I'm not a lawyer either, Walt, but the 300 baud symbol rate
limitation from §97.305(c)(3) below applies to "a RTTY or data
emission", not the individual components of that emission IMHO.
You and I have discussed this potential loophole in the past, and my
advice was to run it up the flagpole with Hollingsworth at the FCC
before mounting any major effort to exploit it. Any progress on that
front?
73,
Dave, AA6YQ
--- In digitalradio@yahoogroups.com, "DuBose Walt Civ AETC CONS/LGCA"
<[EMAIL PROTECTED]> wrote:
>
> What is this 300 symbol/sec limit? I don't see that in Part 97.
>
> §97.305(c) of this Part.
> (1) No angle-modulated emission may have a modulation index
greater than 1 at the
> highest modulation frequency.
> (2) No non-phone emission shall exceed the bandwidth of a
communications quality phone emission of the same modulation type.
The total bandwidth of an independent sideband emission (having B
as the first symbol), or a multiplexed image and phone emission,
shall not exceed that of a communications quality A3E emission.
> (3) 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.
>
> You will note that the description the maximum frequency shift that
it references a single carrier. Thus the reference to the symbol
rate is for one carrier.
>
> In the Frederick/Harris modem, as I recall, no "carrier tone" has a
symbol rate of more than 45.5 (baud). Therefore Ok under Part 97.
>
> In interpreting Federal Administrative Code or Law, unless a
prohibition is specifically stated, you should not take it as implied.
>
> There is no implication that the 300 rate limit is for the total
sum of all carriers (tones) in a mode, rather for a single tone or
carrier.
>
> I am not an attorney but have a number of years working with
government engineers and DoD and DoJ attorneys in interpretation of
Federal Administrative Code or Law.
>
> If the FCC wants to limit the symbol rate to 300 for the total sum
on all data in a mode, then they are obligated to say so. The public
must NOT be left to guess what the "agency" is trying to say. Our
laws MUST BE CLEAR and understandable. Administrative Law and Code
does not, nor was it meant to convey our national feelings, prides or
desires. Rather to specifically define limits and give direction in
the implementation of Public Law.
>
> Don't put words in the FCC's code.
>
> And, don't let MARS interpretation of Part 97 cloud you view of it.
>
> 73,
>
> Walt/K5YFW
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