Hi, Brennan Thanks for your reply. It appears, then, that those transmitting voice using D-Star on HF are tiptoeing through but not around the rules. If data bursts (such as callsign, GPS coordinates and the like) are either suppressed or kept to a minimum that can be characterized as incidental, then D-Star voice is the functional equivalent of F2E, which is permitted in the phone portions of our HF bands as long as the modulation index is 1 or lower. The JARL's technical specifications for D-Star give me no clue as to the modulation index, but Bob Witte K0NR, in his Winter 2009 CQ VHF article, states that the modulation index for GMSK (D-Star's modulation scheme) is 0.5, well below the threshold specified in 97.307(f)(1). As to the incidental nature of the data content, I note that, on page 106 of the IC-9100 operating manual, Icom instructs those wishing to contact another D-Star station directly by calling CQ to program in their own callsign plus a pre-programmed CQ message and then hit "Transmit". It appears that the operator's lips are not moving at this point. However, I suppose one could forego that message programming and just call into the microphone. I believe the latter practice would be more in the spirit of the rules and that some guidance to this effect would be beneficial to the cause of D-Star HF operators. I, for one, would like to see the League take leadership in steering D-Star operators in the right direction if they have not already discovered it for themselves. I think I now have enough information to respond to the inquiries I'm getting, although I intend to reply by telephone only and do not plan on putting anything in writing (i.e., using voice, not data :-) ) Happy Thanksgiving to all, and safe travels . Marty N6VI -----Original Message----- From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Price, Brennan, N4QX Sent: Thursday, November 28, 2013 2:38 AM To: Woll, Marty, N6VI; arrl-odv Subject: [arrl-odv:22120] Re: RM-11708 erratum Marty and all, Happy Thanksgiving, to start. It appears that what I've circulated for review is still under review, and I suspect the holiday may keep it under review for a few days. But the ITU scoffs at American holidays, so I'm working, and I wanted to make an initial observation on D-Star on HF. Characterizing D-Star as combined voice and data, while not inaccurate, is dangerous for HF applications. At 6 meters and above, there are ample band segments, and usually entire bands, authorized for both phone and data emissions. At 10 meters or below, with the exception of 160 meters (and the 60 meter channels, into which a D-Star emission would not fit, as best I can tell), there are *no* band segments authorized for both phone and data emissions. This is the case now, and nothing in our petition changes that. I am not a D-Star operator myself, but as far as I can tell, HF D-Star activity is focused on digital voice. See, e.g., the D-Star HF net info at http://www.dstarinfo.com/DSTARHFNet.aspx. This net operates on phone frequencies, and data transmissions are not allowed on these frequencies, so if it's to be legal, it has to be phone--not phone and data, but phone, period. Any accompanying data is incidental to the phone transmission, so fortunately, this is a reasonable presumption. I know this isn't as chapter-and-verse as you might like, and I assure you it's not as chapter and verse as I am accustomed to. But emission types that postdate the classification of emissions in Part 97 are difficult to handle. Paul Rinaldo's practice was to encourage amateurs and regulators to make all reasonable presumptions that would make new emission types permitted. This was good practice, and I've tried to continue it, although some emission types just can't be saved even with all reasonable presumptions. It is reasonable to call D-Star voice, and we should do so with a minimum of questioning, because a characterization of D-Star as data carries negative consequences for its use on HF under the current rules. Our PRM does nothing to aggravate (or mitigate) those consequences. 73 and Happy Thanksgiving de HB9/N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079