OK, Mark, then it does look like we are not going to be able to use the 
wider modes in the CW/RTTY/Data area. I am not sure what wide modes you 
are referring to that are not sent with J2D as all of the ones I can 
think of are done with injecting tones into an SSB transmitter.

I did find the reference:

- - - - - -
ยง 97.3 Definitions.

(c) (2) Data. Telemetry, telecommand and computer communications 
emissions having
designators with A, C, D, F, G, H, J or R as the first symbol; 1 as the 
second symbol; D as the
third symbol, and emissions A1C, F1C, F2C, J2C, J3C, and J2D having an 
occupied bandwidth
of 500 Hz or less when transmitted on an amateur service frequency below 
30 MHz. Only a
digital code of a type specifically authorized in this part may be 
transmitted.
- - - - - - -

Therefore, it does not appear to be an error when you consider their 
earlier discussion of having narrower band modes in the data area.

I keep forgetting that we still have the RM-11306 bandwidth proposal 
coming eventually. However, I am beginning to suspect that the FCC has 
"telegraphed" some of its thinking along those lines. Maybe they will 
reverse themselves or maybe they will do the right thing and keep all 
data/CW/RTTY areas at or below 500 Hz and allow wide band modes to 
operate in the "phone" section. Then there would be no reason at all to 
even further address a complicated 200/500/3500 Hz scheme.

It does appear that Pactor 3 and wider modes as I mentioned earlier 
(Olivia, MT-63, etc.) may not be possible when this is finalized. Also, 
they would have to revist fully automatic control segments and either 
prohibit or allow automatic operation in some segments, either in the 
CW/Data or Phone areas.

I guess we now have to wait and see if ARRL finds out any additional new 
findings or clarifications.

73,

Rick, KV9U



Mark Miller wrote:

> Rick,
>
> The text in the R&O indicates that the 500Hz maximum occupied 
> bandwidth only applies to the new emissions designators added to the 
> definition of data. and the affected bands are below 30 MHz.  This is 
> what I asked for in my petition.  However, the FCC did put J2D in the 
> list of 500Hz maximum occupied bandwidth emissions designators.  I am 
> not sure why this was added, or if it was a mistake.  My guess is that 
> it should have read:
>
> emissions A1C, F1C, F2C, J2C, and J3C having an occupied bandwidth of 
> 500 Hz or less when transmitted on an amateur service frequency below 
> 30 MHz, and J2D.
>
> I think the and J2D ended up in the wrong spot.
>
> Unless the list is changed, the list of 500Hz maximum occupied 
> bandwidth emissions designators are:
>
> A1C, F1C, F2C, J2C, J3C, and J2D.  The other emissions designators  
> which do not fall under the 500 Hz maximum occupied bandwidth are 
> those with:
>
> A, C, D, F, G, H, J or R as the first symbol; 1 as the second symbol; 
> D as the third symbol, so a general statement that "they are no longer 
> going to
> permit ANY wide band digital modes in the CW/data sub band" is 
> incorrect.  Only images and digital signals input into the mic or 
> accessory jack of a SSB transmitter and transmitted below 30 MHz are 
> under the 500Hz limit.  Even if this was a mistake, I think you will 
> find a majority of amateur radio operators are happy with this decision.
>
> Why did not the FCC allow wide data modes in the phone area other than 
> the usual image modes?  No one asked for that in PR Docket 04-140.  No 
> one has asked because this will be a very unpopular request with the 
> majority of the amateur radio community.  This is one reason that the 
> ARRL petition to regulate by bandwidth is so unpopular.
>
> 73,
>
> Mark N5RFX




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