Fwd: ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions

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WB9QZB

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Nov 17, 2023, 1:51:55 AM11/17/23
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SB QST @ ARL $ARLB031
ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions

ZCZC AG31
QST de W1AW 
ARRL Bulletin 31  ARLB031
From ARRL Headquarters 
Newington CT  November 14, 2023
To all radio amateurs

SB QST ARL ARLB031
ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions

The FCC Commissioners unanimously voted to amend the Amateur Radio
Service rules to replace the baud rate limit on the Amateur HF bands
with a 2.8 kHz bandwidth limit to permit greater flexibility in data
communications.

"The Federal Communications Commission today adopted new rules to
incentivize innovation and experimentation in the amateur radio
bands by removing outdated restrictions and providing licensees with
the flexibility to use modern digital emissions," announced FCC.

The announcement can be found online at,

The new rules can be found online at,

"Specifically, we remove limitations on the symbol rate (also known
as baud rate) -- the rate at which the carrier waveform amplitude,
frequency, and/or phase is varied to transmit information --
applicable to data emissions in certain amateur bands," concluded
the FCC Report and Order and Further Notice of Proposed Rulemaking,
adopted November 13, 2023. "The amateur radio community can play a
vital role in emergency response communications but is often
unnecessarily hindered by the baud rate limitations in the rules."

Consistent with ARRL's request, the amended rules will replace the
current HF restrictions with a 2.8 kHz bandwidth limit. "We agree
with ARRL that a 2.8 kilohertz bandwidth limitation will allow for
additional emissions currently prohibited under the baud rate
limitations while providing sufficient protections in the shared
RTTY/data subbands," concluded the FCC Report and Order.

ARRL President Rick Roderick, K5UR, hailed the FCC's action to
remove the symbol rate restrictions. Roderick stated that "this
action will measurably facilitate the public service communications
that amateurs step up to provide, especially at times of natural
disasters and other emergencies such as during the hurricane season.
Digital technology continues to evolve, and removing the outmoded
data restrictions restores the incentive for radio amateurs to
continue to experiment and develop more spectrum-efficient protocols
and methods while the 2.8 kHz bandwidth limit will help protect the
shared nature of our bands. We thank Congresswoman [Debbie] Lesko
(AZ-08) for her efforts on behalf of all Amateurs to get these
restrictions removed."

In a Further Notice of Proposed Rulemaking (FNPRM), the FCC proposes
to eliminate similar restrictions where they apply in other bands.
"We propose to remove the baud rate limitation in the 2200 meter
band and 630 meter band - and in the very high frequency (VHF) bands
and the ultra-high frequency (UHF) bands.

"Additionally, we seek comment on the appropriate bandwidth
limitation for the 2200 meter band, the 630 meter band, and the
VHF/UHF bands."

ARRL has previously expressed its support for eliminating the symbol
rate limits in favor of bandwidth limits where they apply on the VHF
and UHF bands but suggested that the bandwidth limits themselves be
reviewed in light of today's technology and tomorrow's
possibilities. Similarly, when eliminating the baud limits on the
2200 and 630-meter bands, consideration should be given to what, if
any, bandwidth limits are appropriate.

The FCC will announce a period for public comment on the additional
proposed changes based upon publication of the FNPRM in the Federal
Register.
NNNN
/EX

Takehiko Tsutsumi

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Nov 28, 2023, 9:36:25 PM11/28/23
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Hi WB9QZB,

Thank you for forwarding ARRL information.

I picked up my interested points and write my understanding in the information of FCC R&D comparing JA regulation environments. If you provide me your comments, I appreciate.

1. 30m Emission types of authorized are “RTTY, data” in the “Entire Band”. This means FCC will maintain the policy to eliminate “Phone” in the band.

2. 60m Emission types of authorized are “Phone, RTTY, data” in the five channels in the band. This means FCC also maintain the policy to include “Phone” in the band.

3. I can not see the break down of "data" emission type in 30m in the  R&D but I can see the emission type of “data” as 2K80J2D in referred $97.307 “60M Band Emission Requirements” This means 30m and other “data” in HF is “2K802J2D”. Therefore, “2K80J2D” applys to FreeDV as emission type.

My notes of JA regulation environments of above items are:

1. “data” is allowed between 10.120-10.150MHz. eliminating 10.100-10.120 as for CW only.

2. We are expecting to be allocated WRC-15 recommended band on 60m. However, there is no allocation of 60m band at this moment.

3. There is no specific “radio type” authorized to “data” such as “2K802J2D” but there is “2kHz” maximum OBW rule on 30m band and else bands in HF are "3kHz" OBW limitation. this implicitly eliminate “Phone” usage in 30m. OBW definition is 99% energy rule.

I am waiting your response soon.

Regards,

take

de JA5AEA

2023年11月17日金曜日 15:51:55 UTC+9 WB9QZB:

Mooneer Salem

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Nov 29, 2023, 4:05:37 PM11/29/23
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Hi Take,

Emissions designators seem to be based on the content of the data as well as the modulation. The ARRL, for example, mentioned in a 2000 issue of QEX that digital voice was "J2E". Of course, arguments have been made for and against this interpretation over the years, so there's not much point in repeating them here (though IMO, the distinctions really should go away in favor of solely regulating by bandwidth, even if that means a smaller maximum bandwidth is imposed on the current "data" segments to effectively guarantee the same usage of the bands as today).

Getting back to the recent FCC order, though--as mentioned previously, this ultimately doesn't change much for FreeDV given that it is considered a "phone" mode and not a "data" mode.

Thanks,

-Mooneer K6AQ

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Takehiko Tsutsumi

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Nov 29, 2023, 8:12:17 PM11/29/23
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 Mooner,

Thank you for responding my inquiry.

Here is my advice based on my entire carrier , as a communication engineer, we had better not to stick to "three letters" classification defined at ITU at around 1960s when neither "Internet digitalized multimedia" nor "solid state technology" concepts did not exist. In Japan, we share the side-effects of this classification among us practically for FreeDV example and successfully eliminated it from radio amateur service regulations.

In my previous memo, I questioned whether FreeDV is "J2D" and you responded it was "J2E" in a 2000 issue of QEX". Then, what is your response if I say that FreeDV should be either "J2E" and "J2D" as it has text message field included or simply "J2D" as voice is digitized? I understand the arguments are endless and it is fine to argue as long as we secure the regulators do not specify it.

So, my interest and confirmation is FCC will maintain the policy to eliminate “analogue SSB”and eventtually allow FreeDV in 30m band by saying "30m Emission types of authorized are “RTTY, data” in the “Entire Band” in this R&D. Am I correct?

Regards,

take

de JA5AEA


2023年11月30日木曜日 6:05:37 UTC+9 Mooneer Salem:

Rick, WA6III

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Nov 30, 2023, 2:25:04 AM11/30/23
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This is where maybe the emission designation of 1K20J2E is likely not exactly correct for FreeDV since there actually is other "data" contained in the transmission.



From https://fccid.io/Emissions-Designator/   description below:

An emissions designator is a 6 to 8 character code identifying the electromagnetic modulation characteristics of a wireless device. Different codes represent different features of the wireless emissions from a product. Emission Designators are used by many governments including the FCC and ACMA.
Legacy Emission Designators Legacy emission designators (pre 1998) may contain only 3 characters. Legacy designators are missing the first 4 characters as well as the last character compared with modernized designators. The search above may be used for modern and legacy emissions designators.Modern Emission Designators Necessary Bandwidth The first four characters of a modern emissions designator indicate the necessary bandwidth. Bandwidth is abbreviated to include Hertz, Kilohertz, Megahertz, or Gigahertz. Examples of this abbreviation are provided below.
  • 400 Hz = 400H
  • 2.4 kHz = 2K40
  • 12.5 kHz = 12K5
  • 6 MHz = 6M00
Modulation Types The 5th character in a modern emissions designator is the modulation type. This will be the first character of a 3 character legacy emissions designator. Modulation types include amplitude modulation, angle-modulated, pulse modulation, and combinations thereof. Modulation types not included in those categories are marked with X as the 5th category.Nature of modulating signal The 6th character of the emission designator (2nd character in legacy designators) signifies what type of data is being transmitted. Identified data transmission types are below:
  • N - None
  • A - Aural telegraphy, for people (Morse code)
  • B - Telegraphy for machine copy (RTTY, fast Morse)
  • C - Analog fax
  • D - Data, telemetry, telecommand
  • E - Telephony, voice, sound broadcasting
  • F - Video, television
  • W - Combinations of the above
  • X - All cases not covered above
////

Since FreeDV is not ONLY "Telephony, voice, sound broadcasting" but literally "combinations of the above" (even though it's only a combination of 2)

One could then argue that the emission designator should  be :


1K20J2W--
Bandwidth: 1.20 kHz
Modulation Type: [J] AM, single sideband, suppressed carrier
Modulation Nature: [2] Digital, with modulation
Information Type: [W] Multiple Formats of Data Transmitted


This information could be used to offer an argument that FreeDV *could*  (or maybe should) be used outside of the current analog "PHONE" bands

73/Rick
WA6III (soon to be W7MYR) !

Mooneer Salem

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Nov 30, 2023, 2:50:41 AM11/30/23
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Hi Rick,

I'm not sure if the very low bit rate data stream (used to enable reporting functionality and on the order of maybe 1-2 *bytes* per second) rises to the level of needing to be counted. Note that the current rules (https://www.ecfr.gov/current/title-47/part-97#p-97.3(c)) don't have any provision for 'W' for either phone or data, which lends credence IMO to the predominant content of the signal being what counts. 

Additionally, Icom themselves consider D-Star F7W per their own spec sheets and user manuals, yet make no effort to lock out the mode on HF for their US model radios that support it. You may not be able to use its additional data channel at the same time as the voice channel while on HF, though (I've never tried to know for sure), and if that's the case, it'd likely be more like F7E when on HF (and thus legal).

(See, this is why emissions designators should go away.)

Thanks,

-Mooneer K6AQ

Mooneer Salem

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Nov 30, 2023, 2:54:01 AM11/30/23
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Hi Take,

Take a look at my response to Rick's comment, but in short, FreeDV is likely still considered a phone mode simply due to the fact that a voice signal of some sort is going out. It might be encoded as a digital data stream, but it's being decoded at the other end as an analog voice signal in the end. That means no for 30 meter FreeDV for Americans barring any other rule changes (which I don't think will happen any time soon). Of course, YMMV in other countries.

Thanks,

-Mooneer K6AQ

Takehiko Tsutsumi

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Nov 30, 2023, 4:25:58 AM11/30/23
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Hi Mooneer,

I was surprised to hear your interpretation that FreeDV would not allow to access to 30m band.

I suggest you will contact FCC and make sure they have (un-fair) policy in this R&D and I hope they will simply respond “No”.

Regards,

take

de JA5AEA


2023年11月30日木曜日 16:54:01 UTC+9 Mooneer Salem:

G D

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Nov 30, 2023, 6:28:16 AM11/30/23
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I still don't understand why people continue to believe just because something is not analog audio it should be or could be used in data bands.  There are many "voice " mode that contain some for of data as well, that does not make it a free for all to just go anywhere..  I just don't understand the thought processes many use.  I will say the band segments need to be re-examined and changed to suit current times.  
R/ Glenn

Rick, WA6III

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Nov 30, 2023, 1:18:48 PM11/30/23
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Glenn, digital audio is still digital "DATA".  Back when those segments were set up, The only "digital" signals were CW and RTTY.  The emission designators have evolved to  include combinations of digitally encoded image, audio and other data (hence the "W" designator)

The "information" contained in a digital signal doesn't (or shouldn't) matter.  It's a digital signal.  Hence it should be allowed in a "digital" segment.  

It's "1940's" thinking being used to argue against it (very common at ARRL)
This is why I would suggest that the FCC be inundated with letters requesting STA's  to do just that,  to "experiment" using ALL digital signals in the "digital" segments.

Eventually they would become weary of issuing STAs and propose a separate segment for either digital data/image/voice modes or just propose allowing (encoded voice audio and other)  digital modes in the current digital segments.

Mooneer,

The  (low-rate) bit stream is still a separate digital part of the whole signal.  So I really think the "W" designation allows for it.  The rules are still written by lawyers so it will likely take a lawyer to get through this.  

I see the the change to bandwidth vs "mode" as a "First Step"  

It's quite clear that it did not allow for any real change that could be construed to allow DV, image or any other similar mode to be used in current "data" segments.  

It did however seem to  "open the door" for  an STA could be allowed to permit narrow-band digital audio (or combination audio/data etc)  in the current digital segments.

73/Rick

Tony Langdon

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Nov 30, 2023, 4:13:51 PM11/30/23
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I'm not surprised by this, because the primary purpose of FreeDV is
voice communication and the intelligence carried is speech, so the E
does make sense.

However, I don't believe J2 is correct, because the modulation is
actually done at in the PC (or SM1000 or other device) at audio
frequencies. The SSB transmitter is conceptually nothing more than an
image reject mixer, raising the emission centre frequency from AF to the
desired RF frequency.

To follow the "J2 logic" to the ultimate absurdity, should we label any
transmission made using a transverter as "J2"? Looks similar - mixer
followed by a filter to remove the unwanted sideband from the mixing
process.
> to *eliminate “analogue SSB”and eventtually allow FreeDV** *in
> <https://groups.google.com/d/msgid/digitalvoice/b13ff0ed-658f-4ba8-a694-1f6bf776876cn%40googlegroups.com?utm_medium=email&utm_source=footer>.
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Tony Langdon

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Nov 30, 2023, 4:21:03 PM11/30/23
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Australia is definitely the "lucky country" here, as we've been allowed
to use SSB phone for many years on 30m, so FreeDV is definitely not an
issue here. Only hard part is working out where to run it, given space
is tight, especially with the proliferation of digital data modes, each
on their own internationally coordinated centre frequency.
> *eliminate “analogue SSB”and eventtually allow FreeDV** *in 30m band
> <https://groups.google.com/d/msgid/digitalvoice/b13ff0ed-658f-4ba8-a694-1f6bf776876cn%40googlegroups.com?utm_medium=email&utm_source=footer>.
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Rick, WA6III

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Nov 30, 2023, 5:03:31 PM11/30/23
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On Thursday, November 30, 2023 at 1:13:51 PM UTC-8 Tony Langdon wrote:
I'm not surprised by this, because the primary purpose of FreeDV is
voice communication and the intelligence carried is speech, so the E
does make sense.

r>.


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http://vkradio.com



While I might be inclined to agree,  if the emission designator choice(s)  were "weighted"   I.E. 51% or more of the information transmitted is "Voice" then the designation would be "E - Telephony, voice, sound broadcasting" , regardless of the other info transmitted......It doesn't appear they're specifying that.

Even if it's 50%, voice and 50% Data .......or 10%voice & 90% data  it makes no difference in the designation.

100% "Telephony, voice, sound broadcasting" IS designated "E"

100% "Data, telemetry, telecommand" IS designated "D"

100%  Telegraphy for machine copy (RTTY, fast Morse) IS designated "B"

ETC

Combinations,  however small,  of each component is designated "W"

Therefore, there's a valid argument to designate FreeDV as "W" 

1K20J2W--
Bandwidth: 1.20 kHz
Modulation Type: [J] AM, single sideband, suppressed carrier
Modulation Nature: [2] Digital, with modulation
Information Type: [W] Multiple Formats of Data Transmitted


"Multiple"  appears to  mean 2 or more (they don't specify exactly what they mean by multiple)

The only limitation then,  would be to not exceed  2.8kHz band width.

2K80J2W

And additionally, it's an even better argument to replace band segment restrictions based on mode (emission designation) with band segment restrictions based on width.

It would appear that we're "almost there"!

And additionally , everyone (world-wide)  should be able to use suppressed carrier single sideband AM on 30m (one battle at a time!)

Cheers,

Rick

Mooneer Salem

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Nov 30, 2023, 5:57:54 PM11/30/23
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Hi Rick,

If the reporting data in FreeDV were truly considered a separate data channel, why wouldn't it be something like J7W instead? After all, the '7' means "two or more digital channels" and lines up with Icom's emissions designator for D-Star (one digital voice channel and one data channel).

Anyway, another example we can look at is NXDN. It provides two channels in a 6.25 or 12.5 KHz span of bandwidth, and those channels can be divided as voice/voice, voice/data or data/data. If Wikipedia is to be believed (https://en.wikipedia.org/wiki/NXDN), only the voice/data split results in a 'W' at the end of the emissions designator. Presumably there's some data that goes out over the voice channel as well (i.e. information about the caller), but that doesn't seem to count for the purpose of whether to use 'D', 'E' or 'W' at the end. Thus, while I'm not a lawyer (and could still be very much wrong), I'm pretty sure FreeDV uses 'E' for the final letter.

Thanks,

-Mooneer K6AQ

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Rick, WA6III

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Nov 30, 2023, 6:47:10 PM11/30/23
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On Thursday, November 30, 2023 at 2:57:54 PM UTC-8 Mooneer Salem wrote:
Hi Rick,

If the reporting data in FreeDV were truly considered a separate data channel, why wouldn't it be something like J7W instead? After all, the '7' means "two or more digital channels" and lines up with Icom's emissions designator for D-Star (one digital voice channel and one data channel).




Mooneer,

  I think you absolutely could make that argument!


Emissions Designator 1K20J7W

1K20J7W--Bandwidth: 1.20 kHz Modulation 
Type: [J] AM, single sideband, suppressed carrier Modulation 
Nature: [7] Two or more digital channels Information 
Type: [W] Multiple Formats of Data Transmitted Emissions Designator Lookup

The Emissions Designator 1K20J7W signifies a wireless radio which transfers data over a modulated wave using Two or more digital channels signal. This signal transmits at a 1.20 kHz [1K20] maximum bandwidth . bandwidth does not indicate frequency of the signal. Emissions Designators describe the type of signal only.


Again, the designator doesn't seem to specify the "weight" of each "channel"  Neither dominates, hence the "W" Type.

There could be 5% in the "data" channel and 95% in the "voice-data" channel but there's still "Two or more digital channels of information"

So what if there's encoded audio in one of the channels?  Both are still digital.

(IANAL either!!)




Cheers,

Rick

G D

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Nov 30, 2023, 7:38:58 PM11/30/23
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It is VOICE no matter how the voice is transferred.   With just saying anything digital should be in digital portion of band the I say remove all segments and anything anywhere..  That is how I see putting a digital format of voice in the digital portion of the band.  

Rick, WA6III

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Nov 30, 2023, 8:31:51 PM11/30/23
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Well,

I think we're probably going to disagree here.   

It seems to me that If the final transmitted signal is a digital signal, It matters not what was encoded into the digital signal..... Image, voice, music, dots and dashes, ones and zeros or a mixture and combination of all of the above.... (ARQ/FEC or none at all)

But none of this really matters.

With the current new specifications requiring "digital" signals to be 2.8kHz wide or less, it opens a "channel" (pun intended!) for suggesting Digital segments to include all digital signals. What possible difference would it make if the modulating "signal" starts out as audio before going through an A-D convertor?  Sure.  It's voice audio.  But the transmitted signal is digital.... and if it carries other "digital information" channels in any capacity, it furthers the argument.

And yes, it *should/could* bolster the argument that band segments should be adjusted/designed with bandwidth in mind with no regard to actual mode.  It just happens that most low rate digital modes are very narrow by design (  As is FreeDV  )

I view the 2.8kHz digital BW limitation as an invitation to suggest allowing ANY digital mode in digital "segments" that meets the 2.8kHz (or less) requirement.  

But I think one has to first convince the "powers that be" that a digital voice mode is still a "digital" mode.

Ed Marciniak

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Nov 30, 2023, 8:32:43 PM11/30/23
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Imagine for a moment that you used a single sideband suppressed carrier transmitter fed an audio passband signal that was actually an FSK signal. Now compare that to a directly generated (via FM) FSK signal. The resultant spectrum could be received via either an SSB or FM receiver, but someone might be wondering why there’s a fixed (suppressed carrier) below or above the actual data.

With frequency offsets of KHz, clearly the potential is there for something to leak past filters. With a signal run through a transverter, the image or LO frequencies are likely both out of band, well filtered, and not amplified. 

From: digita...@googlegroups.com <digita...@googlegroups.com> on behalf of Tony Langdon <vk3...@gmail.com>
Sent: Thursday, November 30, 2023 3:11:33 PM
To: digita...@googlegroups.com <digita...@googlegroups.com>
Subject: Re: [digitalvoice] Re: ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions
 

Tony Langdon

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Nov 30, 2023, 9:35:51 PM11/30/23
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Again, why J??? No one has satisfactorily explained that. The only use
case for J is analog SSB.

As I said before, if you are giving these modes a J designator for the
modulation, you need to do the same for anyone using a transmitting
converter.

On 1/12/23 10:47 am, Rick, WA6III wrote:
>
>
> On Thursday, November 30, 2023 at 2:57:54 PM UTC-8 Mooneer Salem wrote:
>
> Hi Rick,
>
> If the reporting data in FreeDV were truly considered a separate
> data channel, why wouldn't it be something like J7W instead? After
> all, the '7' means "two or more digital channels" and lines up with
> Icom's emissions designator for D-Star (one digital voice channel
> and one data channel).
>
>
>
>
> Mooneer,
>
>   I think you absolutely could make that argument!
>
> https://fccid.io/Emissions-Designator/1K20J7W
>
> */Emissions Designator 1K20J7W
> /*
>
> 1K20J7W--/*Bandwidth: 1.20 kHzModulation */
> /*Type: [J] AM, single sideband, suppressed carrierModulation */
> /*Nature: [7] Two or more digital channels Information */
> /*Type: [W] Multiple Formats of Data Transmitted _Emissions Designator
> Lookup <https://fccid.io/Emissions-Designator/>_*/
>
> /*The Emissions Designator 1K20J7W signifies a wireless radio which
> transfers data over a modulated wave using Two or more digital channels
> signal. This signal transmits at a 1.20 kHz [1K20] maximum bandwidth .
> bandwidth does not indicate frequency of the signal. Emissions
> Designators describe the type of signal only.*/
>
>
> Again, the designator doesn't seem to specify the "weight" of each
> "channel"  Neither dominates, hence the "W" Type.
>
> There could be 5% in the "data" channel and 95% in the "voice-data"
> channel but there's still "Two or more digital channels of information"
>
> So what if there's encoded audio in one of the channels?  Both are still
> digital.
>
> (IANAL either!!)
>
>
>
>
> Cheers,
>
> Rick
>
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> https://groups.google.com/d/msgid/digitalvoice/a0c841db-719c-4529-9718-139f6c2a6723n%40googlegroups.com
> <https://groups.google.com/d/msgid/digitalvoice/a0c841db-719c-4529-9718-139f6c2a6723n%40googlegroups.com?utm_medium=email&utm_source=footer>.

Tony Langdon

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Nov 30, 2023, 9:46:12 PM11/30/23
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If it's a suppressed carrier, then it's not (effectively) on air, if it
is detectable outside a local area, it's technically a spurious emission.

These days, Morse is generally regarded as A1A, however, I do know
there's radios that key an audio tome into a SSB transmitter (e.g. FT-7).


n 1/12/23 12:32 pm, Ed Marciniak wrote:
> Imagine for a moment that you used a single sideband suppressed carrier
> transmitter fed an audio passband signal that was actually an FSK
> signal. Now compare that to a directly generated (via FM) FSK signal.
> The resultant spectrum could be received via either an SSB or FM
> receiver, but someone might be wondering why there’s a fixed (suppressed
> carrier) below or above the actual data.
>
> With frequency offsets of KHz, clearly the potential is there for
> something to leak past filters. With a signal run through a transverter,
> the image or LO frequencies are likely both out of band, well filtered,
> and not amplified. 
> ------------------------------------------------------------------------
> *From:* digita...@googlegroups.com <digita...@googlegroups.com> on
> behalf of Tony Langdon <vk3...@gmail.com>
> *Sent:* Thursday, November 30, 2023 3:11:33 PM
> *To:* digita...@googlegroups.com <digita...@googlegroups.com>
> *Subject:* Re: [digitalvoice] Re: ARLB031 ARRL Hails FCC Action to
> https://groups.google.com/d/msgid/digitalvoice/BL3P221MB0321ED7AEDD0E08BE122BEFDFD81A%40BL3P221MB0321.NAMP221.PROD.OUTLOOK.COM
> <https://groups.google.com/d/msgid/digitalvoice/BL3P221MB0321ED7AEDD0E08BE122BEFDFD81A%40BL3P221MB0321.NAMP221.PROD.OUTLOOK.COM?utm_medium=email&utm_source=footer>.

Mooneer Salem

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Nov 30, 2023, 10:31:12 PM11/30/23
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Hi Tony,

Per the ARRL (sidebar on page 2 of https://www.arrl.org/files/file/Technology/tis/info/pdf/0056x003.pdf), the fact that the modulated audio goes through a SSB transceiver to go out over the air is what makes the emissions designator begin with 'J':

The first symbol of the emission symbol depends upon the modulation of the
main carrier. Typically, the output of the digital-voice modem would be fed into
a single-sideband, suppressed-carrier (SSB-SC) transmitter, in which case the
first symbol would be “J.” (If the main carrier of the transmitter is modulated in
some other way than SSB-SC, then choose from the permissible ones: A, C,
D, F, H or R, which are explained in §2.201 in Part 2 of the Rules, readily available in The ARRL’s FCC Rule Book.)

(In fact, a lot of "data" modes begin with 'J' as well, probably for this reason. For example, PSK31 is J2B per https://www.arrl.org/psk31-spec.)

On the other hand, that article was written before the advent of modes like FT8 and definitely before FreeDV became a thing. This mailing list post, for instance, claims that FT8 is F1B despite typically being transmitted through a radio's audio interface. Plus, one can argue that FreeDV may actually be something like D1E or D2E instead (based on OFDM modes listed at https://apps.fcc.gov/els/GetAtt.html?id=325649&x=. beginning with 'D'). Fortunately, the FCC's current definition of "phone" seems to be pretty flexible as to what American hams can use; we just need to agree on *something*.

*insert comment reiterating how emissions designators should go away*

Thanks,

-Mooneer K6AQ

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Tony Langdon

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Nov 30, 2023, 10:48:37 PM11/30/23
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But in my book, the "main carrier" is generated and modulated (using DSP
techniques) at audio frequencies then upconverted externally.
Technically one could argue it's not audio, but IF that gets fed to the
SSB transceiver.

n 1/12/23 2:30 pm, Mooneer Salem wrote:
> Hi Tony,
>
> Per the ARRL (sidebar on page 2 of
> https://www.arrl.org/files/file/Technology/tis/info/pdf/0056x003.pdf),
> the fact that the modulated audio goes through a SSB transceiver to go
> out over the air is what makes the emissions designator begin with 'J':
>
> The first symbol of the emission symbol depends upon the modulation of the
> main carrier. Typically, the output of the digital-voice modem would be
> fed into
> a single-sideband, suppressed-carrier (SSB-SC) transmitter, in which
> case the
> first symbol would be “J.” (If the main carrier of the transmitter is
> modulated in
> some other way than SSB-SC, then choose from the permissible ones: A, C,
> D, F, H or R, which are explained in §2.201 in Part 2 of the Rules,
> readily available in The ARRL’s FCC Rule Book.)
>
> (In fact, a lot of "data" modes begin with 'J' as well, probably for
> this reason. For example, PSK31 is J2B per https://www.arrl.org/psk31-spec.)
>
> On the other hand, that article was written before the advent of modes
> like FT8 and definitely before FreeDV became a thing. This mailing list
> post
> <https://sourceforge.net/p/wsjt/mailman/wsjt-devel/thread/BL0PR06MB5060FAE5EE...@BL0PR06MB5060.namprd06.prod.outlook.com/>,
> <mailto:digitalvoice%2Bunsu...@googlegroups.com>
> > <mailto:digitalvoice...@googlegroups.com
> <mailto:digitalvoice%2Bunsu...@googlegroups.com>>.
> > To view this discussion on the web visit
> >
> https://groups.google.com/d/msgid/digitalvoice/a0c841db-719c-4529-9718-139f6c2a6723n%40googlegroups.com
> >
> <https://groups.google.com/d/msgid/digitalvoice/a0c841db-719c-4529-9718-139f6c2a6723n%40googlegroups.com?utm_medium=email&utm_source=footer>.
>
>
> --
> 73 de Tony VK3JED/VK3IRL
> http://vkradio.com
>
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> <https://groups.google.com/d/msgid/digitalvoice/CAAzDfxPTqmEwWsdW%3DwZo5O4ukMxExeVF9t7zOhaKq4_cC4HArw%40mail.gmail.com?utm_medium=email&utm_source=footer>.

Takehiko Tsutsumi

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Nov 30, 2023, 11:13:52 PM11/30/23
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Hi Glenn,

If you have a U.S. citizenship, would you kindly contact FCC and ask their (unfair) public policy on 30m and 60m bands from your perspectives?

I do not have any intention to suggest FCC to exactly follow the following example but it might be useful to let’s them know the fact that a national regulator, who has one of the largest radio amateur population, recently simplified their “bandplan” discussion eliminating traditional requirement of “ITU “three letters” except “A1A” maintaing CW privilege from their license approval system. This provides fairness and technology development incentives especially for FreeDV camp to be able to access both narrow band data (privileged for WSJT-X) and any modes segment (largest allocated segment) depending on designed OBW.  For example, Devid Bowe may be re-motivated to complete his super low bit codes 2 design, if he knows his new baby has the opportunity to access WSJT-X segment as well. if somebody re-invent analog phone to fit narrow OBW requirement such as 30m and 60m depending on regional congestion, the largest SSB conservatives will be happy too.

Regards,

take

de JA5AEA

2023年12月1日金曜日 12:48:37 UTC+9 Tony Langdon:

jdow

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Dec 1, 2023, 3:55:37 AM12/1/23
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Hokay. I have several SDRs. A subset of them can transmit signals. I can write SDR transmit software that takes in digital audio and directly generates a digitally modulated signal say on 14.222 MHz. Where is the SSB transmitter in this picture? Is the signal magically SSB anyway because .... why? This is magical thinking not technical thinking.

That said, there is, perhaps, a point to separate speakers and listeners from typists and readers. I'll listen to arguments that are free of magical thinking that this is a pertinent point rather than a triviality. The ARRL has some good heads that seem to be utterly incapable of communicating to others in a logical fashion.

I still not they are not regulating how often I can change my transmitting/receiving frequency. I figure 8000 times per second might be quite interesting. (Those were fun days in the early 70s.)

{^_^}   Joanne/W6MKU

G D

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Dec 1, 2023, 6:00:00 AM12/1/23
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The issue is that part of the band is DATA not DIGITAL.  That is where the issue is.  Many cannot get passed the form of the transmission when what is being sent is the purpose of the band plans.

But yup..  we will just have to agree to disagree.

73
Glenn

Rick, W4XA (formerly WA6III)

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Dec 1, 2023, 5:33:42 PM12/1/23
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On Friday, December 1, 2023 at 3:00:00 AM UTC-8 G D wrote:
The issue is that part of the band is DATA not DIGITAL.  That is where the issue is.  Many cannot get passed the form of the transmission when what is being sent is the purpose of the band plans.

But yup..  we will just have to agree to disagree.

73
Glenn



You're right.  It is where the "Issue" is!

It will require a paradigm shift.  Analog segments for Analog voice ....AM, FM, PM and variations (full carrier DSB, reduced carrier DSB, suppressed carrier SSB,  ETC

And if the future requires segments at all, segments for CW, RTTY, DATA, digital and other narrow band modes.

I just don't think  mixing any "digital" mode with analog voice modes as being a very good idea.

73/Rick

Takehiko Tsutsumi

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Dec 1, 2023, 8:53:38 PM12/1/23
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Glenn,

If FCC responded they concern the point you said as "The issue is that part of the band is DATA not DIGITAL", then we simply tell them we have changed the Free"DV" abbreviation from "DIGITAL VOICE" to "DATA VOICE". I am fine if FreeDV can access both 30m and 60m bands. By the way, this is the same approach of Japan i.e. "simplified their “bandplan” discussion eliminating traditional requirement of “ITU “three letters” except “A1A” maintaing CW privilege from their license approval system.". 

73

Regards,

take

de JA5AEA
2023年12月2日土曜日 7:33:42 UTC+9 Rick, W4XA (formerly WA6III):

jdow

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Dec 2, 2023, 2:01:49 AM12/2/23
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Then look up the FCC definition of data. Out of curiosity, what is that definition. Perhaps we should all become familiar with terms we use which may have FCC definitions that are quite different from the street definitions. In computer vernacular, if you dig deep enough into it, "data" is sets of data bits that are to be processed giving output that is one or more sets of data bits. I bet the FCC says otherwise. If not we get to define it as we wish. "DATA" is clearly, to most people, inclusive of text, voice, video, sensor readings, and so forth. It's all sets of ones and zeros.

At least get on the same page as the FCC when picking nits with them.

{^_^}   Joanne/W6MKU

Mooneer Salem

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Dec 2, 2023, 2:42:02 AM12/2/23
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Yeah, data/CW/etc. are defined in terms of emissions designators, just like with phone (https://www.ecfr.gov/current/title-47/part-97#p-97.3(c)(2)). Given how commonly used data modes are defined today (i.e. "F1B" for FT8 or "J2B" for PSK31), you're likely going to have a fairly uphill climb to convince the FCC that a digital voice mode such as FreeDV is a data mode.

-Mooneer K6AQ

jdow

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Dec 2, 2023, 3:35:54 AM12/2/23
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In other words the FCC has gone jabberwocky. (Lewis Carroll.) Then they moved on to vanishing caterpillars with words meaning exactly what I intend them to mean. Some DATA is DATA and some DATA is something else. I hate lawyers and politicians. It takes their sort to come up with this kind of pure tripe. And in what way is DIGITAL distinguished from DATA? Well, technically DATA exists in analog and digital formats. So - WTELF DOES the FCC really mean when they throw out those redefinitions of well known words?

{+_+}   Joanne/W6MKU   Contemplating the FCC gives me a giant headache. That's why I have slid, again, into inactivity. Scroom. Scroom all.

Adrian Musceac

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Dec 2, 2023, 8:16:18 AM12/2/23
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On Saturday, 2 December 2023 09:41:44 EET Mooneer Salem wrote:
> a fairly uphill climb to
> convince the FCC that a digital *voice* mode such as FreeDV is a data mode.

Hi Mooner,

I always thought that what gets sent over the air is not voice, but pitch
estimations and linear prediction coefficients or similar stuff. So I think it's
clearly data.
On the other hand the RF aspect of it presents itself as an analog waveform,
which briefly becomes digital voice only inside the computer (because the
machine is imperfect). So it would make a lot more sense to categorize FreeDV
as *analog data* rather than *digital voice*.
On the other hand, CW could be considered digital voice by some other
criteria, since you could definitely send the same information as FreeDV over
CW if you keyed it sufficiently fast, no?

Adrian




Facility 406

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Dec 2, 2023, 3:29:17 PM12/2/23
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On 11/30/2023 16:38, G D wrote:
> It is VOICE no matter how the voice is transferred.

What if you came across a random digital signal, and didn't know it was
supposed to be voice? What would it be then?

Kurt



Facility 406

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Dec 2, 2023, 3:29:18 PM12/2/23
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> is the same approach of Japan i.e. "simplified their “bandplan”...

A "bandplan", is just that, a plan. It could be your plan, my plan, the
plan of complete lunatics, or a club that thinks it matters.

Check the CFR, Code Of Federal Regulations, Telecommunications, Title
47, Part 97, as THIS, and ONLY this, dictates what can be used, and
where, in the US and possessions, not a "plan".

Kurt

Pierre Martel

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Dec 2, 2023, 10:32:03 PM12/2/23
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I've been refraining from commenting on that subject because I am torn apart by the 2 situations.  Do we have a stream of data that transports some audio or do we have an audio stream converted to digital?
First we should start by stating what is digital and what is data. 
 Digital
adjectivedigital
  1. 1.
    (of signals or data) expressed as series of the digits 0 and 1, typically represented by values of a physical quantity such as voltage or magnetic polarization.
    • relating to, using, or storing data or information in the form of digital signals.
      "digital TV"
    • involving or relating to the use of computer technology.
      "the digital revolution"
  2. 2.
    (of a clock or watch) showing the time by means of displayed digits rather than hands or a pointer.
  3. 3.
    relating to a finger or fingers.

Data
noun
noundata
  1. facts and statistics collected together for reference or analysis.
    "there is very little data available"
    similar words :
    facts
    figures
    statistics
    details
    particulars
    specifics
    features
    information
    evidence
    intelligence
    material
    background
    input
    proof
    fuel
    ammunition
    statement
    report
    return
    dossier
    file
    documentation
    archive(s)
    info
    dope
    lowdown
    deets
    gen
    • the quantities, characters, or symbols on which operations are performed by a computer, being stored and transmitted in the form of electrical signals and recorded on magnetic, optical, or mechanical recording media.
    • PHILOSOPHY
      things known or assumed as facts, making the basis of reasoning or calculation.

The way I see this, data could be an analog or digital information. But it is information.

While Digital is the way to describe how something is expressed in. 

As in the definition Data is a noun and Digital is an adjective. So Digital Voice is Voice expressed digitally. 

And Data is information, data could be anything, a photo, an analog level, a value, a state, sound, music, text, voice. 

So, do we describe the voice by specifying it as digital, or do we name the information or data sent as being voice? 

Or do we do both? We send data, it is easy to see it, And that data can be anything as I understand it, it can be an analog information as voice, or a stream of data that can be digital video? See what I did here? 

So is the data the transporter or is it the transported? I see it as the transporter. 

Digital is an adjective, so it describe what? the state of the transporter or the state of the transported? I see it as the state of the transported.

And what if we always been doing both thing at the same time? We are sending a data stream of digital voice. Since the digitalisation is done outside of the hf spectrum, should we be saying that we send voice or data? But that data is still digitalise voice. We cannot get out of the loop we do BOTH. 

The only difference between on side and the other is the viewing angle of the problem, If we look as the transported information, we transport voice. if we look at how we transport the voice, it is as digital data.  

Now do the FCC specify voice as being an analog only mode? And when they specify data, do the FCC specify it as being absolutely non voice information? 

The answer is no to both question and yes to both. If taken as the point of view of the legislator when the law was written the answer is just YES, but technology came and broke the whole idea behind the law so it is now a big NO. voice can now be digital, and voice can be seen as data. 

Just my 2 cent. 

BTW I dont do FreeDV QSO for one reason. I just cannot receive them because of noise level around my place. If it would not be that, I would always be on it. I dont do analog voice either, the same reason. I do some data mod from time to time. like FT-8 but I do miss the voice part of the hobby.

Pierre
VE2PF

Takehiko Tsutsumi

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Dec 15, 2023, 1:10:39 PM12/15/23
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 Hi, I found the following definition of DV in all IARU Band plans.


DV: Digital Voice: Any mode based on digital encoded voice, restricted to the specified bandwidth and application of the segment. The non-voice digital embedded content must be an ancillary data, not the main purpose of the communication, except during emergency communications. Digital Voice users should first check if the channel is already in use by other stations and modes (including analog).


I believe the above definition will help us to have common understanding who we are. However, if the demand of “Listen Before Talk” practice is imposed only on DV, I oppose. In this case, I believe we should have multiple Center of Activity (CoA) channels to satisfy our traffics. Please confirm your CoA frequencies in each regions. They are different with our “Calling Frequency” list in FreeDV Reporter. and we need reconsider our list.


It looks like we are classified in to phone segment by the following clause.


R1 & R3:

Phone: Phone operation includes, SSB, DSB AM, FM and Digital Voice modes with similar bandwidth not exceeding 6 kHz. On 50 MHz and above, the maximum bandwidth not exceed 25 kHz


R2:

Single Sideband (SSB), Amplitude Modulation (AM) and Frequency Modulation (FM): These modes are cited on the band plan for analog phone communications only (not for Digital Modes or Digital Voice).


Again, we anticipate we are segregated from other phone or data service in the above sentence and we should make lobby activity to correct them.


Any comments?


Regards,


take


de JA5AEA



2023年12月3日日曜日 12:32:03 UTC+9 Pierre Martel:

Mooneer Salem

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Dec 15, 2023, 3:30:09 PM12/15/23
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Hi Take,

Based on the information you provided from IARU, it sounds like FreeDV activity is where it's supposed to be (generally the upper halves of each of the HF bands). One thing that would be good for R2 is to have appropriate frequencies assigned for DV in its band plan, though I don't think it'll 100% solve the problem of people transmitting over us.

Thanks,

-Mooneer K6AQ

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jdow

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Dec 15, 2023, 8:33:58 PM12/15/23
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Everybody who remembers the SSB / AM wars raise your left hands. SSB was tried and found successful in the ham marketplace. I  fear DV won't because it's not possible for the big radio manufacturers to include DV in their transceivers. They're not going to  go GPL any time soon. (as in Hell freezing over?)

(Donning my full on protective gear) May I suggest a shift to BSD, MIT, or Apache licenses?

{^_^}/    Joanne/W6MKU

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John D. Hays

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Dec 15, 2023, 8:46:53 PM12/15/23
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Icom includes D-STAR DV in some of their HF radios.  We need to work on manufactures implementing FreeDV



--
John D. Hays
Kingston, WA
K7VE / WRJT-215

 

Mooneer Salem

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Dec 15, 2023, 9:12:40 PM12/15/23
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Hi Joanne,

From what I understand of the LGPL, it shouldn't cause problems for the manufacturer (i.e. needing to release any source code) as long as they don't modify the FreeDV code. Even if they had to modify the Codec2 library for whatever reason, they'd only need to publish the stuff they changed.

Anyway, manufacturers will be more likely to include FreeDV if (a) it's documented well enough to easily be able to integrate it (in progress) and (b) if there's demand from their customers. For those of you who want to see it in actual radios, definitely reach out to your manufacturer of choice and let them know you want FreeDV support!

Thanks,

-Mooneer K6AQ

On Fri, Dec 15, 2023 at 5:33 PM jdow <jd...@earthlink.net> wrote:

Adrian Musceac

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Dec 16, 2023, 3:12:23 AM12/16/23
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On Saturday, 16 December 2023 03:33:52 EET jdow wrote:
> (Donning my full on protective gear) May I suggest a shift to BSD, MIT, or
> Apache licenses?
>

The problem with that is BigCo takes BSD code, adds their own improvements and
maybe some patented things on top, makes it closed source and because of their
market traction and mindshare you pretty soon have BestDV(TM) getting popular
instead of FreeDV, except now you don't have access to its source code
anymore, or need some proprietary operating system like Doors(TM) to run it.

I thought the whole point of FreeDV and Codec2 was to be be a free software
alternative that can actually be studied and understood by people, not to be
the most popular DV mode in town. Other than that, free software will always
have a very small user base and never be the hip thing in the town. Accept
that and things will make more sense.

Adrian



G D

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Dec 16, 2023, 7:32:01 AM12/16/23
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FreeDV was in the Flex Radio Option downloads but had not been available for a while as it is NOT fkex software, just a works with and a third party available software.   I did have the original version buy nobody used it.  That is an option for programmers to look into building again for those atleast 

Ed Marciniak

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Dec 16, 2023, 8:58:23 AM12/16/23
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Maybe we need a new type of license that permits someone to make improvements closed source, provided they provide a complete functional specification of necessary interfaces and protocols (and encoding methods) to permit interoperability.

If they spend money implementing a nice user interface that’s good enough that people will pay for it, yet they’re effectively required to not change say a codec and document their input/output bitstream…they always run the risk of too greedy that someone will just write a compatible (free) version.

From: digita...@googlegroups.com <digita...@googlegroups.com> on behalf of Adrian Musceac <kant...@droiddv.org>
Sent: Saturday, December 16, 2023 2:12:16 AM
To: digita...@googlegroups.com <digita...@googlegroups.com>
Subject: Re: [digitalvoice] Re: ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions
 
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wal...@k5wh.net

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Dec 16, 2023, 10:24:38 AM12/16/23
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Done.

 

Many thanks G D for setting us up for the response on this one. 😊

 

 

For anyone that did not have the opportunity to catch the online TAPR conference last Saturday, you may have missed a quiet little announcement, that has some pretty BIG implications for FreeDV, to this very point.

 

Here’s a link to the recorded session on YouTube.  (1088) tapr 2023 - YouTube

 

In particular, there were 2 presentations, for FreeDV.

I gave one on the normal operation and configuration of the client software, with a small glimpse of a NEW way to use FreeDV on a Flex 6000 series radio, as well as an Icom IC-705 radio. ezDV device.

This will also work with any other radio as well like the way the SM1000 does, just not as seamless as the previous 2 radios mentioned.

 

Then Monneer-K6AQ presented the ezDV device to do this with, that he designed, and will very soon be available for purchase through the TAPR online store. Much appreciation for TAPR to recognize the need for something like this to made available for all.

 

If your on FreeDV today, and access the FreeDV Reporter page, https://qso.freedv.org/ you will see a few of using this device right now with excellent results, and a great deal more functionality than the Waveform implementation of many years ago. As this does NOT require ANY software to be installed on the radio itself. It just makes a wifi connection to link to the radio.

 

Building on the really great work that Flex did as an early concept, this NEW method allows for multiple modes, Analog, 700D, 700E, 1600 for now, similar to the SM1000 modes, Voice Keyer for CQ messages, and the ability to flash new firmware over the network to stay very current with the many changes taking place in FreeDV every week or so.

 

And this shows up on the Flex radio as 2 NEW modes, much like USB and LSB, there is now FDVU and FDVL. After you have selected the mode you want to operate in like 700D via a simple web interface, you then just select the FDVU mode on the radio, dial up the frequency like 14.236 or anything else, and use any mic you want, such as the PC mic, or the local mic on the radio, and your on the air, quick and easy.

 

 

As an added bonus, if your accessing your Flex 6000 series radio remotely via an Ipad, Iphone, or PC, again, you just select the FDVU mode, and your ready to go. Nothing to install on the other devices to take advantage of these features.

 

If you have any question on this, feel free to let us know, or catch me on my ZOOM channel any time, if you want to see more of what it looks like.

Look me up on QRZ for the link, we are always on with many others.

 

Don’t forget, THIS is the FreeDV Activity weekend, so get on the air and join us..

 

All the best,

Walter/K5WH

 

From: digita...@googlegroups.com <digita...@googlegroups.com> On Behalf Of G D
Sent: Saturday, December 16, 2023 6:32 AM
To: digita...@googlegroups.com
Subject: Re: [digitalvoice] Re: ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions

 

FreeDV was in the Flex Radio Option downloads but had not been available for a while as it is NOT fkex software, just a works with and a third party available software.   I did have the original version buy nobody used it.  That is an option for programmers to look into building again for those atleast 

image001.png

Gary Kohtala

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Dec 16, 2023, 2:27:50 PM12/16/23
to digitalvoice

Is anyone doing FREEDV on a Flex 1500? If so, how?

Best regards,

Gary, K7EK

Mooneer Salem

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Dec 16, 2023, 3:34:25 PM12/16/23
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My understanding was that Flex radios older than the 6000 series use PowerSDR, so setup should be pretty similar to what's done for the Hermes Lite. Several people (including myself) have set up FreeDV to operate with the Hermes with no problems :)

Anyway, from what I remember, you'll need a virtual serial port driver (e.g. VSPE or com0com) and a virtual audio cable (such as VB-Cable). PowerSDR would basically be set up so that one virtual audio cable is the output for VAC1 and another for the input (along with CAT control using one of the virtual serial ports). FreeDV would then be set up to use those virtual audio cables on the radio side and the other virtual serial port for CAT control (using something like the Kenwood TS-2000 or whatever PowerSDR is set up to emulate). Hope this helps!

-Mooneer K6AQ

wal...@k5wh.net

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Dec 16, 2023, 3:35:46 PM12/16/23
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On the 1500, you have to use the regular client software, and it works well for that.

 

 

Walter/K5WH

 

From: digita...@googlegroups.com <digita...@googlegroups.com> On Behalf Of Gary Kohtala
Sent: Saturday, December 16, 2023 1:28 PM
To: digitalvoice <digita...@googlegroups.com>
Subject: Re: [digitalvoice] Re: ARLB031 ARRL Hails FCC Action to Remove Symbol Rate Restrictions

 

 

Is anyone doing FREEDV on a Flex 1500? If so, how?

Mooneer Salem

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Dec 16, 2023, 3:36:59 PM12/16/23
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To add to Walter's comment, ezDV is useful for the Flex even if you have no interest in FreeDV (although we hope that you do give it a shot) simply for the voice keyer feature. AFAIK it's still not native to SmartSDR, so having a device that will let you kick off the voice keyer whether using FreeDV or analog is useful for sure.

-Mooneer K6AQ

Bret Mills

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Dec 16, 2023, 4:17:53 PM12/16/23
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It was the early 6700, 6500. and 6300 with SmartSDR that had embedded FreeDV not PowerSDR.
Maybe someday it will return 
73 
Happy Holidays
Bret
WX7Y




--
Bret Mills
WX7Y
Mills Electronics

glenn...@gmail.com

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Dec 17, 2023, 8:22:54 PM12/17/23
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Is the integrated Flex 6000 version available for download somewhere?  I have not seen it anywhere, possibly just missed its location.

 

Glenn

image001.png

Mooneer Salem

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Dec 17, 2023, 9:09:59 PM12/17/23
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Hi Glenn,

ezDV is intended to replace the Flex waveform that was previously available. The latter (assuming it can still be found somewhere online) has a few downsides:

1. No support for 700D, E, etc.--only 1600 mode.
2. Only supports SmartSDR 2.x (it will not work with SmartSDR 3.x).

(2) in particular is likely a dealbreaker for most as 3.x has been around for a while at this point. Fortunately it shouldn't be too long for ezDV to appear in the TAPR store :)

Thanks,

-Mooneer K6AQ

Takehiko Tsutsumi

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Dec 18, 2023, 12:45:23 AM12/18/23
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Hi Mooner,

Thank you for your response.

Concerning your comments "One thing that would be good for R2 is to have appropriate frequencies assigned for DV in its band plan, though I don't think it'll 100% solve the problem of people transmitting over us.", I interprete them as follows.

1. FreeDV CoA of all IARU band plans on 40m is "7.070MHz" and Canadian stations belong to R2 can transmit on 7.070MHz and it would be good to be able to commucate world-wide.

2. However, FCC R&D allows  "Phone, image" in  "7.075–7.100 MHz" and therefore, US FreeDV stations even they belong to R2, they can not transmit at 7.070MHz CoA and it is a problem even FreeDV is designated as "Phone" with "generally the upper halves of each of the HF bands".

Am I correct?

Regards,

take

de JA5AEA

2023年12月16日土曜日 5:30:09 UTC+9 Mooneer Salem:

Mooneer Salem

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Dec 18, 2023, 1:27:26 PM12/18/23
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Hi Take,

I was actually thinking about 20 meters with my previous comments. It doesn't look like there's a DV frequency for Region 2 there, while 14.130 MHz is the DV "center of activity" for the other regions. Even for the other regions, I wonder if it should be moved to better match current reality (i.e. to 14.236 MHz or wherever other DV activity happens).

Regardless, I don't think 7.070 MHz is a good idea on 40 even if it were legal for Americans due to the fact that other digital modes are pretty close to that frequency.

Thanks,

-Mooneer K6AQ

Takehiko Tsutsumi

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Dec 18, 2023, 6:21:35 PM12/18/23
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Mooner,

No, 20m is another problem as well as 40m because FCC R&D only allows  "Phone, image" in  "14.15–14.35 MHz". You can not access 7.070MHz as they are allocated only to "RTTY data" on 40m. Indeed, this R&D has 100% problems for us.

Thus my conclusion is:

1. It is clear that FCC/ARRL categorizes DV is "Phone" not "Data" by this R&D. This may be good as they match IARU definition and finilaize our discussion "who we are" in this thread. 

2. It is clear that FCC/ARRL intends to expand Data and shrink Phone/Image by this R&D from the example of 40m and 20m prime band plan. If they do not want to be isolated from the rest of world, they must convince IARU members to move the current IARU DV CoAs (priortized for generic DV who does not have LBT feature like WSJT-X) to Phone/Image bands, (lowest edge of FCC phone/Image?).

3. FreeDV has implemented bi-lingual capability to talk to analog SSB/AM.  FreeDV is different from exsisting Image or generic DV service who needs  "Listen Before Talk" practice to avoid interferencestated to SSB/AM. Thus, we have the freedom to access any Phone/Image segment holding the "first radio service" title along with SSB/AM phone. We will also define FreeDV unique working frequencies adding to IARU CoAs (highest edge of phone/Image?).

Am I correct?

Regards,

take

de JA5AEA

2023年12月19日火曜日 3:27:26 UTC+9 Mooneer Salem:

Bruce Perens

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Dec 18, 2023, 6:52:33 PM12/18/23
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There are a few well-known problems here that are not going to be fixed without an additional rule-making. I would encourage people who are really interested in such to make one. Anyone can and I'd be happy to help, having worked on such things as removing the code testing requirement. You definitely do not need ARRL, indeed their participation is potentially of negative value because they have previously been influenced to remove a regulation-by-bandwidth NPRM by their membership, who felt it was a threat to their analog operations.

Yes, modulation designators were great for describing simpler modulations but are fatally flawed in that they include the type of payload.

Yes, regulating digital communication by payload is inherently flawed because it can be anything from moment to moment and generally is more than one thing.

The simplest way to approach this is two-pronged:

1. File for an STA (special testing authority) that other hams can sign on to, which allows the sort of operation you want; digital communication with inherently multiple payloads, in various band segments. Note on the STA that is an experiment that is likely to result in a request for rule-making. STAs are generally easy to get. After issuance any FreeDV operator can sign on to it.

2. File for rule-making. Find someone in congress to write to FCC and encourage them to act, if they don't do so on a timely basis (this is what ARRL just did).

    Thanks

    Bruce



Rick, W4XA

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Dec 19, 2023, 2:39:36 AM12/19/23
to digitalvoice
I agree with Bruce

I think an STA application could be a pretty good first step since FreeDV could be shown to fall into the multiple "payload" category since even the emission designators do not indicate "weight " or percent of the mix of "voice",  image or other  "data" as the dominant purpose of the transmission.

It gets the ball rolling in the direction of a specific segment on each band and/or possibly general inclusion in the "RTTY & DATA" segments.  Since the bandwidth will likely always be less than 2.8kHz it can be argued that because of the (currently) small amount of actual users, effective testing can continue with no disruption to existing SSB/AM operations nor be hampered by SSB/AM as is currently happening on a regular basis.

Regards,

Rick

jdow

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Dec 19, 2023, 6:11:06 AM12/19/23
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OK, I started some of this mentioning the AM/SSB wars. On contemplating it a little more I suspect one reason SSB caught on was the compatibility with most equipment hams owned. If a radio could receive CW it sound receive SSB to some degree. The conversations would draw somebody in. Operating between modulation platforms was quite feasible. FreeDV has both SSB and DV operating modes. Su let's go a step further and optionally include a (much?) reduced power SSB signal over the DV signal. (Heh, let the FCC sort out the modulation code for that station. {^_-}) At least where the signal is strong the SSB operator may be able to hear the SSB and decide "Am I hearing something I want to hear better?" If yes, break in politely and ask "How the heck do I join what you guys are doing?" Be inviting not confrontational. If the SSB power remains say 10 dB below the DV power DV demodulation should be good and SSB readable but crappy. That might speed up the transition - catching ARRL and FCC with their pants down again.

{^_^}   Joanne/W6MKU

(Yeah, I remember the wars. My first SSB TX was a 50 MHz Heathkit phasing beast nearly 60 years ago. Polite worked FAR better than "Ralphie".))

Rick, W4XA

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Dec 19, 2023, 12:25:42 PM12/19/23
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It's of course,  always better to be non-confrontational and positive.  

I did get a somewhat "positive " response from the (extra-class) POTA guy that spewed forth 4-letter expletives in response to a DV signal after I explained what the signal was.

But in general in current times many amateurs think someone is "tuning-up" (zero-beat)  on the frequency when I transmit checking into traffic nets running my Viking Valiant (AM) and a great many think I'm running encrypted voice if I operate on 75 or 40m using the opposite sideband.

The "transition" if one could call it that, probably won't ever be people listening with an SSB receiver on "Phone" segments of current bands  and wondering how they could "try" it.  

 Back in the "old days" , those listening to SSB with an AM receiver could of course easily tell someone was talking, and then  "decode" using a simple BFO or even the "spot" mode of their transmitter.

(EF Johnson calls it  "Zero" on the Valiant)   After my Valiant warms up and becomes "stable" ....I'm frequently able to "zero-in" the transmitter by "tuning-in" Net-Control stations.    9-times out of 10, no one notices I am on AM and every once in a while the Net Control will say "Someone is tuning up on frequency, every time you transmit, but we can hear you fine "through" i!  A few times some of the more observant ones will say "you appear to have some carrier on your signal" (!!!!)  And another time a net member broke in and told me that he was observing his "display" and "Did you know that you're really wide?"

I still believe our "best bet" will be either a segment on each band dedicated to DV or maybe authorization to operate in NON phone segments until more can be educated in DV.  

Just about all the other digital mode operators have the computer skills and radio set up covered. It's just another software package for them to download, install and configure.

The pure PTT appliance operators will likely be willing to try it when the "Box" between the microphone and radio becomes widely available and inexpensive or ICOM/Ken/YAE/Flex/ANAN etc finally add a "FreeDV" button  (Yes, I know....that may never happen )   

Yes, I know I sound rather cynical.

Regards,

Rick

Steve Stroh

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Dec 19, 2023, 6:14:12 PM12/19/23
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My thanks to W6MKU, K6AQ, K5WH, and K6BP for interesting comments in this thread. I’ll be including some excerpts from this thread, with some “meta” commentary in this week’s issue of Zero Retries.


--
Steve Stroh N8GNJ (he / him / his)
Editor
Zero Retries Newsletter - https://www.zeroretries.org

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