Change to ARRL's Bandwidth Limit

[WA0LYK]

'The following is what I am sending to my ARRL Director. If you agree that this is a better alternative than the "occupied bandwidth" plan that is in the current ARRL proposal, please let your director know ASAP.

I want to let you know that I can not support the elimination of mode segregation and replacing it with the ARRL's proposed "occupied bandwidth" regulatory plan at this time.

However, I would like to recommend another alternative to the current ARRL bandwidth petition -- using the "necessary bandwidth" term from emission designators as a limit to describe frequency segments. I believe this recommendation will reduce regulation, reduce the costs of FCC enforcement, and reduce the cost of future regulation changes should new digital techniques require marginally wider bandwidths.

This alternative would use the first term of emission designators. ITU defined emission designators are a somewhat new means of defining emission types and have been accepted/implemented by the FCC. Some good definitions are at http://wireless.fcc.gov/services/ind&bus/licensing/emission.html.

The use of technically accurate definitions such as these would make the amateur community and the ARRL appear much more professional to the FCC. As many amateurs are not familar with emission designators, an added benefit would be the education of the amateur community about these conventions.

The first term of emission designators is known as the "necessary bandwidth" of the emission being used. There are mathematical calculations, well defined by the FCC and the ITU, required to determine the necessary bandwidth. They are not based upon measurements which have a high cost, only upon the published operating characteristics of any given emission.

The necessary bandwidth notation is somewhat unique. It consists of four characters where H = Hertz and K = kHz. Some examples are:

60H0 - 60.0 Hz (used for PSK31 - 60H0J2B)
375H - 375 Hz (used for Pactor II - 375HJ2D)
2K20 - 2.20 kHz (used for Pactor III - 2K20J2D)
2K70 - 2.70 kHz (used for digital voice - 2K70J2E)
3K00 - 2.70 khz (used for analog voice - 2K70J3E)

These were taken from a document at the NTIA web site: NTIA Amateur Radio Emission Definitions (http://ntiacsd.ntia.doc.gov/ussg1/uswp1a/WP%201A%20Documents/2004_10_Meeting/R03-WP1A-C-0031!!MSW-E.doc)

The ARRL proposed petition attempts to define the band segments using what is known as the "occupied bandwidth" which describes a transmitters RF footprint. For example, when running analog voice, the necessary bandwidth could be defined as 2.70 kHz in the emission designator, while the occupied bandwidth of the transmitter would be limited to 3.00 kHz. Limiting the occupied bandwidth makes it necessary to measure the transmitter using a well defined technique such as a two tone test and making sure the RF footprint fits into a well defined emissions mask, i.e. no emissions above -26 db at 3.00 kHz.

A proposed plan with two segments, using necessary bandwidths, could say something like "From here to there all modes whose emission designator has a necessary bandwidth less than or equal to 2.5 kHz, and from here1 to there1 all modes whose emission designator has a necessary bandwidth greater than 2.5 kHz". CW can be allowed anywhere by modifying the exemption in 97.305(a) to say "CW (____A1A)". A total bandwidth limit can be specified as "no emissions whose necessary bandwidth is greater than 9K00 (9 kHz). Subsequent voluntary bandplans can use any or all of the last three characters to limit transmissions to certain characteristics and band segments.

The invention of new emission types would only require the calculation of the necessary bandwidth to determine which part of the band they belong to. The calculations required to determine the necessary bandwidth are well defined by the FCC and the ITU. No FCC intervention would be required to implement a new emission type which reduces the regulatory burden and costs.

I am very concerned with the ability for amateurs to measure and meet the proposed bandwidth restrictions with current transmitters. I believe the operational findings of PSK31 users is illuminating. Almost every web site on PSK31 recommends that transmitters run with no ALC and at a very reduced power level in order to minimize third order intermodulation products (3IMD). QST even had a review recently of a commercial product that would monitor IMD on a PSK31 signal and automatically reduce sound card output to the correct level. Digital signals in the 3 kHz bandwidth segment will have the benefit of processing their signals through a SSB crystal filter which will help reduce the 3IMD. However, I expect there will be a large number that will not meet stringent standards. The real problem will be running digital signals in SSB mode in the 500 Hz segment. Very few tranmitters currently in use allow using the 500 Hz receive filter while transmitting in SSB mode. The signals at this bandwidth are narrow enough that 3IMD products will not be reduced at all because they will lie within the passband of normal 2.4 kHz to 2.8 kHz transmit SSB crystal filters, just like PSK31. This means a large number of transmitters could easily exceed any stringent measurement, i.e. -26 db below PEP.

The alternative I have proposed will eliminate this problem and let us keep the current rules on interference without having to resort to expensive spectrum analyzer measurements to determine if we are operating within FCC regulations.


Jim
WA0LYK

[W8MW]

Jim, thanks for your view on this matter. ITU designators are entirely appropriate. #So is Good Amateur Practice which equals flexibility in exchange for each operator's desire to do the right thing technically and operationally, particularly with respect to interference. #

Transmitter bandwidth measurement is not a place we want to go in ham radio. #Major complexities and costs. #The league recognizes that very point by saying we won't have to measure it, while pushing forward to request the very regulations that would make it necessary. Duh. #It would almost be funny if the consequences of this reckless petition weren't so much against the spirit of amateur radio.

73 Mike

[ae1x]

Quote[/b] (W8MW @ May 23 2005,14:45)]Jim, thanks for your view on this matter. ITU designators are entirely appropriate. #So is Good Amateur Practice which equals flexibility in exchange for each operator's desire to do the right thing technically and operationally, particularly with respect to interference. #

Transmitter bandwidth measurement is not a place we want to go in ham radio. #Major complexities and costs. #The league recognizes that very point by saying we won't have to measure it, while pushing forward to request the very regulations that would make it necessary. Duh. #It would almost be funny if the consequences of this reckless petition weren't so much against the spirit of amateur radio.

73 Mike
Very true and from some exchanges I have had with my representatives, I think there will be some that will give this a good look. There seems to major concern about the specific bandwidth proposed in the presentation.

I hope this proposal is accepted in full and I will suggest that my director give this serious consideration.

Ken

P.S.

Jim,

Thank you for a well worded and thought out proposal.

[ae4fa]

LYX:

So, you have no proposal concerning automated and semi-automated stations running anywhere they damn well like - as long as bandwidth considerations are met?

Far too simplistic in my view - as is the ARRL proposal.

[WA0LYK]

Quote[/b] ]ae4fa Posted on May 23 2005,18:29

So, you have no proposal concerning automated and semi-automated stations running anywhere they damn well like - as long as bandwidth considerations are met?

Far too simplistic in my view - as is the ARRL proposal.

I have two concerns about the ARRL proposal. One is the bandwidth requirement and the other is the auto/semi-auto stations.

The bandwidth issue is a unique issue and that is what I tried to address.

The auto/semi-auto has been beat to death on other threads and I don't have a good solution other than setting up restricted bands for both and this is what I'll be recommending.

Jim
WA0LYK

[ae1x]

Quote[/b] (ae4fa @ May 23 2005,20:29)]LYX:

So, you have no proposal concerning automated and semi-automated stations running anywhere they damn well like - as long as bandwidth considerations are met?

Far too simplistic in my view - as is the ARRL proposal.
The League plan is simplistic by design. Read what has been written. It is intended to be a flexible regulatory scheme to be augmented by concensus? #or ARRL published band planning. Either way, mode segmentation is to be eliminated from the regulations in the name of maximum flexibility.

The real question remains: are we responsible enough to accept the task of self-regulation? WL2k has a track record that indicates that it will not abide by band planning by non-regulatory means. They appear to have an agenda that will required significant resources to accomodate their interests and their user community is a don't care group. They want cheap and reliable e-mail.

League members must get involved. I don't care about your past experiences with communicating with your director. WL2k has been lobbying them using their web-site. If you feel this proposal needs adjustment, and it does, get out there and flood your director with your comments, ideas, and demands and demand an answer. You have every right to expect a reasonable explaination concerning his/her actions on this manner.

Ken

[kb2vxa]

Hi all,

And they wonder why NCTs have little to no incentive to upgrade, HF is a freakin' battleground! Likely most are waiting for the dust to settle before taking a look around to see if it's even worth venturing forth.

No crap from the trolls is acceptable, take a look at my avatar, and like Granny said "I have SPOKEN!". (This won't make me popular but I'm happy without all the "atmospherics" up here.)

[KA1UNW]

I think this is related,and it pertains to now

2.7khz is a very reasonable figure for SSB. But I notice not much is clear about AM. I'm talking about just how far away in frequency must 2 stations be before one can"legally" ignor anothers complaints about overlapping bandpasses?
Since it would be foolish to design and build rigs contrary to FCC guidelines( that link in the first post isn't working), equipment mfgs use 2.1 or 2.7 and 6 khz filters. Everyone has gotten used to being 3khz apart. That's on SSB being next to another SSB station.

However if on SSB(LSB) and below an AM station shouldn't 3kc be enough and if above then 6khz should be enough?
(assume crowded band condx or attempting to call someone on a preagreed on freq)
There are some AM users who seem to want 15khz (they transmit that wide on both sides of the carrier) and are getting very nasty about it.

Just where does a person stand here?

Randy

[ae1x]

Quote[/b] (KA1UNW @ May 25 2005,03:26)]I think this is related,and it pertains to now

2.7khz is a very reasonable figure for SSB. But I notice not much is clear about AM. I'm talking about #just how far away in frequency must 2 stations be before one can"legally" ignor anothers complaints about overlapping bandpasses?
# #Since it would be foolish to design and build rigs contrary to FCC guidelines( that link in the first post isn't working), equipment mfgs use 2.1 or 2.7 #and 6 khz filters. Everyone has gotten used to being 3khz apart. That's on SSB being next to another SSB station.

However if on SSB(LSB) and below an AM station shouldn't 3kc be enough and if above then 6khz should be enough?
(assume crowded band condx or attempting to call someone on a preagreed on freq)
There are some AM users who seem to want 15khz (they transmit that wide on both sides of the carrier) and are getting very nasty about it.

Just where does a person stand here?

Randy
Randy,

I think the problem is that the AM users are using wideband receiving equipment and are trying to obtain excellence in their transmitted audio. Of course they will want plenty of elbow room.

Remember most of the proponents of AM are using old boat anchor transmitters and receivers. This is not modern state-of-art gear. The receivers, in nost cases, do have not crystal filters, but rather double-tuned LC IF filters. These receivers done have good selectivity by today's standards and they prefer it that way.

We will always be the guardians of the past as well the innovators of the future, a sort of museum/laboratory if you will. We have to be tolerant of all interests not just those that are innovating. All interests must be accomodated within our shared spectrum.

Ken

[KA1UNW]

Yes, the boat anchor rigs...I am aware of that, but they are not the problem. There are some "class E " people who have designed rigs that are far worse than any nice old Viking or Military rig.
You would think that with a new design they would set their BW to fit the condx and ongoing use of the band.
Us SSB people use 50w while the class E's use 350w++
and they use modern Rx's or R 390's so it's not like they are captive audiances RX wise. But with their sending width under their full control they can Xmit wide (and
rx narrow)...a trick that they use to razz on SSB's and those they call appliance users. It wrecks any QSO we are trying to have.

This still does not give us a number to go by ( they get all caustic and say "30khz a*******" to anyone who trys to be reasonable), that we can claim is right and proper.

It's a give an inch and take a mile thing, the way it's been going.

If we use communications quality BW standards as used by ---oh say--- 1970s commercial AM rigs, 6khz should be enough ( +/- 3khz ). But it seems as tho we are expected to get more than 15kc away.

There just is not enough room to clear a path that wide
to accomodate them. I am hoping that that issue will be addressed...giving us a standard to go by.

[KA1UNW]

--------------------------------------------------------------------------------
Yes, the boat anchor rigs...I am aware of that, but they are not the problem. There are some "class E " people who have designed rigs that are far worse than any nice old Viking or Military rig.
You would think that with a new design they would set their BW to fit the condx and ongoing use of the band.
Us SSB people use 50w while the class E's use 350w++
and they use modern Rx's or R 390's so it's not like they are captive audiances RX wise. But with their sending width under their full control they can Xmit wide (and
rx narrow)...a trick that they use to razz on SSB's and those they call appliance users. It wrecks any QSO we are trying to have.

This still does not give us a number to go by ( they get all caustic and say "30khz a*******" to anyone who trys to be reasonable), that we can claim is right and proper.

It's a give an inch and take a mile thing, the way it's been going.

If we use communications quality BW standards as used by ---oh say--- 1970s commercial AM rigs, 6khz should be enough ( +/- 3khz ). But it seems as tho we are expected to get more than 15kc away.

There just is not enough room to clear a path that wide
to accomodate them. I am hoping that that issue will be addressed...giving us a standard to go by.

[ae1x]

Quote[/b] (KA1UNW @ May 25 2005,05:24)]--------------------------------------------------------------------------------
Yes, the boat anchor rigs...I am aware of that, but they are not the problem. There are some "class E " people who have designed rigs that are far worse than any nice old Viking or Military rig.
#You would think that with a new design they would set their BW to fit the condx and ongoing use of the band.
Us SSB people use 50w while the class E's use 350w++
and they use modern Rx's or R 390's so it's not like they are captive audiances RX wise. But with their sending width under their full control they can Xmit wide (and
rx narrow)...a trick that they use to razz on SSB's and those they call appliance users. It wrecks any QSO we are trying to have.

This still does not give us a number to go by ( they get all caustic and say "30khz a*******" to anyone who trys to be reasonable), that we can claim is right and proper.

It's a give an inch and take a mile thing, the way it's been going.

#If we use communications quality BW standards as used by ---oh say--- 1970s commercial AM rigs, 6khz should be enough ( +/- 3khz ). But it seems as tho we are expected to get more than 15kc away.

There just is not enough room to clear a path that wide
to accomodate them. I am hoping that that issue will be addressed...giving us a standard to go by.
Good points all.

You know, I would suggest that you discuss with the engineer-in-charge at the FCC office near you. It could be that they are involation.

I'll have to do some reading on class E transmitter design. I know the theory, but I'm not up on the practice. They may be able to use it under the good engineering practice clause since this is different technology, but I'm not sure enough to comment.

73...

Ken