ARRL report - No Consensus Reached for FCC on “Symbol Rate” Issues

Discussion in 'Ham Radio Discussions' started by W0PV, Jul 17, 2019.

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  1. N9LYA

    N9LYA Ham Member QRZ Page

    This is just one rule in Part 97 that some Division Directors do not KNOW.. Sad state we live in today.. How many more do they not understand yet want to recommend change. When they do not realize what they are changing... If it were not so embarrassing it would be laughable. All we can hope for now is they try to KNOW Part 97 before they make further mistakes. Or assumptions.
    This notice below from 1995 explains its purpose and how it was conceived. It does not say ONLY Automatically Controlled Digital Station, can work in the Automatically Controlled Digital Sub Bands.. It just says all unattended to Unattended contacts must be in these subbands. all other responding to interrogation can be on any frequency in the HF Ham Bands Digital Segments.. And any digital mode can also be in the ACDSs. Its not an exclusive Band Segment for any mode or group.. No one owns a freq and we share our resources.. Wake up ARRL.. PLEASE.. 73 Jerry N9LYA





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    $//R&O,HF Amateur Digital Comm,PR Dck 94-59,FCC 95-163//$

    $/97.109 Station control/$

    $/97.221 Automatically controlled digital station/$

    Before the 95-163


    Washington, D. C. 20554

    In the Matter of ) PR Docket No. 94-59


    Amendment of Part 97 of the ) RM-8218

    Commission's Rules Concerning ) RM-8280

    HF Digital Communications in the )

    Amateur Service. )


    Adopted: April 17, 1995 Released: April 27, 1995

    By the Commission:


    1. On June 13, 1994, we adopted a Notice of Proposed Rule

    Making (Notice) in the above-captioned proceeding. In the

    Notice, we proposed to authorize automatic control of stations

    transmitting digital emission types on the High Frequency (HF)

    amateur service bands, subject to two conditions for such

    operation. The automatically controlled station must either be

    connected to another station that is under manual control, or the

    automatically controlled station must transmit within a subband

    designated for this purpose. In this Report and Order, we adopt

    the proposed rules.


    2. In response to the Notice, we received nineteen comments

    and one reply comment. The comments ranged from recommending

    that automatic control not be authorized under any condition to

    recommending that automatic control be authorized

    unconditionally. They confirmed generally that the amateur

    service has a need for stations to transmit digital emission

    types on the HF bands while under automatic control. The

    comments also established that there is concern that such

    transmissions could cause interference to other communications.

    The comments, however, generally agree that the conditions

    proposed will provide the necessary degree of protection against

    such interference. They indicated, moreover, that the desired

    communications can be carried out under the conditions proposed.

    3. Except for temporary authority we issued to permit a

    feasibility study directed by The American Radio Relay League,

    Inc. (ARRL), automatic control has not been authorized on the HF

    bands. Heretofore we have considered immediate action by the

    station control operator as necessary to avoid causing

    interference to the communications of other amateur stations

    transmitting on an HF band. A station transmitting on an HF

    band usually demands greater attention by its control operator

    than does a station transmitting on Very-High Frequency (VHF) and

    higher frequency bands because HF radio wave propagation is long

    range and changes often. The comments, however, indicated that

    such operation is practical on the HF bands when the

    automatically controlled station is simply responding to

    interrogation by a station having the control operator at its

    control point or when the station is transmitting on a channel

    located within a small subband designated for that purpose.

    4. The ARRL supports the proposal. It states that absent

    consensus in the comments, we should take the compromise approach

    reflected in the rules as proposed. It contends that

    authorization of automatic control will result in greater

    flexibility in experimentation and development of digital

    communications as well as facilitate adaption of existing digital

    technologies to practical use. In another comment that

    strongly supported automatic control, however, Colby states that

    establishing and maintaining communications on a shared HF

    channel is no different than it is on a shared VHF channel, and

    opposes any conditions on automatically controlled amateur

    stations beyond those now required in the VHF bands. The ARRL

    argues that additional conditions proposed are necessary because

    any automatically controlled station transmitting in a crowded

    shared HF band involves a substantially increased risk of

    interference. Other comments also express concern with an

    increased risk of interference. Further, they oppose the

    establishment of subbands as a solution to the interference

    concern because subbands would significantly reduce the available

    spectrum for stations transmitting other emission types.

    5. Automatic control of stations transmitting digital

    emission types enables amateur operators to utilize high-speed

    computer-based message technology for the rapid and accurate

    relaying of messages and data. For this reason, we conclude that

    there has been demonstrated a need for stations in the amateur

    service to transmit on the HF bands under automatic control.

    Such operation will result in greater flexibility in

    experimentation and development of digital communications.

    6. We do recognize the concerns of those who oppose the

    proposal on the basis of potential interference, and in response

    to these concerns we are limiting when automatic control can be

    employed. First, the control operator of the station that is

    connected to the automatically controlled station must prevent

    the automatically controlled station from causing interference.

    Second, we are designating subbands to which transmissions

    between two automatically controlled stations are confined.

    These subbands are a small portion of the spectrum otherwise

    available for digital emission types. We also are confident in

    the ability of the amateur service community to respond, as it

    has in the past, to the challenge of minimizing interference with

    novel technical and operational approaches to the use of shared

    frequency bands.

    7. Requiring automatically controlled stations to transmit

    only in the designated subbands when communicating with another

    automatically controlled station, furthermore, will not reduce

    the HF spectrum available for other emission types. The

    bandwidth of the transmissions of an automatically controlled

    station will occupy no more than 500 Hz, and the subbands

    represent only 3.8 percent of the HF spectrum authorized to the

    amateur service. Other than Morse telegraphy, only digital

    emission types are currently authorized for the specified

    subbands. Nothing in the rules that we are adopting prohibits

    other stations from continuing to share these subbands.


    8. In summary, we are amending the amateur service rules to

    authorize automatic control of amateur stations. To lessen the

    possibility of inadvertent interference, the automatically

    controlled station either must be connected to another station

    that is under manual control, or the automatically controlled

    station must transmit only within a subband designated for

    communications between automatically controlled stations. We

    believe these rule changes will allow the amateur service

    community to contribute to communication technology and to

    advance its communication and technical skills consistent with

    Section 97.1 of the Commission's Rules, 47 C.F.R. 97.1. We see

    this action as fundamental to our commitment to provide maximum

    flexibility to the amateur service community. Therefore, we will

    amend the amateur service rules as set forth in the attached



    9. Accordingly, IT IS ORDERED that effective July 1, 1995,

    Part 97 of the Commission's Rules, 47 C.F.R. Part 97, IS AMENDED

    as set forth in the Appendix hereto. Authority for this action

    is found in Section 4(i) and 303(r)of the Communications Act of

    1934, as amended, 47 U.S.C. 154(i) and 303(r).

    10. IT IS FURTHER ORDERED that this proceeding IS


    11. For further information, contact William T. Cross of

    the Wireless Telecommunications Bureau, Private Wireless

    Division, (202) 418-0680.


    William F. Caton

    Acting Secretary


    Part 97 of Chapter I of Title 47 of the Code of Federal

    Regulations is amended as follows:

    Part 97 - Amateur Radio Service

    1. The authority citation for Part 97 continues to read as


    Authority citation: 48 Stat. 1066, 1082, as amended;

    47 U.S.C. 154, 303. Interpret or apply 48 Stat. 1064-1068,

    1081-1105, as amended; 47 U.S.C. 151-155, 301-609, unless

    otherwise noted.

    2. Section 97.109 is amended by revising paragraphs (d) and

    (e) to read as follows:

    97.109 Station control.

    * * * * *

    (d) When a station is being automatically controlled, the

    control operator need not be at the control point. Only stations

    specifically designated elsewhere in this Part may be

    automatically controlled. Automatic control must cease upon

    notification by an EIC that the station is transmitting

    improperly or causing harmful interference to other stations.

    Automatic control must not be resumed without prior approval of

    the EIC.

    (e) No station may be automatically controlled while

    transmitting third party communications, except a station

    transmitting a RTTY or data emission. All messages that are

    retransmitted must originate at a station that is being locally

    or remotely controlled.

    3. A new Section 97.221 is added to Subpart C To read as


    97.221 Automatically controlled digital station.

    (a) This rule section does not apply to an auxiliary

    station, a beacon station, a repeater station, an earth station,

    a space station, or a space telecommand station.

    (b) A station may be automatically controlled while

    transmitting a RTTY or data emission on the 6 m or shorter

    wavelength bands, and on the 28.120-28.189 MHz, 24.925-24.930

    MHz, 21.090-21.100 MHz, 18.105-18.110 MHz, 14.0950-14.0995 MHz,

    14.1005-14.112 MHz, 10.140-10.150 MHz, 7.100-7.105 MHz, or 3.620-

    3.635 MHz segments.

    (c) A station may be automatically controlled while

    transmitting a RTTY or data emission on any other frequency

    authorized for such emission types provided that:

    (1) The station is responding to interrogation by a station

    under local or remote control; and

    (2) No transmission from the automatically controlled

    station occupies a bandwidth of more than 500 Hz.
  2. KY5U

    KY5U Subscriber QRZ Page

    Excellent Strawman argument.
    I do not want to kill Winlink to wit, I just want it to stay as it is bandwidth wise, I want the ARRL subterfuge to be over on it's behalf, and I would like to see emails myself. The page says:

    "If you are not a Winlink user and are a member of the amateur radio community, you may request an account for access. Please send your request for an account and provide:
    • your first and last names
    • your current callsign
    • your email address
    • ASent

    You do not need to use Winlink radio email to have access. Access will be granted if your email address and callsign are confirmed. Please allow 24-48 hours for processing your request."

    So for the 4th time:

    Screenshot from 2019-10-11 06-41-16.png

    Sent 10/11/19 @ 6:55 AM
    Last edited: Oct 11, 2019
    NL7W likes this.
  3. KY5U

    KY5U Subscriber QRZ Page

    Whoop-t-doo.... Directors don't know. I accept that, but the gist of the ruling:
    ACDS authorization...YES
    ACDS has own subband...YES
    Mention of additional data modem bandwidth...NO
    Last edited: Oct 11, 2019
  4. N9LYA

    N9LYA Ham Member QRZ Page

    Hi.. Thanks I do agree its an excellent Argument. Thanks you.. :) SARC...
    You may not want to but SOME do want to KILL WINLINK they see it as competition for air time.

    Yes I agree the ARRL are in over their heads. 73
  5. N9LYA

    N9LYA Ham Member QRZ Page

    If they do not understand 97.221 how can they make a decision/recommendation one way or the other.
    *ACDS in one aspect means Automatically Controlled Digital Station
    **ACDS in another aspect means Automatically Controlled Digital Sub-band
    Only Unattended to Unattended *ACDS are required to play only in the **ACDS.
    They can be in any part of the Digital Bandplan is only responding to interrogation.

    WINLINK stations do not do Unattended to unattended anywhere.. They only respond to interrogation so they can be anywhere in the Digital Band Plan.

    And even though Unattended to Unattended *ACDSs must be in the **ACDSs that does not make it only their play ground any digital mode can work in this band space as well..

    as far as Bandwidth that is another topic for another day... 73 Jerry
  6. KY5U

    KY5U Subscriber QRZ Page

    Yep, read your post. They may do so at 500hz bandwidth.

    "(c) A station may be automatically controlled while
    transmitting a RTTY or data emission on any other frequency
    authorized for such emission types provided that

    (1) The station is responding to interrogation by a station
    under local or remote control; and

    (2) No transmission from the automatically controlled
    station occupies a bandwidth of more than 500 Hz.
  7. N9LYA

    N9LYA Ham Member QRZ Page

    That is true of any AC Digital Station OUTSIDE the ACDS (Automatically Controlled Digital Subband) They must only respond to interrogation and Bandwidth of 500 Hz or less.
  8. N9LYA

    N9LYA Ham Member QRZ Page

    Within the ACDS is a totally Different beast!
  9. KY5U

    KY5U Subscriber QRZ Page

    Wasn't Orthagonal OJ Simpson's first name?
    NL7W likes this.
  10. K0IDT

    K0IDT Ham Member QRZ Page

    At least you're consistent in what you believe is going on. What group decided the current events were all about them? What group is madly scrambling to hide past misdeeds (some still happening today)?
    If you don't wish to call unwanted attention to an operation perhaps screaming loudly about how it's all legal and above board is not the best course of action, that didn't work so well in the current case. Two decades plus of "nothing to see here", the arrogance of ARSFI, the corruption of the process involving the ARRL, and the chickens have come home to roost.

    Go back and reread RM-11831, you know the one that was written specifically to kill Winlink, the one where you said the intent was plain, if you read the message hidden between the lines. The message isn't in there, no invisible ink, no
    encryption, no attempts to otherwise hide the intent. It's just too bad certain parties made it all about themselves, and will most likely take down others in the process of committing suicide.
    NL7W likes this.

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