Greg, thanks for your input. Let me take your points as laid out in your email: On Mon, Feb 13, 2012 at 2:43 PM, Greg Sarratt <w4ozk@arrl.org> wrote:
I think we should make the best practices document wording a little simpler and include a simple table that shows amateurs where to operate.
April QST will have a 2-page article which covers the document's scope but uses "friendlier" language. I have a draft of that article which may have been updated by now -- if you'd like to see the current version I can obtain it and pass it along. Once the directors have all chimed in and their suggestions vetted, the best practices document will be posted on the ARRL website, along with an introductory transmittal letter which will serve much the same purpose as the user-friendly QST article.
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We should make the CW operation requirement very clear, something like, Per FCC rules Only one CW station can transmit at a time per channel and must transmit exactly on the Channel Center frequency. (actually this statement could be made for all the modes but CW begs the clarifying statement)
The doc and QST draft make the "only one station" statement now. In fact, for my taste they are almost too strong -- not in the sense of discouraging off-center operation, but in discouraging possible multiple QSOs otherwise acceptable because of minimal QRM due to propagational 'recycling'. The Band Plan committee looked at defined +/- freq. tolerance as it applies to the 5 MHz band, and the meaning of "exact". The stated tolerance for HF (whether by FCC or NTIA I don't recall) is quite strict, but W3KD and K1ZZ both are confident this is not intended to apply to amateur use of the 5 MHz channels. The Feds want us to "get right on center" as defined by normal amateur operator diligence and techniques. We avoided discussion of exactness for these reasons.
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97.303 states PSK31 on the Carrier freq but the recommended document states Center freq? Am I reading this correctly??****
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Simple table:****
60M Operating Frequencies Table xx****
*Channel*
*Phone (USB)*
*PSK31 or PACTOR III*
*CW*
1****
5330.5 kHz****
5330.5 kHz****
5332.0 kHz****
2****
5346.5 kHz****
5346.5 kHz****
5348.0 kHz****
3****
5357.0 kHz****
5357.0 kHz****
5358.5 kHz****
4****
5371.5 kHz****
5371.5 kHz****
5373.0 kHz****
5****
5403.5 kHz****
5403.5 kHz****
5405.0 kHz****
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Let me quote from the Band Plan committee's author-in-residence WB8IMY for this:
*Greg may be misreading that portion of the R&O. See below.
"Accordingly, we amend Section 97.303(h) to specify that control operators of stations transmitting phone, data, and RTTY emissions (emission designators 2K80J3E, 2K80J2D, and 60H0J2B, respectively) may set the carrier frequency 1.5 kHz below the center frequency, and that, for stations transmitting CW emissions (emission designator 150HA1A), the carrier frequency is set to the center frequency."
The word "carrier" as it applies here is the "suppressed carrier," which would be 1.5 kHz below the center frequency. The FCC also specifies that when operating CW the carrier frequency is set to the center frequency.
And then in Note 64 in the R&O, the FCC becomes specific concerning PSK31 . .
"We adopt a modified instruction for PSK31 channel use to correct an error introduced in the NPRM. To have a PSK31 signal transmitted on the center frequency, the control operator should not set the carrier frequency to the center frequency but should instead set the carrier frequency 1.5 kHz below the center frequency (i.e., the same as for phone and data emissions)."
So, the tables and examples in the Recommended Practicies document and the April QST article are accurate. I'm not sure adding still more tables will make it clearer. It is also too late to do so for the April article.
We can add a line to the effect that the R&O permits only one signal (of any type) per channel. The FCC doesn't quite say this bluntly in the R&O, but they note that the NTIA does ask for that prohibition.*
Regarding your later email about different interpretations of the R&O -- there are PLENTY of landmines in the wording of the R&O. It took our in-house experts considerable time and diligence to ferret out intent -- both by reading the full document carefully, and knowing what NTIA's concerns are. In cases where doubt or wiggle room remained, we tried to err on the conservative side in formulating the practices doc -- we want to maintain our track record of relinquishing our secondary use quickly. We have hopes that doing so may lead to eventual allowance of multiple cw/data signals per channel, or even an allocation of contiguous spectrum. I think you'll be pleased with the style of the QST and web articles, which get away from the "spectacles and green eye-shade" feel of the Recommended Practices document. WB8IMY, as well as K1ZZ and W3KD have done yeoman duty on this project. 73 Bruce K0BJ