[digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread expeditionradio


Hi Roger,

ARRL was as confused as many other hams were by the new rules. That
was understandable, considering how poorly written and
self-contradictory they are.

But, in the case of the 500Hz bandwidth limit, the FCC has already
published guidelines in the RO to aid us in interpretation of their
new rules. If there is to be any argument about interpretation of the
rules, it is probably best to bet on the side of what FCC intended:

19.   ...To accommodate the concern raised by ARRL, however, we will
revise our rules to clarify that the 500 Hz limitation applies only to
the emission types we are adding to the definition of data when
transmitted on amateur service frequencies below 30 MHz.
By amending the rule in this manner, the 500 bandwidth limitation will
not apply to other data emission types or amateur service bands in
which a higher symbol rate or bandwidth currently is permitted.

After reading the FCC's own words, you can now clearly see that FCC
never intended to limit the fast data modes that hams have been using
for many years. Their intent is to only limit images sent in the data
subbands to 500Hz bandwidth. Nothing more.

There is no deception. Pactor-3 is legal on HF, as it always has been.
In fact, Pactor-1 can now be used to send photos in the data subband.

73---Bonnie KQ6XA

 Is this topic header pretty deceptive?  It appears to say that an FCC 
 clarification of the new regs decides Pactor III to be OK on HF.  But 
 instead the author of this post is offering an opinion independent of 
 the FCC and at variance with the determination of the ARRL staff.  
 Opinions are OK, but not when presented as rulings when they are 
 no such thing.
 
 de Roger W6VZV






Re: [digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread Roger J. Buffington
expeditionradio wrote:



  Hi Roger,

  ARRL was as confused as many other hams were by the new rules. That
  was understandable, considering how poorly written and
  self-contradictory they are.

  But, in the case of the 500Hz bandwidth limit, the FCC has already
  published guidelines in the RO to aid us in interpretation of their
  new rules. If there is to be any argument about interpretation of the
  rules, it is probably best to bet on the side of what FCC intended:

  19. ...To accommodate the concern raised by ARRL, however, we will
  revise our rules to clarify that the 500 Hz limitation applies only
  to the emission types we are adding to the definition of data when
  transmitted on amateur service frequencies below 30 MHz. By amending
  the rule in this manner, the 500 bandwidth limitation will not apply
  to other data emission types or amateur service bands in which a
  higher symbol rate or bandwidth currently is permitted.

  After reading the FCC's own words, you can now clearly see that FCC
  never intended to limit the fast data modes that hams have been using
  for many years. Their intent is to only limit images sent in the
  data subbands to 500Hz bandwidth. Nothing more.

  There is no deception. Pactor-3 is legal on HF, as it always has
  been. In fact, Pactor-1 can now be used to send photos in the data
  subband.

  73---Bonnie KQ6XA


Actually, it is mostly Greek to me.  I admit it.  Are you saying that 
the above quote, beginning with the numeral 19 came out **after** the 
ARRL interpreted the regs as prohibiting Pactor 3? Or are you simply 
disagreeing with ARRL on the interpretation of the FCC regs? 

And how does this affect Olivia and MT-63?  Since these modes were 
presumably included in the original definition of Data are they 
unaffected as well--i.e. 1Khz Olivia and MT-63 would be permitted below 
30 Mhz?

de Roger W6VZV



[digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread expeditionradio
 And how does this affect Olivia and MT-63?  Since these modes were 
 presumably included in the original definition of Data are they 
 unaffected as well--i.e. 1Khz Olivia and MT-63 would be permitted 
 below 30 Mhz?
 
 de Roger W6VZV

Hi Roger,

1kHz and 2kHz bandwidth Olivia or MT63 are not affected by the new FCC
rules for Data or Text. They are allowed just the same as they have
been... no change.

But keep in mind that the new rules don't allow transmission of an
image in the data subbands using Olivia or MT63 (any bandwidth). You
have to QSY to the phone band if you want to use Olivia or MT63 for
sending images.
 
Bonnie KQ6XA






Re: [digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread Mark Miller
I disagree.  You can send images as long as the bandwidth is 500 Hz 
or less.  That is what J2C is all about.  A transmission can have 
more than one emissions designator as you have pointed out.  You may 
start by sending J2B, then during the course of the QSO switch to J2C 
without ever changing the modulation type.  With the image mode that 
is used with MFSK16 as employed by MixW, the emission there starts 
out as J2B, then switches to J3C, then back to J2B.


But keep in mind that the new rules don't allow transmission of an
image in the data subbands using Olivia or MT63 (any bandwidth). You
have to QSY to the phone band if you want to use Olivia or MT63 for
sending images.

Bonnie KQ6XA




Re: [digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread Mark Miller
Roger,

I will let Bonnie respond, but let me add my 2 cents.  Paragraphs 15 
through 19 address the rule changes which allow image 
emissions.  Paragraph 19 has most of us confused because while it 
says we will revise our rules to clarify that the 500 Hz limitation 
applies only to the emission types we are adding to the definition of 
data; J2D was already in the definition of data before this 
revision.  They also say the 500 bandwidth limitation will not apply 
to other data emission types or amateur service bands in which a 
higher symbol rate or bandwidth currently is permitted.  There is a 
footnote to that sentence that references 97.305(c), 
97.307(f)(3)-(8), (13).  This would indicate that the intention of 
the revision to the definition is to add image emissions that have a 
maximum occupied bandwidth of 500 Hz.  I am not sure why J2D was 
moved into the less than 500Hz area.  I would only be guessing if I 
gave my hypothesis.

73,

Mark N5RFX


Actually, it is mostly Greek to me. I admit it. Are you saying that
the above quote, beginning with the numeral 19 came out **after** the
ARRL interpreted the regs as prohibiting Pactor 3? Or are you simply
disagreeing with ARRL on the interpretation of the FCC regs?

And how does this affect Olivia and MT-63? Since these modes were
presumably included in the original definition of Data are they
unaffected as well--i.e. 1Khz Olivia and MT-63 would be permitted below
30 Mhz?

de Roger W6VZV




[digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread jgorman01
Bonnie,

Why can't you use bandwidths of 500 or less in Olivia or MT63 to send
images in the narrow subbands?  My copy of gMFSK allows setting
parameters of both protocols to values that should meet the
requirements of the new FCC rules.  I recognize MT63 may not have an
occupied bandwidth of 500 Hz at its lowest setting, but I haven't
researched that totally.

Jim
WA0LYK

--- In digitalradio@yahoogroups.com, expeditionradio
[EMAIL PROTECTED] wrote:

 But keep in mind that the new rules don't allow transmission of an
 image in the data subbands using Olivia or MT63 (any bandwidth). You
 have to QSY to the phone band if you want to use Olivia or MT63 for
 sending images.
  
 Bonnie KQ6XA






Re: [digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread Mark Miller
Jim,

Yes, MT3 at 500Hz bandwidth may have an occupied bandwidth greater 
than 500 Hz.  My spectrum analyzer has a hard time with bandwidths 
less than 500 Hz.  I used to not have that problem with it, but I 
have changed something.  I will have to check.  I went through the 
resolution bandwidth and video bandwidth, but that did not help.  The 
problem is that when I measure the occupied  26 db down, the 
bandwidth of a single tone it is 384 Hz.  That used to not be the 
case.  Maybe my delta 44 sound card is not as clean as I would have hoped.

73,

Mark N5RFX

At 11:56 AM 11/19/2006, you wrote:

Bonnie,

Why can't you use bandwidths of 500 or less in Olivia or MT63 to send
images in the narrow subbands? My copy of gMFSK allows setting
parameters of both protocols to values that should meet the
requirements of the new FCC rules. I recognize MT63 may not have an
occupied bandwidth of 500 Hz at its lowest setting, but I haven't
researched that totally.

Jim
WA0LYK




Re: [digitalradio] Re: FCC Rules: Pactor-3 is OK on HF, and Pactor-1 is OK for Image.

2006-11-19 Thread Andrew O'Brien
Roger, I read what Bonnie quoted , it was in the FCC regs that were 
published several weeks ago prior to being included in the Federal 
Registrar. I assume the same language made it to the version that the 
Federal Registrar published.


Andy, K3UK.