FCC Letter to Hi-Fi SSBers

WASHINGTON (QRZ.com) -- An "Advisory Letter" recently sent from the Federal Communications Commission warns a group of hi-fi SSB stations that complaints have come in about their station activities.

The letter addresses members of a group experimenting with audio techniques on single sideband that improve the sound of transmitted and received signals on that mode. Such audio quality subjectively sounds better but technically consumes more bandwidth, even among the cleanest, low-distortion signals, than does the more narrow, limited fidelity sound traditionally associated with SSB.

By way of background, we note here that the pursuit of hi-fi SSB has become increasingly popular among users of the latest microprocessor-based transceivers with "tone control" menus, and through the use of external audio hardware marketed to the amateur community for improved audio by such companies as Heilsound and W2IHY. Some SSB hi-fi buffs are using audio gear primarily intended for professional sound reinforcement, musicians, and broadcasters. Some hams additionally have modified their new and older amateur SSB equipment to experiment with improved audio techniques. Such modifications have always been part of the technical interests of the hobby, and remain legal on all homebrew and store-bought rigs intended for licensed amateur service.

However, controversy has come when such experimentation goes bad, and bandwidth is inappropriately made larger by poor design or practice causing "splatter" and interference from overmodulation and/or dirty amplification of poorly done audio modifications. These would be violations under existing FCC rules, including those that address purity of emissions.

The FCC letter, under the signature of Enforcement Counsel Riley Hollingsworth, K4ZDH, carries no enforcement sanctions but passes along complaints the Commission received that accuse the stations of being "wider than necessary and contrary to good engineering practice." The agency provided no confirmation that the complaints were actually valid. Hollingsworth acknowledged in the letter that "precise measurements of bandwidth may be somewhat complex," and depend somewhat on the "characteristics of the receiver being used."

Hollingsworth warned the amateurs that such complaints, if not resolved, may lead to Petitions for Rulemaking asking the agency for constraints. Hollingsworth encouraged the stations to make sure they avoid having "a negative impact" on other stations.

He then went on to generally describe problems that may lead to enforcement action, including how it can be "extremely inconsiderate of other operators" to employ "wide band overly-processed audio, especially when coupled with high intermodulation levels of certain amplifiers." Hollingsworth stopped short of directly concluding that these amateurs were guilty of such conduct or had transmitted questionable emissions, according to the text of the letter that has been distributed by at least two of the recipients.

In an interview conducted for an upcoming audio report for Amateur Radio Newsline, quoted here with permission, one ham who got the FCC advisory letter said the complaints focus on operations on the 20 meter band, where high occupancy sometimes leads to friction as people look for a place to operate. "There must be room on Amateur Radio for this kind of experimentation and enjoyment," said John Anning, NU9N, "if there is room for DXing, AM and SSTV."

Anning said "I'm not concerned. For every complaint filed, there are hundreds who think this is a great technical endeavor for the good of Amateur radio."

A second amateur who also received the letter, Paul Christensen, W9AC, told Newsline in an email that he's been off the air for six months, and that Hollingsworth "incorrectly addressed his Advisory Notice on the premise that I had been operating." Christensen cited and endorsed the objectives of the specialty group AM International, which he says includes promotion of experimentation and technical advancement.

Both of the men rejected any allegation their signals fail to meet technical standards, and both said they can show their signals are clean and permissable within the FCC's rules, which do not specifically define bandwidth.

But Hollingsworth had written that ham radio frequencies "were not allocated for a 'broadcast quality' audio emission or sound." He called it "shortsighted to transmit an 'enhanced Single Sideband' emission" in a heavily used Amateur band.

On the other hand, the FCC enforcer did NOT seem to totally reject the use of hi-fi techniques short of broadcast quality. Hollingsworth, according to the letter, suggested a review of historical operating patterns, where if an activity may have a negative impact, the alternative is "operating on uncrowded Amateur spectrum, or at times when spectrum used by many Amateur stations is not heavily utilized."

Hollingsworth, when asked to comment for this report, wrote in an email (cited with permission) that he had "no problem" with this account as written.

 

Gee, I feel left out; Riley didn't write me.

While it is possible that some are exceeding the 3KHz ssb bandwidth assumed by regulation, in the main we're dealing with good, clean signals, and not with overdriven amplifiers.  At least, that's my observation.

The bands are full of radios with inadequate dynamic range, and marginal IF filtering, and operators who can't tell the difference between poor receiver performance and a 'wide signal'.  

It will be interesting to see how this plays out.

N2EA

 

So called "HI-FI" audio is a complicated issue. Perception is probably the largest part of the issue. Personal tastes force subjective, rather than objective standards to be applied in the observation of a particular signal.

While I have heard some stations achieve truly good sounding audio, the majority do not really sound all that enchanting. Of course the same can be said for most of the "regular" stations on the air.  Try listening during a contest where you hear way too much compression and over driven audio, particularly on the 10 Meter Novice/Technician portion.

The other side of the coin is in receiving. Over the last 15 years, two major problems have surfaced due to the lack of understanding the technical aspects of the hobby. The first is the lack of understanding by "MOST" Hams to realize that their receiver is usually what is at fault. The second is an increasing aspect of climbing in too close to the next QSO where the high frequency audio products are put right into the next QSO's bandpass. When approached about the issue the offender claims  that he is not hearing the other QSO so he must not be  interfering.  Clearly a lack of understanding!

This is not to say that those that are experimenting with wide SSB are not, perhaps, being overly broad in their attempts or outright over driving their equipment and causing splatter. But, the same can be equally said for those offending stations chasing "DX" or operating in contests where all is OK in the pursuit of that contact.

The area that I have a real concern about is the out right abuse, under the color of authority, demonstrated by Mr. Hollingsworth. While Mr. Hollingsworth admits that the issue is one of "perception" and there is no legal basis for his writing, he nonetheless wishes to embarrass those written to as though they committed some egregious act.  The obvious intent is to please some people that are complaining.  The likelihood of those complaining having the proper technical equipment to prove an issue is in serious doubt.

Has Mr. Hollingsworth helped the issue?  The short answer is no! Those who complained did not understand that there is no legal basis for their complaints. So now they will think that this sets policy and continue with their short sided inappropriate complaining.

The whole issue is set forth in whether or not there is a clear and unambiguous definition of bandwidth for each type of modulation scheme employed. Currently no such definition exists, as it is left up to us "HAMS" to operate appropriately.  This greater latitude allows us the freedom to experiment with various concepts without being hindered by preconceived notions. Such notions like "SSB" is only 3 KHz wide, or that "AM" is only 6 KHz wide.

If those who complained feel that a more restrictive covenant is required then they can write a proper request for a rule change addressing that issue. The same goes for Mr. Hollingsworth, as he has the same personal rights to petition a rule change.

Mr. Hollingsworth's attempt to force his will, and others, by innuendo under the "color of authority" is clearly an abuse of his position. The act of writing these letters should be viewed as malicious intent bordering on a libelous act. Shame on you Riley!

.............................
Bill - WB6BNQ

 

How does that saying go ?  Even though it looks like he is stirring the pot and full of BS, I still defend his right to comment !!!

 

I think the HiFi SSB guys need an attitude check.  I just finished listening to a group on 17 meters and all they did was constantly perform for the listeners out there.  It started to sound like a talk show.  I was waiting for the 1-800 #.

The (2) stations mocked the FCC, mocked Riley, mocked his reprimand letters and mocked all those who use normal SSB transmissions.  They then proceeded to use sound effects such as echo, reverb.  They then switched  to normal bandwidth SSB, saying their audio sounded like their underwear was too tight etc.  I think you get the idea.  Infantile to say the least.

I would have greater respect for the HiFi SSB guys if they didn't make it so obvious their disdain for normal ~ 2.3 khz SSB.

Bottom line, I was left wondering what these (2) gentlemen were accomplishing and the only thing I could come up with was they wanted to hear themselves, while waiting for the obvious compliments from others that their audio was superb.  Ego?  Probably.

Sure others were listening but there simply was no point to the "Demonstration Audio" that I could perceive.

K2WH

 

WB6BNQ's comments are interesting; however, I for one have an excellent receiver and know how to properly use it.  When one monitors the bands, you will hear all levels of audio quality (or really lack of).  I have often helped others adjust their station to achieve good communications quality consistent with intent of §97.307(a).  Some hams achieve great sounding audio within reasonable bandwidth and without splattering.  But many of those I have heard (some on 20 m too) are fouling the spectrum nearby, which is harming the orderly use of the spectrum by other hams.  This is the point.  Want to experiment with wideband audio?  Then perhaps go up to 10 m where there is a lot of "room" to experiment.  As WB6BNQ correctly pointed out, many hams use compression or other forms of speech processing with results that result in interference with others nearby.     Not only is this true of US hams, but DX stations as well.  My experience in attempting to help other hams "tune" their stations is that almost all of them (1) want to have good audio, (2) don't want to interfere with others, and (3) just guessed at how to set the processor due to lack of good monitorig or the like.  On the other hand, there are those that beleive they "own" the spectrum and don't care for others or the rule.  §97.307(a) is much like the rule that we are required to use the minimum power necessary to conduct communications.  I expect that we all fail on this one too at times, but I do often tell folks that they are 20/9 or very strong and they and I both generally turn off the amps (if on) assuming we are going to chat for a bit.  Consideration is a major part of hamming and that is a big part of what Hollingsworth is addressing.  
73,
Barry - W4WB

 

Barry (W4BW);  I couldn't agree more with your assessment.  While WB6BNQ makes very thoughtful and factual comments, you have shown both sides of the fence.  I, too, wish to have better sounding on the air audio.  Never at the risk of becoming my own worst enemy, though.  It is true that we as HAM's should never cease experimenting with possible alternatives within the communications arena.  At the same time, however, concern for those around us (fellow HAM's, pedestrians, etc.) should be prevalent at all times.  This is certainly a tough call...  What's the right answer?  Who knows...  As for Mr. Hollingsworth, he's just like one of us...  Trying to do the job he signed up for to the best of his ability.  Besides, the letters which were sent were not convictions of guilt, nor did they imply that an investigation was taking place.  I think the letters were less of a warning and more a way of him suggesting that those who received the letter might just want to double check their equipment.  Those who received the letter should do so, as if their neighbor complained about receiving interference from their station.  Hey, you can never check your equipment enough to ensure its integrity, as well as your own!  Anyway, just my two-cents.  Thank you all for reading.

Chris   KC2KFW

 

"SSB hi-fi", Hahahaha, it _STILL_ makes me laugh. What's next, PSK-128K? I can see it now, PSK at the speed of ISDN.

 

I cant hear much difference in the sound in theses Hi-Fi stations.....I sure can hear and see the 4-8 KC splatter.
No one said you can not enhance your audio with in 3kc.
The Amateur Community sure does not like enhanced "Splatter"....If you like more than 3 Kc or need more than 3KC`s, there is a provision for those hams, use AM mode. leave SSB to 3KC or less to make communication`s enjoyable....
Lets remember there are others hams that have the right to communicate and not to violate there privalges by unnecessary WIDE BANDWIDTH splatter.
Consideration and good operating practice goes over well
and express "GOOD ATTITUDE" on air !!

97.307(a) of the Amateur Service rules that requires the signal of an amateur station to not occupy "more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good amateur practice."

 

My sympathies lie clearly on the side of those amateurs who disagree with the audio zealots' activities. For many of these broadcast-studio wannabe's ("bandwidth bandits" as I have come to regard their ilk), the utter absurdity of trying to cram 10KHz or more of "hi-fi" analog audio into a mere 3KHz passband, simply doesn't register!

In my opinion, Mr. Hollingsworth's effort to address this issue "softly" is appropriate, if only from a diplomatic standpoint. His timing could have been better, as I feel this should have been done LONG ago, but I am glad to see it finally brought to some form of official notice.

While true that there is no written regulation regarding a 3-KHz SSB voice emissions limit in Part 97 rules and regulations, the "You didn't say I couldn't do it" attitude, adopted by those hams who continue to steal more than their fair share of bandwidth, was bound to attract FCC attention.

Playtime is overwith, boys! Recognize Mr. Hollingsworth's letter for what it is---an attempt to get you to wake up to the fact that you CANNOT have your own personal FM broadcast-quality "studios" on the amateur bands! If you continue to cause problems for others (myself included) with your excessive occupation of shared bandwidth, you may soon induce the FCC into much sharper action than Mr. Hollingsworth's implied "PLEASE!".

 

Type in the calls of the hams who received letters from R.H. here on qrz.com. You will see some lengthy bio's that focus almost exclusively on their passion - striving for broadcast sound using 'enhanced' SSB.

What strikes me most, however, is listening to these guys (or others) on 14.178. The emphasis is hardly ever on what they have to say, but how they sound when they say it.

I can't help but smile because the enhanced SSB guys seem to be ham radio's 'body builders' - constantly checking themselves and each other out in front of their 'audio mirrors'. And just like many body builders who can't hit a baseball, the focus is on form not substance.

 

I see three issues at work here.

1. While it's admirable to see amateur radio operators experimenting with something in this day and age of CB-ified, plug-and-play appliance operation, the filter characteristics and intermodulation distortion figures of the SSB transmitter must be considered. If one tries to jam processed audio into a typical narrow SSB filter, ringing and distortion result. Even if the audio is not heavily processed, the filter can cause some very unpleasant effects on the transmitted signal. Have you ever noticed how women often sound as if they're talking into a barrel when they transmit SSB on many of the common rigs? The IM distortion will cause the signal to occupy excessive bandwidth. I cannot fault anyone who wants to sound like a human being on the air. But the transmitter must be properly designed for such service. Most of the common "riceboxes" don't cut the mustard here. Proper implementation of enhanced-fidelity audio on SSB should include the substitution of a phasing-type exciter for the conventional filter-type and examination of the transmitted signal with a spectrum analyzer.

2. Even with "normal" narrowband SSB, most of our phone subbands are horribly congested, with 20 and 75 meters being the worst ones. Meanwhile, the reserved nonvoice segments are sparsely used. If the FCC is so concerned about efficient use of spectrum, why are we still saddled with obsolete subband regulations that allocate half of the 75/80 meter band to CW and other nonvoice modes while CW is slowly but steadily declining? We should either join the rest of the world in abolishing subbanding and ghettoization completely or at least confine CW to the lower 25 kHz of each band, where most of the activity congregates anyway.

3. With every passing day, it becomes obvious that Riley Hollingsworth is an officious bureaucrat on a power trip who definitely needs to be reined in, or, better still, removed from any position dealing with FCC rules enforcement. The Enforcement Bureau carries a lot of responsibility. We neither need any loose cannons nor any miniature Hitlers in this bureau. One recipient of Hollingsworth's "advisory letter" mentioned in another forum that he hasn't even operated any form of SSB since October, 2002, although he has written articles on "enhanced SSB". If the inclusion of that amateur's name and callsign in an FCC Public Notice and on the ARRL Web site could be considered libellous, maybe it's time for a good attorney to file a lawsuit against Hollingsworth. It seems that Hollingsworth likes to write his own rules, judging from the text of some of his "advisory letters". Or he simply enjoys inserting a new, strict interpretation to FCC rules that are quite vague. As for his comment about amateur radio not being a "substitute for the Broadcasting Service", perhaps Mr. Hollingsworth should spend a bit more time monitoring 3890 and 14.275, so the Enforcement Bureau could issue a Notice of Violation or a Notice of Apparent Liability (for forfeiture) to a certain station in Belgrade Lakes, Maine that actually operates as a broadcast station while claiming that its broadcasts are "bulletins of interest to the amateur radio community."

 

Well geez, I guess the FCC is obliged to respond once having received a given number of comments regarding a particular type of operation. They appear to have responded in a completely appropriate manner, notwithstanding what their opinion may be as to the veracity of the commentary received.

Personally, it's far more interesting and enjoyable to listen to the audiophiles of 14.178, relative to some of the other routine operations found on the amateur bands. On the latter, the obscenity and vulgarity found nightly on 75M SSB, and sometimes on daytime 20M SSB comes to mind. Then there's the all too common 2M FM signal, where the operator has not a clue what audio level or deviation means, but he's adjusted the "modulation" on his "rig" all right. Then let's not forget the frequency police who feel a need to use the quasi spectrograph on their new Yaecom 756 Mark VI Pro III DSP (what's that) to tell you that your signal is splattering, or usually the term applied is "overmodulating". To silence these folk, just ask them what the spectral purity and emission standards are for the current operation, the one they're engaged in using also. You can have an awfully "dirty" signal and still be in technical compliance with FCC Part 97. Aaahh, but who needs to read FCC Part 97 anyway, when it's much simpler to harass the folks that are at least trying to experiment with different techniques aimed at educating themselves and others?

See you on the sats and V/U SSB for a while, at least.....

 

Dear Mr Hollingsworth,

And I use the term “Mr.” loosely I might add.

I find the letters and citations sent out to W2ONV, NU9N, W9AC, and W4NSG appalling and ridiculous. It is my belief that you need to go on record and remit your letters of poor amateur radio practice to these individuals.

I had lost all interest in amateur radio, and was about to sell all of my radio gear and give up the hobby, but then I crossed paths with SSB AUDIO and my interest in the hobby was rekindled. This aspect of the hobby brought back the passion and fascination for the hobby that I had lost. But now you want to remove this part of the hobby that is the ONLY part of the hobby I find interesting!! How dare you Riley and shame shame on you!!! Your personal opinion on this matter is irrelevant and you are doing more damage to the hobby than good at this point. I felt your position was to help and clean up the amateur radio bands, I thought you were here to help us keep our hobby alive and strong. But instead you are singling out those of us that appreciate SSB AUDIO and you are trying to banish us from the airwaves! Censorship?? I’m starting to wonder if this is the real issue.

I thought part of this hobby, and the founding principle of ham radio, was experimentation. Wasn’t this all started due to experimentation Mr. Hollingsworth? And I ask you, where would we be now if someone like YOU prevented experimentation 50 or 60 years ago? Where were all of the wide band bashers when FSK came along, where were they when SSTV came out, why are they not compaining about 10 meter FM, why am I not hearing of AM signals with heterodyne? Where were they when all of the WIDE modes started hogging up band width? They weren’t complaining then, and I ask you to think about that. Just for a minute ask yourself why there were no complaints about other wide band modes of operation. I will tell you, because this isn’t about Bandwidth, it’s about those that do not like hi fi ssb audio. We could use up 3kc bandwidth or 4 kc bandwidth and these people would still complain, it’s their personal position that hi fi ssb audio doesn’t have a place on the amateur bands. If this were a point of bandwidth the complaints would have been rolling in when any wider bandwidth mode of operation was occurring on the bands. If it’s a matter of bandwidth, why are these anti bandwidth bandits complaining of AM signals that occupy more bandwidth and produce heterodyne? Why? I will tell you why, because these are anti hi fi ssb audio bandits.

If you wish to remove wide band audio from the airwaves then you should start sending notices to those that operate SSB, SSTV, FSK, AM, FM and all SSB signals that are over 1.8 K. A reliable signal is intelligible with 1.8 K bandwidth Mr Hollingsworth, so why are you not taking that position and forcing all signals to be no wider than that? If you wish to site from the the fcc guildine then so will I:

Hollingsworth cited §97.307(a) of the Amateur Service rules that requires the signal of an amateur station to not occupy "more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good amateur practice."

This is 1.8 K is it not???? Is it not???????????????????

I have listened and partaken in conversations on 14.178 with 6 K wide audio. On hundreds of occasions we would set up on 14.178 and start transmitting and there would be no signals within 10 kc up or down of .178. After setting up our passband on 178 others would intentionally set up WITHIN our passband. Why? Strictly so they could say that they were being interfered with. But in reality they were causing intentional QRM to US!!!

I think what is taking place here is that you receive letters from individuals that are anti hi fi ssb audio, and this is the only side you are hearing from. You don’t receive the letters from those of us that enjoy this part of the hobby. So your only hearing one side of the story. I think you will be amazed at the numbers that you are affecting by taking this stance of anti hi fi ssb audio. We are much stronger in numbers that what you are aware. I cannot force others to write you, but I hope that you receive a letter from every single PRO HI FI SSB AUDIO proponent so you can be made aware that you, Mr. Hollingsworth, are making a big mistake.

HI FI SSB does belong on the airwaves!! This aspect has brought more people into the hobby, and kept more operators active in the hobby than any other aspect of amateur radio to date.

Sincerely,

N0PG
Anthony Whitmore

 

Oh geez. Hollingsworth is reacting to a problem that nets him up to 20 complaints per week. I'd be pretty upset if he didn't write a letter to the hi-fi ssbers. He's just doing his job, folks.

What galls me is NU9N's comment that he apparently doesn't care about the FCC letter. Frankly, that's a stupid way to behave. It's a surefire way to set in motion exactly what Riley doesn't want to happen - increased FCC regulations on amateur radio modes. Yet, people call Hollingsworth the Nazi... when you've hit the top of the epithet pile, I wonder what you'll call the FCC Commissioners who will eventually legislate bandwidth restrictions if this fractiousness doesn't stop.

I think there's a place for hi-fi ssb on the bands. Sure - I don't find any appeal in it, but to each as own. However, these hi-fi folks need to learn how to be good neighbors and comply with good amateur practice as well as realizing that the amateur bands prohibit broadcasting which the transmissions I've heard sometimes veer towards (not in quality but content).