Rick,

It was my petition that caused this part of the R&O.


>I understand most of the new FCC rule changes that will go into effect
>on 11 Nov 06, but I am a bit confused when it comes to the digital changes.
>
>Under Item 15 below, they state:
>
>"Nevertheless, our Part 97 rules do not now authorize amateur stations
>to transmit both image and data emission types on any HF frequency
>segments,"

Image emissions have not been authorized in the RTTY/Data subbands of 
the 80 through 10 meter bands.


>I am probably misunderstanding something, but I had thought that we
>could transmit both image and data and voice throughout the 160 meter
>band. It is not necessarily meeting the band plans, but I had thought
>the FCC rules permitted it.

In the 160 meter band RTTY/Data/Voice/Image overlap.  80 thorugh 10 
meters RTTY/Data and Phone/Image are separated.


>Hopefully, others will have a lot more understanding than I have on what
>it is they are permitting on the "data" portions of the bands which to
>me means anything that is not the phone section. If I understand it,
>they will allow both analog and digital image in the non-phone areas,
>but only if they are narrow bandwith or under 500 Hz?

Correct.  I chose 500 Hz because this is the bandwidth that is 
accepted by most amateur radio operators as a reasonable maximum 
bandwidth in the RTTY/Data portions of the 80 through 10 meter bands.

>But no data to be transmitted in the phone areas except for "image" and
>digital voice. I am very disappointed if we can not include "data" when
>using WinDRM types of programs in the phone portion of the band and I
>can not understand their reasoning on this. Unless what they really mean
>is that you could use WinDRM (wide band modes) in the phone section to
>transmit "data," but you can not use the narrow band modes in the phone
>band section such as RTTY.

You can use WinDRM to transmit digital voice and images in the 
Phone/Image subbbands.  You can use WinDRM to transmit data in the 
RTTY/Data subbands.  I agree that data should also be allowed in the 
Phone/Image bands, but I did not ask for that.  I belive in asking 
for a little at a time.

>I find Item 19 to be not fully clear about NOT accepting the ARRL's
>request to NOT impose a 500 Hz bandwidth limitation in the data area:

Let me explain this part about the ARRL.  The ARRL wrote a comment 
during the comment period to the FCC.  The full text is at 
http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6516213520
 
The part dealing with my petition starts in section III.  Simply put 
the ARRL was opposed to the 500 Hz lamination that I asked to be 
placed on image emissions transmitted in the RTTY/Data 
subbands.  Here is the reason for their objection.  Winlink2000 
stations have have been transmitting images for many years in the 
RTTY/Data portions of the HF bands.  These emissions have not been 
authorized.  For Winlink 2000 stations to continue to transmit images 
without lowering speed, the 500 Hz limitation could not be 
implemented.  I felt the best way to allow image emissions in the 
RTTY/Data portions of the 80 through 10 meter bands was to ask for a 
bandwidth limit.  SInce the emissions I was asking for were analog, 
this is the only way I could guarantee that wide band emissions would 
not make their way into these subbands.

The primary reason for my petition was to allow U.S. amateurs to use 
the narrow band image mode found in MixW.  This analog image mode is 
used with MFSK16.  This is just a first step in many steps that must 
be taken in my opinion.

73,

Mark N5RFX 



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DigiPol: http://groups.yahoo.com/group/Digipol  (band plan policy discussion)

 
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