitation applies only to the emission types we are adding to the definition of data".

J2D was not added to the definition of data. It was already there.

Since F1D and J2D have the same necessary bandwidth calculations and similar occupied bandwidth characteristics, F1D should have been added to the list of 500 Hz emissions designators. I had not thought about this exception until Tim challenged me during my explanation of necessary and occupied bandwidths of the same. Discussion is good.

We can bury our heads in the sand and pretend that these exceptions don't exist. What does not exist is any statement that refers to PIII or wideband signals used as Internet access links; this part of the R&O is about authorizing image emissions.

I would be very happy to see PIII go by the wayside and this new definition of data does that, but we should not for a moment think that this definition would go unchallenged.

The original purpose of this thread was a request by Albert W3MIV to email our ARRL officials. I added links to a petition I had been working on to solidly limit wideband signals in the RTTY/Data subbands and was looking for comment.

No scapegoats have been called for, only action.

73,

Mark N5RFX

[n5rfx]

Some may be wondering about the relavance of emissions designators and necessary bandwidth. I noticed 3 Extra exam questions on the subject.

E8C08 ©
What is the necessary bandwidth for a 170-hertz shift, 300-baud ASCII emission
J2D transmission?
A. 0 Hz
B. 0.3 kHz
C. 0.5 kHz
D. 1.0 kHz

E8C09 (D)
What is the necessary bandwidth of a 1000-Hz shift, 1200-baud ASCII emission F1D
transmission?
A. 1000 Hz
B. 1200 Hz
C. 440 Hz
D. 2400 Hz

E8C10 (A)
What is the necessary bandwidth of a 4800-Hz frequency shift, 9600-baud ASCII
emission F1D transmission?
A. 15.36 kHz
B. 9.6 kHz
C. 4.8 kHz
D. 5.76 kHz

73,

Mark N5RFX

[N5PVL]

N5RFX says:
Quote[/b] ]
I have not seen a CSMA protocol that beats AX.25 on HF. #I have tried Q15X25 a couple of years ago, and was not impressed. #We were able to go to 300 Baud 200 Hz shift AX.25 and communicate pretty well. #I saw some work adding FEC to AX.25, but have not tried it on HF. #I think that would be interesting to test.


I haven't seen another CSMA protocol on HF at all, better or worse unless I saw one but didn't know what I was looking at.

I think that having a clear and reliable set of parameters to work within will do more good than most of us realize at this early date.

Q15x25 is AX25 by the way. Remember RadioMirror? That was AX25 multicast software. FlexNet is AX25 just like NetRom, but is so advanced compared to NetRom that it is like looking at two different protocols.

The most backward, feature-free AX25 implementation? - APRS.

In the long run though, my loyalty to AX25 is about like my loyalty to BPQ node software was, when FlexNet became available. After seven or eight years with BPQ, I dropped it like a hot potato the minute that something that worked out better for me came along.

[KQ6XA]

Pactor-1 can now be used to send photos in the data subbands. When Pactor-1 is used to send images, the emission designator is F1C.

[KQ6XA]

PACTOR (FSK) = F1D / F1B / F1C
PACTORII (DPSK) = G1D / G1B / G1C
PACTORIII (DBPSK or DQPSK) = G1D / G1B / G1C

As you can see, Pactor 3 is allowed under the new rules, the same as it has been. There is no 500Hz limit for Pactor data or text. The 500Hz limit only applies to Pactor image. Pactor is not J2D.

[KQ6XA]

Emission Designators for Common
Amateur Radio Digital Data / Text / Fax

Frequency Modulated
RTTY (FSK) = F1D / F1B / F1C
MFSK (FSK) = F1D / F1B / F1C
ALE (FSK) = F1D / F1B / F1C
PACTOR (FSK) = F1D / F1B / F1C
PACKET (FSK) = F1D / F1B / F1C
FSK31 (FSK) = F1D / F1B / F1C
8FSK DTM ARQ (FSK) = F1D / F1B / F1C
8FSK DBM ARQ (FSK) = F1D / F1B / F1C
FMHELL (FSK) = F1B / F1C

Phase Modulated
BPSK31 (PSK) = G1D / G1B / G1C
QPSK31 (QPSK) = G1D / G1B / G1C
PSK63 (PSK) = G1D / G1B / G1C
Q15X25 (QPSK) = G1D / G1B / G1C
MT63 (DBPSK) = G1D / G1B / G1C
PACTORII (DPSK) = G1D / G1B / G1C
PACTORIII (DBPSK or DQPSK) = G1D / G1B / G1C
MIL-STD 188-110 (PSK) = G1D / G1B / G1C

Amplitude and Angle Modulated Simultaneously
Olivia (AMFSK) = D1D / D1B / D1C
OFDM (AMPSK) = D1D / D1B / D1C

Duration or Position Modulated
FELDHELL (PWM) = L1B / L1C
FELDHELL (PPM) = M1B / M1C
-
As you can see, J2D is not on the list.

Bonnie KQ6XA

[N5PVL]

KQ6XA says:
Quote[/b] ]
As you can see, J2D is not on the list.

It is in the R&O though.

Nice list, there.

I'm glad you got past making a seperate post for every sentence. - It takes up a lot of bandwidth to no purpose.

[KQ6XA]

It seems that many hams, including ARRL (and myself) were confused by the initial reports and ARRL synopsis of the R&O and the ruling. That is not surprising, since the FCC actions were poorly written, self-contradictory, and unclear. But, the new FCC definition of "Data" does not have the effect that some thought it had, from the first news.

To all the sadistic operators wishing for the death of Pactor-3... please be advised that rumors of its demise are premature! http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif

Pactor-3 is allowed under the new rules, the same as it always has been!

[KC9ECI]

Quote[/b] (KQ6XA @ Nov. 19 2006,09:16)]To all the sadistic operators wishing for the death of Pactor-3... please be advised that rumors of its demise are premature! http://www.qrz.com/iB_html/non-cgi/emoticons/smile.gif
No sadistic intent here at all Bonnie, I wish it a speedy, painless demise.

[n5rfx]

N5PVL:
Quote[/b] ] haven't seen another CSMA protocol on HF at all, better or worse unless I saw one but didn't know what I was looking at.
Now that you mention it, neither have I. I was just tying to find common ground with you.

N5PVL:
Quote[/b] ]Q15x25 is AX25 by the way.
Yes, I think I am differentiating the modems and not the protocol, that was a mistake in my CSMA comment. My original statement should have been about Bell 103 versus Q15X25.

N5PVL:
Quote[/b] ]The most backward, feature-free AX25 implementation? - APRS.
Man aren't we polar opposites? I enjoy APRS very much, but I am a telemetry and telecommand nut. I have been into mapping and navigation for a long time. It integrates well with the Internet so APRS is a perfect fit for me.

Butcher, baker, candlestick maker, we all have our place in amateur radio.

73,

Mark N5RFX

[N5PVL]

The search for a magic loophole in the new restructured PART97 goes on!

Picture it... Is this a good picture of what ham radio is all about? - Of course it isn't, but there is no cause for worry because the digital elitists hysterically searching a magic loophole make up a tiny minority.

Most hams have no trouble at all seeing why the 500Hz limit on data modes is a good thing for the hobby, and why it makes good sense. ( Note my signature... This is a digital enthusiast speaking. )

The only ones being hurt by the R&O are those who have been consistently flouting the spirit if not the letter of PART97 for years.

Cry me a river for deliberate Lids.

I agree that this transition should be as quick and painless as possible, but I'm afraid we have at least twenty-six more days of the quest for the magic loophole ahead of us.

If it were up to me, I would be sensitive enough to have the restructuring occur immediately. - The sooner the better, in any case.

What we will have to stand by for here on QRZ after december 15th will be a new raft of bitter anti-ham tirades about how pointless amateur radio is. These frustrated lids will not hesitate to attack the hobby any more than they hesitated to flout and attack the PART97 regulations that make up amateur radio's foundation.

Take my word for it when I tell you that many of this virulent minority of "Hinternet" devotees would gladly see ham radio go down in the first place. - That's what the "Hinternet" is all about; dedicating amateur radio spectrum to internet services.

They want it all.

Ever hear the story about the camel who asked to put "just his nose" into the tent? - That parable applies here.

( The camel then wanted "just his neck" then "just his front legs"... The story ends when the guy wakes up the next morning to find he is in bed with the camel. )

So there will be a flurry of discontent from the folks who have been mocking the rules, when the loopholes are stopped up on december 15th.

We'll all have to stand by to ignore some, and encourage others. Many of these Hinternet devotees are good hams who have been led astray and only have to be themselves for a while in order to adjust.

[KQ6XA]

Quote[/b] (N5PVL @ Nov. 19 2006,08:39)]The search for a magic loophole in the new restructured PART97 goes on!
There isn't any need for a loophole. Everything is status quo for fast digital, plus we now have image allowed in the data subbands.

[ab0wr]

Quote[/b] (n5rfx @ Nov. 18 2006,17:18)]Tim,

Thanks for the explanation. #In a non-chanellized environment using non-certified (type accepted) equipment, what is the importance of differentiating between J2 and F1 emissions?

73,

Mark N5RFX
It is even more important in a non-channelized, non-type accepted environment to know exactly what emission type is being used.

Since each suffer from different impairments knowing the emission type can facilitate trouble-shooting should the transmitter suffer a problem.

You would expect to see significant carrier and opposite sideband artifacts from a J2B emission where either the balanced modulator, the filter, or the phasing circuits have suffered a failure. You would not expect to see such from an F1B emission.

This means J2B emissions from misadjusted transmitter chains have the potential for being much worse neighbors than F1B emissions. That's not to say that an oscillator in an F1B transmitter can't get out of adjustment and cause adjacent channel interference but in that case the operator would soon notice that he could make no contacts and would begin investigating why.

I'm sure I could come up with more examples but this should suffice to show why classification of emission type based on the transmitter chain and not on the receiver chain is important.

tim ab0wr

[ab0wr]

Quote[/b] (KQ6XA @ Nov. 19 2006,06:42)]PACTOR (FSK) = F1D / F1B / F1C
PACTORII (DPSK) = G1D / G1B / G1C
PACTORIII (DBPSK or DQPSK) = G1D / G1B / G1C

As you can see, Pactor 3 is allowed under the new rules, the same as it has been. There is no 500Hz limit for Pactor data or text. The 500Hz limit only applies to Pactor image. Pactor is not J2D.
Bonnie,

Frankly, this is some of the worst kind of gamesmanship I have seen. This is worse than the ARRL saying that 1000hz Olivia used for keyboard-to-keyboard communications has been made illegal.

The definition of "G" is:

Quote[/b] ]Emission in which the main carrier is angle-modulated:

Phase Modulation # # First Symbol = G

I do not understand how you can say that Pactor is a G type emission. when the *carrier* in a SSB transmitter sending Pactor is **SUPRESSED**, not modulated.

Pactor II and III *** is *** J2_ for an emission type.

Look at these URL's:

www.arrl.org/FandES/field/regulations/techchar/PACTOR-III.html
www.winlink.org/Presentations/PACTOR-III-Protocol.pdf

tim ab0wr

[ab0wr]

Quote[/b] (KQ6XA @ Nov. 19 2006,08:51)]Quote[/b] (N5PVL @ Nov. 19 2006,08:39)]The search for a magic loophole in the new restructured PART97 goes on!
There isn't any need for a loophole. Everything is status quo for fast digital, plus we now have image allowed in the data subbands.
Bonnie,

You are engaging in the exact same yellow journalism the ARRL is engaged in.

Please stop.

You cannot redefine reality by wishful thinking.

tim ab0wr

[n5rfx]

Quote[/b] (ab0wr @ Nov. 18 2006,09:56)]It is even more important in a non-channelized, non-type accepted environment to know exactly what emission type is being used.

Since each suffer from different impairments knowing the emission type can facilitate trouble-shooting should the transmitter suffer a problem.

You would expect to see significant carrier and opposite sideband artifacts from a J2B emission where either the balanced modulator, the filter, or the phasing circuits have suffered a failure. You would not expect to see such from an F1B emission.

This means J2B emissions from misadjusted transmitter chains have the potential for being much worse neighbors than F1B emissions. That's not to say that an oscillator in an F1B transmitter can't get out of adjustment and cause adjacent channel interference but in that case the operator would soon notice that he could make no contacts and would begin investigating why.

I'm sure I could come up with more examples but this should suffice to show why classification of emission type based on the transmitter chain and not on the receiver chain is important.

tim ab0wr
Your statements are valid, but are not applicable to the Amateur Radio Service and this R&O. The principal use of emission designators in regulations for the Amateur service is to relegate the transmission of certain inharmonious emission types to different segments of the frequency bands. How is J2D inharmonious with F1D, or for that matter A, C, D, F, G, H, or R1D? If the R&O spoke about J2D being inharmonious or the different impairments such as significant carrier and opposite sideband artifacts or anything resembling that I would agree with you.

Paragraphs 15 through 19 are there to authorize image emissions. The 500 Hz limitation applies only to the emission types that were added to the definition of data. J2D was not added. The 500 Hz bandwidth limitation does not apply to other data emission types or amateur service bands in which a higher symbol rate or bandwidth currently is permitted. Footnote 90 references 97.305©, 97.307(f)(3)-(8), (13). The R&O says these things, but says nothing about removal of authorization for Pactor III or OFDM type emissions.

It is a nice idea, but is on very shaky ground. I have a theory on how J2D was moved inside of the 500 Hz area, but it is only a theory, not fact.

73,

Mark N5RFX

[ab0wr]

Quote[/b] (KQ6XA @ Nov. 19 2006,06:44)]Emission Designators for Common
Amateur Radio Digital Data / Text / Fax

Frequency Modulated
RTTY (FSK) = F1D / F1B / F1C
MFSK (FSK) = F1D / F1B / F1C
ALE (FSK) = F1D / F1B / F1C
PACTOR (FSK) = F1D / F1B / F1C
PACKET (FSK) = F1D / F1B / F1C
FSK31 (FSK) = F1D / F1B / F1C
8FSK DTM ARQ (FSK) = F1D / F1B / F1C
8FSK DBM ARQ (FSK) = F1D / F1B / F1C
FMHELL (FSK) = F1B / F1C

Phase Modulated
BPSK31 (PSK) = G1D / G1B / G1C
QPSK31 (QPSK) = G1D / G1B / G1C
PSK63 (PSK) = G1D / G1B / G1C
Q15X25 (QPSK) = G1D / G1B / G1C
MT63 (DBPSK) = G1D / G1B / G1C
PACTORII (DPSK) = G1D / G1B / G1C
PACTORIII (DBPSK or DQPSK) = G1D / G1B / G1C
MIL-STD 188-110 (PSK) = G1D / G1B / G1C

Amplitude and Angle Modulated Simultaneously
Olivia (AMFSK) = D1D / D1B / D1C
OFDM (AMPSK) = D1D / D1B / D1C

Duration or Position Modulated
FELDHELL (PWM) = L1B / L1C
FELDHELL (PPM) = M1B / M1C
-
As you can see, J2D is not on the list.

Bonnie KQ6XA
WAIT A MINUTE!!!!

I don't even know where to begin.

Olivia is an offshoot of mfsk. It is a multi-tone frequency shift keying mode, not OFDM.

Olivia sends one tone at a time. It is a Single-Sideband, Suppressed Carrier signal containing quantitized digital information via the use of modulating sub-carrier.

OFDM uses multiple tones that are orthogonal so that the spectrum of the individual tones can overlap and guard spacing is not required. Multiple tones can be sent at once. While the tones on mfsk16 use the same theory to minimize the spectrum required for each tone, it is not ofdm either.

Olivia is NOT OFDM and is therefore not a "D" emission type.

PSK31, Pactor, ALE, mt63, etc ARE NOT "G" type emissions.

"G" type emissions require modulating the carrier itself, not use of a modulating sub-carrier with the actual carrier itself being supressed.

Charles was right. We are beginning to see the cockroaches come out of the woodwork in an effort to redefine reality and find the "magic loophole".

*********************

Mark,

It is exactly this reason that I was trying to make the point that F1B and J2B are two entirely different things. Now we are seeing people say that D1D is the same as D2D and G1D is the same as J2D AND THERE IS NO SUCH THING AS J2D!!!!

The definitions *DO* mean something. There *ARE* technical reasons for why they exist.

tim ab0wr

[ab0wr]

Quote[/b] ]I don't see a loophole -- I see a badly written regulation. #It was never clear to me that there was a relationship between baud rate and bandwidth -- it is too dependent on the modulation scheme you use. #I could send the same tones over conventional SSB in 3 KHz or over a commercial FM transmitter in 150 KHz. #Obviously quite a difference in bandwidth.

I think that regulations should always explicitly say what they mean, rather than using circumlocution to try to achieve some effect indirectly. #

If the intent is to limit the bandwidth of digital signals, the new regulation is an improvement. #I can't say I'm that