First and foremost, Happy Thanksgiving to everyone. (Actually, I hope most of you will be reading this post-turkey, not having spent your Thanksgiving morning on email.) Second, the large bandage that was on my right hand since surgery last Wednesday has been replaced with a much smaller one, so I'm better able to type. (My dominant left hand gets the same treatment beginning December 13.) Finally, I agree with Brennan's analysis. RM-11708 has no effect whatsoever on HF digital voice. The FCC's regulatory regime does not permit voice and data on the same frequency anywhere on HF except as Brennan has noted. I'm not familiar with the use of D-Star on HF, but since D-Star was not developed for the unique HF environment it seems unlikely that it would match the performance of the digital voice systems that have been, and continue to be, developed specifically for HF. Still, people ought to be able to play with it if they want to, and I believe it is legal to do so as long as data emissions are only incidental as per 97.3(c)(5). 73, Dave K1ZZ ________________________________ From: arrl-odv-bounces@reflector.arrl.org [arrl-odv-bounces@reflector.arrl.org] on behalf of Price, Brennan, N4QX Sent: Thursday, November 28, 2013 5:38 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 ________________________________________ From: arrl-odv-bounces@reflector.arrl.org [arrl-odv-bounces@reflector.arrl.org] on behalf of Woll, Marty, N6VI Sent: Wednesday, November 27, 2013 17:13 To: Imlay, Chris, W3KD; Sumner, Dave, K1ZZ; arrl-odv Subject: [arrl-odv:22119] Re: RM-11708 erratum Chris noted that HQ staff are receiving complaints based on confusion over the classification of digital voice. No doubt some are concerned that DV will show up in the data / CW bands. Others are concerned that their use of digital voice on HF will be restricted. With respect to D-Star, which is the subject of the calls I'm getting, I suspect that the absence (as far as I can tell) of definitive guidance is due to the dual nature of that mode; it is not just digital voice but both voice and data sent simultaneously. I do not find sufficient specifics in either Part 97.3 or in Part 2.201 to be able to respond to my concerned constituents with as definitive an answer as they are requesting. Although, being neither an attorney nor an engineer, I may well be missing something, here's what I find: Part 97.3(c)(5) defines "phone" as "Speech and other sound emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1, 2 or 3 as the second symbol; E as the third symbol. Also speech emissions having B as the first symbol; 7, 8 or 9 as the second symbol; E as the third symbol". From what I can tell, D-Star voice has a designator of 6K00F7W, which, because it has "two or more channels containing quantized or digital information" does not fit within the foregoing definition of "Phone". D-Star includes both a voice channel and a data channel; hence the "7" and "W" in its emission designator. Part 97.3(c)(2) defines "data" as "Telemetry, telecommand and computer communications emissions having (i) designators with A, C, D, F, G, H, J or R as the first symbol, 1 as the second symbol, and D as the third symbol; (ii) emission J2D; and (iii) 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." Clearly, D-Star, with its voice component, does not fit there, either. Since Icom has been selling HF+ transceivers with built-in or optional D-Star capability (IC-7100 and IC-9100, respectively), there have been D-Star HF nets on nearly all our HF bands. It is unclear to me - and, apparently to others - as to where in the FCC rules this phone + data mash-up is authorized on HF. (Why anyone would want to use a non-weak-signal mode on HF is beyond me, but that's another question.) The IC-9100 operating manual section on DV has illustrations showing only VHF and UHF frequencies on the displays, and there is no mention of using DV on HF. Still, people are putting their D-Star radios on the lower bands. As long as they are unsure as to where their authorization to do so comes from, we'll probably keep getting questions on the topic. Sorry for the bandwidth, but I would really like to have a chapter-and-verse response for my members. A secondary question is where a D-Star user would find recommended procedures for avoiding causing interference to weak-signal modes (such as, listen on SSB before transmitting on digital), assuming that a listener in the D-Star mode would, like one on FM, not hear CW, SSB or other amplitude-based signals.. 73, Marty N6VI ________________________________ From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Tuesday, November 26, 2013 1:09 PM To: dsumner@arrl.org; arrl-odv@arrl.org Subject: [arrl-odv:22114] Re: RM-11708 erratum However, there is some substantial feedback being received at Headquarters about the Petition in other respects, most notably with respect to the 2.8 kilohertz proposed occupied bandwidth limit for data communications. The principal misunderstanding found in these complaints is related to the classification of digital voice. According to the FCC rules, digital voice is classified as voice, not data. _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv