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

423 views
Skip to first unread message

WB9QZB

unread,
Nov 17, 2023, 1:51:55 AM11/17/23
to Digest Recipients

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bands by removing outdated restrictions and providing licensees with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

unread,
Nov 28, 2023, 9:36:25 PM11/28/23
to digitalvoice
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

unread,
Nov 29, 2023, 4:05:37 PM11/29/23
to digita...@googlegroups.com
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

--
You received this message because you are subscribed to the Google Groups "digitalvoice" group.
To unsubscribe from this group and stop receiving emails from it, send an email to digitalvoice...@googlegroups.com.
To view this discussion on the web visit https://groups.google.com/d/msgid/digitalvoice/b13ff0ed-658f-4ba8-a694-1f6bf776876cn%40googlegroups.com.

Takehiko Tsutsumi

unread,
Nov 29, 2023, 8:12:17 PM11/29/23
to digitalvoice

 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

unread,
Nov 30, 2023, 2:25:04 AM11/30/23
to digitalvoice
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

unread,
Nov 30, 2023, 2:50:41 AM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 2:54:01 AM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 4:25:58 AM11/30/23
to digitalvoice
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

unread,
Nov 30, 2023, 6:28:16 AM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 1:18:48 PM11/30/23
to digitalvoice

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

unread,
Nov 30, 2023, 4:13:51 PM11/30/23
to digita...@googlegroups.com
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>.
>
> --
> You received this message because you are subscribed to the
> Google Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from
> it, send an email to digitalvoice...@googlegroups.com.
>
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/179b2d59-817d-4205-8335-fb60f85f8206n%40googlegroups.com
> <https://groups.google.com/d/msgid/digitalvoice/179b2d59-817d-4205-8335-fb60f85f8206n%40googlegroups.com?utm_medium=email&utm_source=footer>.
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it, send
> an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice...@googlegroups.com>.
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/31d706f0-ade9-4813-9d07-06dc2584e000n%40googlegroups.com
> <https://groups.google.com/d/msgid/digitalvoice/31d706f0-ade9-4813-9d07-06dc2584e000n%40googlegroups.com?utm_medium=email&utm_source=footer>.


--
73 de Tony VK3JED/VK3IRL
http://vkradio.com

Tony Langdon

unread,
Nov 30, 2023, 4:21:03 PM11/30/23
to digita...@googlegroups.com
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>.
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it,
> send an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice...@googlegroups.com>.
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/179b2d59-817d-4205-8335-fb60f85f8206n%40googlegroups.com
> <https://groups.google.com/d/msgid/digitalvoice/179b2d59-817d-4205-8335-fb60f85f8206n%40googlegroups.com?utm_medium=email&utm_source=footer>.
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it, send
> an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice...@googlegroups.com>.
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/CAAzDfxP5aRF3BoVM04fgUkBmssMxLtTjM%2Bx6nDSBaOmRNzxiPA%40mail.gmail.com
> <https://groups.google.com/d/msgid/digitalvoice/CAAzDfxP5aRF3BoVM04fgUkBmssMxLtTjM%2Bx6nDSBaOmRNzxiPA%40mail.gmail.com?utm_medium=email&utm_source=footer>.

Rick, WA6III

unread,
Nov 30, 2023, 5:03:31 PM11/30/23
to digitalvoice
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>.


--
73 de Tony VK3JED/VK3IRL
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

unread,
Nov 30, 2023, 5:57:54 PM11/30/23
to digita...@googlegroups.com
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

--
You received this message because you are subscribed to the Google Groups "digitalvoice" group.
To unsubscribe from this group and stop receiving emails from it, send an email to digitalvoice...@googlegroups.com.

Rick, WA6III

unread,
Nov 30, 2023, 6:47:10 PM11/30/23
to digitalvoice
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

unread,
Nov 30, 2023, 7:38:58 PM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 8:31:51 PM11/30/23
to digitalvoice
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

unread,
Nov 30, 2023, 8:32:43 PM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 9:35:51 PM11/30/23
to digita...@googlegroups.com
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
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it, send
> an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice...@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>.

Tony Langdon

unread,
Nov 30, 2023, 9:46:12 PM11/30/23
to digita...@googlegroups.com
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

unread,
Nov 30, 2023, 10:31:12 PM11/30/23
to digita...@googlegroups.com
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

To unsubscribe from this group and stop receiving emails from it, send an email to digitalvoice...@googlegroups.com.
To view this discussion on the web visit https://groups.google.com/d/msgid/digitalvoice/daac134d-1dac-3c4b-2934-5c0b343f9268%40gmail.com.

Tony Langdon

unread,
Nov 30, 2023, 10:48:37 PM11/30/23
to digita...@googlegroups.com
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
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it,
> send an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice%2Bunsu...@googlegroups.com>.
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/daac134d-1dac-3c4b-2934-5c0b343f9268%40gmail.com.
>
> --
> You received this message because you are subscribed to the Google
> Groups "digitalvoice" group.
> To unsubscribe from this group and stop receiving emails from it, send
> an email to digitalvoice...@googlegroups.com
> <mailto:digitalvoice...@googlegroups.com>.
> To view this discussion on the web visit
> https://groups.google.com/d/msgid/digitalvoice/CAAzDfxPTqmEwWsdW%3DwZo5O4ukMxExeVF9t7zOhaKq4_cC4HArw%40mail.gmail.com
> <https://groups.google.com/d/msgid/digitalvoice/CAAzDfxPTqmEwWsdW%3DwZo5O4ukMxExeVF9t7zOhaKq4_cC4HArw%40mail.gmail.com?utm_medium=email&utm_source=footer>.

Takehiko Tsutsumi

unread,
Nov 30, 2023, 11:13:52 PM11/30/23
to digitalvoice
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

unread,
Dec 1, 2023, 3:55:37 AM12/1/23
to digita...@googlegroups.com

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

unread,
Dec 1, 2023, 6:00:00 AM12/1/23
to digita...@googlegroups.com
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)

unread,
Dec 1, 2023, 5:33:42 PM12/1/23
to digitalvoice
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

unread,
Dec 1, 2023, 8:53:38 PM12/1/23
to digitalvoice
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

unread,
Dec 2, 2023, 2:01:49 AM12/2/23
to digita...@googlegroups.com

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

unread,
Dec 2, 2023, 2:42:02 AM12/2/23
to digita...@googlegroups.com
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

unread,
Dec 2, 2023, 3:35:54 AM12/2/23
to digita...@googlegroups.com

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

unread,
Dec 2, 2023, 8:16:18 AM12/2/23
to digita...@googlegroups.com
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

unread,
Dec 2, 2023, 3:29:17 PM12/2/23
to digita...@googlegroups.com
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

unread,
Dec 2, 2023, 3:29:18 PM12/2/23