Hi all: Dave explained how the meaning is clear and there is no needto take action. I’d suggest we take counsel’sadvice and leave it as is. 73 Rick – K5UR -----Original Message----- From: Michel, Howard, WB2ITX (CEO) <wb2itx@arrl.org> To: k5ur@aol.com <k5ur@aol.com>; Jairam, Ria, N2RJ, (Dir, HD) <rjairam@gmail.com>; Carlson, Kermit, W9XA (Dir, CL) <W9XA@yahoo.com>; arrl-odv <arrl-odv@arrl.org> Cc: david@davidsiddall-law.com <david@davidsiddall-law.com> Sent: Wed, Jul 31, 2019 9:18 pm Subject: [arrl-odv:28491] Re: HF Digital Voice Effectively Stopped? Dear Officers, Directors and Vice Directors,I've discussed this with Atty Siddall. Since the resolutions directs him to take action, his understanding of the motion is critical.As has been discussed here, there is no “digital” mode used in the FCC rules for HF subband definitions. There are only five modes: CW, RTTY, data, phone, and image. Atty Siddall stated "In any event, although the concern raised is legitimate from a broader perspective, my thought is that the meaning is clear from context; and since “digital mode” is a nullity in this context – there is no such mode in the FCC’s rules with regard to HF subbands – no harm is done and it can be left as is. It certainly CANNOT be interpreted to require digital voice to move into the ACDS bands, because digital voice is a “phone mode” and therefore its permitted subbands are unaffected by the term." He further states "The FCC staff will read our pleading, not the Resolution (which is not sent them)." Therefore I recommend that we not change the motion.Having said that, if the Board thinks that the record needs to be made clearer, we have two options to change the motion. To do it correctly would require a Board vote. If the vote is done by email, all Board members would have to vote, and to vote affirmatively. Or we could call a special meeting of the Board, ie a phone call. You would only need a majority to approve the motion but you would need to comply with the provisions for calling such a meeting.Rick, I think this is your call. 73, Howard, WB2ITX On 7/31/2019 1:20 PM, Roderick, Rick, K5UR via arrl-odv wrote: (2) All digital mode stations that operate with a bandwidth greater than 500 Hz also must operate within the ACDS bands designated in the FCC's Rules, whether or not automatically controlled. Dave, the reference was in the motion we passed on the symbol rate matter (minute 31). The rub is in the highlighted yellow part where we say "All digital mode stations" when we really mean all digital "data" mode stations. 73Rick - K5UR -----Original Message----- From: david davidsiddall-law. com <david@davidsiddall-law.com> To: k5ur@aol.com<k5ur@aol.com>; rjairam@gmail.com <rjairam@gmail.com>; w9xa@yahoo.com <w9xa@yahoo.com> Cc: arrl-odv@arrl.org<arrl-odv@arrl.org> Sent: Wed, Jul 31, 2019 11:17 am Subject: [arrl-odv:28486] Re: HF Digital Voice Effectively Stopped? #yiv1236917388 -- filtered {panose-1:2 4 5 3 5 4 6 3 2 4;}#yiv1236917388 filtered {font-family:Calibri;panose-1:2 15 5 2 2 2 4 3 2 4;}#yiv1236917388 p.yiv1236917388MsoNormal, #yiv1236917388 li.yiv1236917388MsoNormal, #yiv1236917388 div.yiv1236917388MsoNormal {margin:0in;margin-bottom:.0001pt;font-size:11.0pt;font-family:sans-serif;}#yiv1236917388 a:link, #yiv1236917388 span.yiv1236917388MsoHyperlink {color:blue;text-decoration:underline;}#yiv1236917388 a:visited, #yiv1236917388 span.yiv1236917388MsoHyperlinkFollowed {color:purple;text-decoration:underline;}#yiv1236917388 p.yiv1236917388msonormal0, #yiv1236917388 li.yiv1236917388msonormal0, #yiv1236917388 div.yiv1236917388msonormal0 {margin-right:0in;margin-left:0in;font-size:11.0pt;font-family:sans-serif;}#yiv1236917388 span.yiv1236917388EmailStyle18 {font-family:sans-serif;color:windowtext;}#yiv1236917388 .yiv1236917388MsoChpDefault {font-size:10.0pt;}#yiv1236917388 filtered {margin:1.0in 1.0in 1.0in 1.0in;}#yiv1236917388 div.yiv1236917388WordSection1 {}#yiv1236917388 Rick, I have not seen the draft minutes, which I think (?) is what these comments address, so my comments are general in nature. Current FCC regulation is by defined “modes,” at Section 97.305. The modes related to HF are defined as CW, data, RTTY, phone, and image. “Digital” is not a mode for purposes of this section. CW is allowed on all frequencies. RTTY/data have subbands, as do phone/image. Digital voice and SSTV both are limited to the phone/image bands, even though in common parlance they otherwise might be viewed as “digital modes. ” The current FCC regulatory modes are somewhat agnostic on whether a signal is digital or analog. I don’t think anything done at the Board meeting was to suggest a regulatory change with regard to digital voice, or more generally, to the current HF modes as defined by the Commission. Hope that this helps. 73, Dave From:"k5ur@aol.com"<k5ur@aol.com> Date: Wednesday, July 31, 2019 at 12:02 PM To: "rjairam@gmail.com"<rjairam@gmail.com>,"w9xa@yahoo.com"<w9xa@yahoo.com> Cc: "arrl-odv@arrl.org"<arrl-odv@arrl.org>,"david@davidsiddall-law.com"<david@davidsiddall-law.com> Subject: Re: [arrl-odv:28480] Re: HF Digital Voice Effectively Stopped? I've sent some of the emails to counsel Siddall to fill him in and have asked Howard to coordinate with Dave to see what we need to do. 73Rick - K5UR -----Original Message----- From: rjairam@gmail.com<rjairam@gmail.com> To: Kermit Carlson <w9xa@yahoo.com> Cc: arrl-odv <arrl-odv@arrl.org> Sent: Tue, Jul 30, 2019 8:43 pm Subject: [arrl-odv:28480] Re: HF Digital Voice Effectively Stopped?Kermit, I think this is a good clarification, although it may be unnecessary. But since a lot of concerns were raised about modes like DMR and DSTAR which wouldn't have been affected, this would at least clarify things. However I think David is the best person to ask about this since he has experience with how the FCC would react. Ria N2RJ On Tue, 30 Jul 2019 at 21:38, Kermit Carlson <w9xa@yahoo.com> wrote:
Hello Dick, Ria et al,
Could there be a statement of consensus by the Board affirming that digital voice should continue to be considered a voice mode and treated separrate from digital data modes as it has been for over two decades ? I remember that Mr. Siddall mentioned during our meeting that to a large measure that the FCC is inclined not to make large changes; keeping DATA and Voice separate should not require anything more than a clear explanation of the Board’s intent not to change that distinction.
Thank You
73, Kermit W9XA
Sent from Yahoo Mail for iPhone
On Tuesday, July 30, 2019, 13:28, Richard J. Norton <richardjnorton@gmail.com> wrote:
The language of the Board motion says, "all digital mode stations."
The language does not specify anything about digital data or digital voice, although some may think it does.
73,
Dick
On Tue, Jul 30, 2019 at 11:03 AM rjairam@gmail.com <rjairam@gmail.com> wrote:
As far as I know, digital voice has never been categorized as a data mode. This is why they exist inside of the phone sub-bands, and not the data sub-bands. The same goes for digital SSTV including EasyPal which sends a link to a web file. It resides in the image sub-bands.
For some odd reason it appears as though the FCC cares about content and not so much the emission type.
If what you were saying we’re true, then all current digital voice operations would be illegal because they take place the phone sub-bands.
But we know better, so the long and short is that it won’t be affected.
73, Ria N2RJ
On Tue, Jul 30, 2019 at 1:24 PM Richard J. Norton <richardjnorton@gmail.com> wrote:
Digital voice has never been big on HF to the best of my knowledge, but is increasingly being deployed on VHF and also being deployed by commercial interests on frequencies outside the ham bands.
It looks like the motion passed at the last Board meeting on Interference and Enforcement, wll outlaw use of digital voice on frequencies below 28 MHz, except inside the tiny ACDS bands.
(2) All digital mode stations that operate with a bandwidth greater than 500 Hz also must operate within the ACDS bands designated in the FCC's Rules, whether or not automatically controlled.
I'm uncertain how this comports with parts of the basis and purpose of Amateur Radio, such as:
Continuation and extension of the amateur's proven ability to contribute to the advancement of the radio art [97.1(b)] Encouragement and improvement of the amateur service through rules which provide for advancing skills in both the communication ans technical phases of the art [97.1(c)]
How should the League respond to possible inquiries or complaints about stifling technical advancement?
73,
Dick Norton, N6AA _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv
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_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv________________________... arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv -- Howard E. Michel, WB2ITX Chief Executive Officer ARRL, The National Association for Amateur Radio® 225 Main Street, Newington, CT 06111-1494 USA Telephone: +1 860-594-0404 email: hmichel@arrl.org_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv