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Why (and How) You Should Urge the FCC to Reject the ARRL’s Symbol Rate Petition

Discussion in 'Working Different Modes' started by AA6YQ, Dec 7, 2013.

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  1. KV6O

    KV6O Ham Member QRZ Page

    Just filed my comment in favor of the petition. Thanks for the easy instructions on how to do so!

    The interference issue exists now, and will continue to exist if this gets adopted - it's an enforcement issue. Being limited to 300 baud is so 1978, and I thought we were a group that pushed the technical envelope, not one that clings to one that was created 30 something years ago. BTW, is already allowed on 60M (no symbol rate limit, max 2.8k BW) and the world hasn't ended, heck, I never even heard a complaint.

    Steve
    KV6O
     
  2. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    As has pointed out in this thread, the ARRL petition is not "orthogonally related" to the issue of interference from automatic stations: if adopted, the petition will allow such stations to use wider modes than they do today and thus increase the interference they generate.
     
  3. N1EN

    N1EN Premium Subscriber QRZ Page

    I note that you failed to respond to the point I actually raised.
     
  4. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    It's "failure to incorporate modern technology" issue, not an enforcement issue:

    1. When an automatic station disrupts your QSO because the remote station activating the automatic station can't hear you, no regulation has been violated. There is currently no regulation requiring an automatic station to forego transmitting if its frequency is not clear.

    2. Busy frequency detectors are digital signal processing algorithms that effectively detect CW, RTTY, SSB, PSK, and Pactor signals. These detectors have been developed and successfully deployed over the past 5 years; source code is publicly available. There is no good excuse for not incorporating them in automatic stations.

    Deploying automatic stations without busy frequency detectors is similarly regressive. Removing the 300 baud limit would allow busy automatic stations to use wider modes than they do today, and thus would increase the interference they cause. The 300 baud limit should be removed, but automatic stations should simultaneously be required incorporate busy frequency detectors in order to use modes wider than 2200 hertz. This would incentivize adoption of busy frequency detectors and thereby reduce interference from automatic stations. The ARRL petition should be rejected, modified to include this requirement, and resubmitted.

    Unlike any other HF amateur band, operation on 60m is channelized. Furthermore, 97.221(b) precludes automatic stations from using digital modes wider than 500 hertz on 60m. Thus extrapolating from experience on 60m is invalid.

    73,

    Dave, AA6YQ
     
  5. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    The premise of your point was incorrect. The ARRL petition is not "orthogonally related" to the issue of interference from automatic stations. If adopted, the level of such interference will increase.

    Furthermore, there is nothing to report to the FCC or an OO: automatic stations are not currently required to incorporate busy frequency detectors. When one starts up on top of your QSO, it is not violating any regulation.

    Besides making the situation worse by enabling automatic stations to use wider modes than they do today, the ARRL petition foregoes an opportunity to incentivize automatic stations to incorporate busy frequency detectors by requiring their incorporation to gain access to the wider modes enabled by eliminating the 300 baud symbol rate requirement.

    Hence the current focus of this thread is correct: the ARRL petition should be rejected, modified to require automatic stations using modes wider than 2200 hertz to incorporate busy frequency detectors, and re-submitted.
     
  6. W4PG

    W4PG Super Moderator Lifetime Member 279 Volunteer Moderator Platinum Subscriber Life Member QRZ Page

    There is currently NO limit on the bandwidth of digital modes in the non "phone/image" sub-bands. The current limit is solely by "gentleman's agreement." I see no reason why considerate users of the digital sub-bands will change their basic use if a limit of 2.8 kHz is adopted, especially considering that there currently is NO bandwidth limit in the digital sub-bands - only a throughput limit of 300 baud.
     
  7. AA6YQ

    AA6YQ XML Subscriber QRZ Page

    Non"phone/image" sub-bands are not relevant to this discussion. What is relevant are the sub-bands defined by 97.221 (b) in which automatic operation at bandwidths greater than 500 hertz is permitted. For automatic stations, the combination of the 300 baud symbol rate limit and the passbands of most HF transceivers limits bandwidth to 2200 hertz. By eliminating the symbol rate limit, the ARRL petition would increase this to 2800 hertz.

    Considerate operators of automatic digital stations have incorporated busy frequency detectors in those stations, and are not relevant to this discussion. What is relevant are the inconsiderate operators whose automatic stations do not incorporate busy frequency detectors, and whose stations will be able to use even wider modes than they do today if the ARRL petition is adopted -- increasing the interference they generate.
     
  8. NN4RH

    NN4RH Premium Subscriber QRZ Page

    Part 97.221 is not being changed. From the ARRL briefing memo, http://www.arrl.org/files/media/News/RM-11708 Briefing Memo.pdf




    Nobody in their right mind would be operating CW or conversational data modes in those automatically controlled segments in the first place.
     
  9. NN4RH

    NN4RH Premium Subscriber QRZ Page

    That's because it would weaken his argument if he limited to what the ARRL petition actually says. It's a lot easier for someone to argue against something by making up stuff about it.
     
  10. W4PG

    W4PG Super Moderator Lifetime Member 279 Volunteer Moderator Platinum Subscriber Life Member QRZ Page

    Non "phone/image" sub-bands are precisely the segments at issue. Where in the world do you think data modes, other than digital phone, take place? Am I to conclude you have no clue where the digital sub-bands at issue reside? Hint: it AIN'T the phone bands!

    If you think that simply listening on HF bands will fix the problem, there is this concept of "skip" that you need to check out. I don't doubt that busy detectors will help some, but they won't fully correct the problem.

    The ARRL petition will NOT allow wider modes than are allowed today. You appear not to understand the current FCC rules that places NO limit on bandwidth of data transmission in the non-phone/image sub-band. As an aside, the passband of my rig in SSB mode is set at 2.7 kHz, not 2.2 kHz.

    Please show me where the FCC rules restrict bandwidth of digital modes to 2.2 kHz. Hint: you will not find it since it doesn't exist (just in case you decided to waste your time looking).
     
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