ODV, When the FCC acted in November to replace the symbol rate with a 2.8 kHz bandwidth limit for the HF bands, it also issued a Further Notice of Proposed Rulemaking (“Further Notice”) proposing to remove the remaining baud rate limits on other bands. The comment deadline on these proposed changes is January 8th. ARRL agrees with the FCC that the existing symbol rate limitations should be deleted, but does not have a position at this time on whether the existing bandwidth limits are appropriate, should be changed, or should be deleted; nor if bandwidth limits should be added to the LF bands. At an EC meeting last week it was suggested that input be solicited from members, especially those who operate on the bands at issue. Given the holidays, I suggest we schedule a zoom call AND ask for email input. Do I have a volunteer from among you who will schedule a call -- this Wednesday or Thursday evening would be good but I am reasonable flexible -- so that all ODV members can reach out and ask their relevant constituents to join the call or, alternatively, to email their suggestions (maybe to a unique email address at HQ for forwarding or viewing by me?). [I do not have access to ARRL's zoom platform for scheduling calls.] Below is a synopsis of the bands under consideration, existing symbol rates proposed to be deleted, and existing bandwidth limits that the FCC proposed to keep --- presumably for "specified" as well as for "unspecified" codes. Comment is appropriate on bandwidth limits different from the existing ones, but rationales would have to be stated (“why”?). The reason to do something this week is the holidays, but if you think better, we could try for something between Dec. 26 and Dec. 30 also. Everyone should be aware that for this purpose it is essential not to just state "what" should be done, but also "why". Bands Up for FCC Consideration to keep, change, or delete bandwith limits. (I assume no one would keep the symbol rates.) • 135.7 – 137.8 kHz band (2200 meters) and 472-479 kHz band (630 meters): 300 baud symbol rate, currently no bandwidth limits. • 50.1-54 MHz (6 meters) and 144.1-148 MHz (2 meters): “specified digital codes” limited to 19.6 kilobauds; “unspecified digital codes” limited to 20 kHz bandwidth. • 219-220 MHz portion of the 1.25 meter band has no symbol rate limit for specified codes; unspecified digital codes limited to 100 kHz bandwidth. • 222-225 MHz portion of the 1.25 meter band and 420-450 MHz (70 centimeters): specified digital codes limited to 56 kilobauds and unspecified digital codes to 100 kHz bandwidth. Definitions
“specified digital codes” defined at 97.309(a): “ Where authorized by §§ 97.305(c)<https://www.ecfr.gov/current/title-47/section-97.305#p-97.305(c)> and 97.307(f)<https://www.ecfr.gov/current/title-47/section-97.307#p-97.307(f)> of the part, an amateur station may transmit a RTTY or data emission using the following specified digital codes:
(1) The 5-unit, start-stop, International Telegraph Alphabet No. 2, code defined in ITU–T Recommendation F.1, Division C (commonly known as “Baudot”). (2) The 7-unit code specified in ITU–R Recommendations M.476–5 and M.625–3 (commonly known as “AMTOR”). (3) The 7-unit, International Alphabet No. 5, code defined in IT–-T Recommendation T.50 (commonly known as “ASCII”). (4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.
“unspecified digital coes” defined at 97.309(b): “Where authorized by §§ 97.305(c)<https://www.ecfr.gov/current/title-47/section-97.305#p-97.305(c)> and 97.307(f)<https://www.ecfr.gov/current/title-47/section-97.307#p-97.307(f)>, a station may transmit a RTTY or data emission using an unspecified digital code, except to a station in a country with which the United States does not have an agreement permitting the code to be used. RTTY and data emissions using unspecified digital codes must not be transmitted for the purpose of obscuring the meaning of any communication. When deemed necessary by a Regional Director to assure compliance with the FCC Rules, a station must:
(1) Cease the transmission using the unspecified digital code; (2) Restrict transmissions of any digital code to the extent instructed; (3) Maintain a record, convertible to the original information, of all digital communications transmitted. 73, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
