Marty, nothing in the petition affects any HF subbands other than those to which the current 97.307(f)(3) and (4) apply, which are the subbands in which RTTY/data emissions are permitted. The phone/image emission subbands are not affected except on 160 meters, where the two happen to coincide (i.e. both RTTY/data and phone/image are authorized in the entire band). Phone is defined as “speech or other sound emissions,” whether analog or digital. Data is specifically defined as “telemetry, telecommand and computer communications emissions.” Section 2.201 may be helpful if Part 97 is not sufficiently clear. Dave From: Imlay, Chris, W3KD Sent: Tuesday, November 26, 2013 2:33 PM To: Woll, Marty, N6VI; Sumner, Dave, K1ZZ; arrl-odv Subject: Re: [arrl-odv:22109] Re: RM-11708 erratum Marty, I think the answer to your question is no, there is no inadvertent effect on digital voice modes which are currently permitted in the HF bands, though the symbol rate committee members are better able to address that point than I am. This erratum is both urgent and delicate, however, in terms of the perception of our petition as it was originally filed; and incorporating any other changes now is (in my view) unnecessary and risky. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG> -----Original Message----- From: Marty Woll <n6vi@socal.rr.com<mailto:n6vi@socal.rr.com>> To: 'Sumner, Dave, K1ZZ', K1ZZ' <dsumner@arrl.org<mailto:dsumner@arrl.org>>; 'arrl-odv' <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Sent: Tue, Nov 26, 2013 2:14 pm Subject: [arrl-odv:22109] Re: RM-11708 erratum Before we file the erratum, is there any chance our petition could inadvertently affect any digital voice modes currently permitted in the HF bands (i.e., the old is-it-phone-or-is-it-data question)? If so, should our amendment contain an explicit exclusion for digital voice? 73, Marty N6VI ________________________________ From: arrl-odv-bounces@reflector.arrl.org<mailto:arrl-odv-bounces@reflector.arrl.org> [mailto:arrl-odv-bounces@reflector.arrl.org<mailto:arrl-odv-bounces@reflector.arrl.org?>] On Behalf Of Sumner, Dave, K1ZZ Sent: Tuesday, November 26, 2013 9:54 AM To: arrl-odv Subject: [arrl-odv:22106] RM-11708 erratum In one respect the criticism being voiced about our RM-11708 petition has some merit. This is with regard to the addition of "unspecified digital codes" language to 97.307(f)(3). This change is not discussed at all in the body of the petition and was not intended to be included in the proposal. Chris is filing an erratum with a corrected appendix later today. The revised proposed 97.307(f)(3) will read: "Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The authorized bandwidth is 2.8 kHz." By the way, in 1995 the FCC clarified that "specified digital code" is any digital code that has its technical characteristics publicly documented. All of us who reviewed the draft and missed this are deeply sorry for the confusion thus caused. 73, Dave K1ZZ _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> http://reflector.arrl.org/mailman/listinfo/arrl-odv

Chris, Dave and Kay, thanks for your fast replies. I asked only because I have been fielding calls from members of a large D-Star group here expressing concern about the possible effect of our petition on them. By no means do I wish to hold up the filing, and I am relieved that there is no cause for concern as to digital voice. 73, and Happy Thanksgiving to all. Marty N6VI _____ From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Kay Craigie Sent: Tuesday, November 26, 2013 11:52 AM To: arrl-odv@arrl.org Subject: [arrl-odv:22112] Re: RM-11708 erratum While I appreciate your abundance of care, Marty, I believe we need to get this known problem fixed by filing the erratum without delay. 73 - Kay N3KN

TNX Chris! There is a lot of complaining down here from RTTY and PSK DXers claiming the 2.8 Kc bandwidth is too wide and will destroy weak signal narrow band work. AA5AU made some very good and cogent points to me in an email late last week which I have shared with you and the PSC. They are also concerned about Winlink/automatic PACTOR stations causing significant interference with traditional users. What are your thoughts on this as a potential problem, and if so, do you or Brennan have any possible solutions? 73 David A. Norris, K5UZ Director, Delta Division ARRL - The National Association for Amateur Radio © -----Original Message----- From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Tuesday, November 26, 2013 3:09 PM To: dsumner@arrl.org; arrl-odv@arrl.org Subject: [arrl-odv:22114] Re: RM-11708 erratum Here is the Erratum that I just filed with FCC a few minutes ago. This addresses those concerns related to the allegation that the symbol rate petition would permit unspecified digital codes at HF, which the Symbol Rate Committee did not intend to do, but the error crept into the final report. 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. This petition, if granted, would not allow digital voice where voice is not now permitted by the rules. Furthermore, where data is now permitted by the rules, there is no maximum bandwidth. ARRL proposes one in the Petition. So we are not compromising the RTTY operations by this proposal. In fact, the Petition would insure for the first time that data communications in the same subbands do NOT usurp the limited spectrum available. Brennan Price has provided Dan Henderson with some "talking points" that will hopefully clarify this for people who inquire. If it would be helpful in dealing with member inquiries, a version of this could be provided to you as well. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ, K1ZZ <dsumner@arrl.org> To: arrl-odv <arrl-odv@arrl.org> Sent: Tue, Nov 26, 2013 12:54 pm Subject: [arrl-odv:22106] RM-11708 erratum In one respect the criticism being voiced about our RM-11708 petition has some merit. This is with regard to the addition of "unspecified digital codes" language to 97.307(f)(3). This change is not discussed at all in the body of the petition and was not intended to be included in the proposal. Chris is filing an erratum with a corrected appendix later today. The revised proposed 97.307(f)(3) will read: "Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The authorized bandwidth is 2.8 kHz." By the way, in 1995 the FCC clarified that "specified digital code" is any digital code that has its technical characteristics publicly documented. All of us who reviewed the draft and missed this are deeply sorry for the confusion thus caused. 73, Dave K1ZZ _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv

Greg and ODV, I've asked a few folks to review the document, and I will circulate as soon as the review is complete. It shouldn't take long, but what I circulate absolutely needs to be right. 73 de Brennan HB9/N4QX Sent from my Verizon Wireless BlackBerry -----Original Message----- From: G Widin <gpwidin@comcast.net> Sender: <arrl-odv-bounces@reflector.arrl.org> Date: Tue, 26 Nov 2013 21:40:16 To: Chris Imlay<w3kd@aol.com> Cc: arrl-odv<arrl-odv@arrl.org> Subject: [arrl-odv:22116] Re: RM-11708 erratum _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv

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.

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

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