Ok Rick...here goes... I don't know about the ARRL DV WG's request. However, I believe that the League and its legal staff have come to understand that you don't want to ask the FCC for a ruling as you probably are going to get the strictest agency answer in writing which will/may cause you to have to request a rules change which the agency DOES NOT want to do...it is VERY time comsuming and all agency staffs have been cut due to budget constraints.
Thus the thought process is don't ask don't tell and its easier to ask forgiveness than permission. At least I HOPE that is the position the League has taken. Do what you feel is in accordance with good communications engineering technology advancement and amateur radio practice. Remember that a "ticket" from the FCC can always be asnwered with..."sorry about that, I will quit doing it." And then quit doing it until you get an STA, experimental license or rule change. Ref. MT63, as you say, the max. baud rate for MT63-2K is 20 baud so 64 tones times 20 baud is a total of 1280 baud. If the 300 baud rate applies to the mode, then MT63 is not IAW Part 97. Maybe the FCC didn't monitor my HF data operation in 2004. Hi Hi. 73, Walt/K5YFW -----Original Message----- From: digitalradio@yahoogroups.com [mailto:[EMAIL PROTECTED] Sent: Wednesday, August 30, 2006 8:10 PM To: digitalradio@yahoogroups.com Subject: [digitalradio] Maximum baud rate limitation The 300 baud issue was something that the ARRL Digital Voice Working Group Task Force brought up in Jan 2003: http://www.arrl.org/announce/reports-03/digi-voice.html In their minutes, under item 3B: " B) Support a rule interpretation that allows multimedia operation based on the primary content of emissions, and that interprets the 300-baud limit as pertaining to individual subcarriers, not to the total." Does anyone know if the rule was reinterpreted? Unlike modes such as Clover modes, which only transmits one specific tone at any one moment, am I correct that modes such as MT-63, are transmitting multiple tones at any point in time, therefore the baud rate of each tone is additive? It would seem that as long as each subcarrier was kept under 300 baud there should not be a limitation based upon the baud rate total of the signal. For example when using MT-63, there are 64 tones that at the l KHz BW runs as a 10 baud DPSK signal. Would each tone be considered a subcarrier? That would mean that MT-63 has 64 x 10 = 640 baud total. If you use the 20 baud rate with 2 KHz, then it would be 1280 baud total, even though each tone is running at 20 baud at that BW and speed. 73, Rick, KV9U DuBose Walt Civ AETC CONS/LGCA 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 > > >-----Original Message----- >From: digitalradio@yahoogroups.com [mailto:[EMAIL PROTECTED] >Sent: Wednesday, August 30, 2006 2:06 PM >To: digitalradio@yahoogroups.com >Subject: RE: [digitalradio] Re: ALE QRM is minimal > > > >Hi Walt, > >I guess you mean the Frederick 1102 made under license from Harris? >I have one of those actually. They are strictly to the standard, >1800hz PSK carrier, 2400bps symbol rate, the needed channel BW is >300-3300hz (3Khz) at any supported data rate (75-2400bps coded). Its >that symbol rate, its to high, it exceeds the 300 symbol/sec limit >per FCC Part 97. > >In MARS-ALE I added tailoring to get down to a 1200hz PSK carrier and >1600bps symbol rate, it works great at 200-2200hz for a 2Khz BW, but >the symbol rate is still to high. > >/s/ Steve, N2CKH > > > Need a Digital mode QSO? Connect to Telnet://cluster.dynalias.org Other areas of interest: The MixW Reflector : http://groups.yahoo.com/group/themixwgroup/ DigiPol: http://groups.yahoo.com/group/Digipol (band plan policy discussion) Yahoo! Groups Links Need a Digital mode QSO? Connect to Telnet://cluster.dynalias.org Other areas of interest: The MixW Reflector : http://groups.yahoo.com/group/themixwgroup/ DigiPol: http://groups.yahoo.com/group/Digipol (band plan policy discussion) Yahoo! Groups Links <*> To visit your group on the web, go to: http://groups.yahoo.com/group/digitalradio/ <*> To unsubscribe from this group, send an email to: [EMAIL PROTECTED] <*> Your use of Yahoo! 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