Band Plan and 14.130 in USA

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Mel Whitten

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Oct 3, 2021, 11:32:14 AM10/3/21
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In my previous posting, I am aware that 14.150 is the lowest frequency for SSB and that is for US extra class licenses only too.  14.130 would require the FCC rules be changed which would mean DV be defined as a digital mode and not a voice mode.  So 14.130 is not a frequency we could move to unless the rules changed.  With the IARU band plan backing, maybe this would help get the rules changed to identify DV as a digital mode and allow us to use 14.130?

 

Perhaps, this is wishful thinking on my part and maybe we would run into “other” QRM on .130, but I doubt it could be worse than it is on 14.236.

 

Mel, K0PFX

 

 

Bruce Perens

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Oct 3, 2021, 12:39:15 PM10/3/21
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Do FCC rules really define digital voice as radiotelephone? I think this is the applicable regulation:

Speech and other sound emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1, 2, 3 or X as the second symbol; E as the third symbol. Also speech emissions having B or F as the first symbol; 7, 8 or 9 as the second symbol; E as the third symbol. MCW for the purpose of performing the station identification procedure, or for providing telegraphy practice interspersed with speech. Incidental tones for the purpose of selective calling or alerting or to control the level of a demodulated signal may also be considered phone.

Codec2 on HF is a multi-carrier mode and arguably should have "W" as the first letter. The second letter can arguably be "2", and the third is " E", and maybe a fourth, 5" or "X" as the modulation detail.

I guess the point here is that modulation designators haven't really kept up with digital development. Their use in regulation at this late date is going to cause confusion and have unintended effects. There can be two reactions to ambiguity: don't do anything ambiguous, or do the ambiguous until regulations catch up. At least in the United States are regulator is not pulling licenses over this kind of issue.

Thanks

Bruce

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wal...@k5wh.net

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Oct 3, 2021, 12:42:35 PM10/3/21
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So then, what are the requirements for that, assuming that 14.130 was adopted by the FCC and the IARU.

 

If it’s defined that way, does it mean that we would be locked to ONLY that single frequency, instead of having the ability to move between a whole band segment like today?

 

That would certainly be problematic for sure.

 

If it gets reclassified as a digital mode, that would open up 30 meters as an option, so certainly some value in that.

 

Being away from the competition of SSB would really be nice for sure.

 

 

Walter/K5WH

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Bruce Perens

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Oct 3, 2021, 12:49:00 PM10/3/21
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Neither ITU nor FCC will be adopting IARU band plans. They are voluntary agreements among radio amateurs. IARU's have input to what they ask for at International Radio Conferences. However, both IARU and ARRL know better than to ever hard-code modulation methods in Federal Regulation or International treaties again.

Thanks

Bruce

wal...@k5wh.net

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Oct 3, 2021, 1:11:58 PM10/3/21
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So if that’s the case, then is there anything at all to stop us from adopting 14.130 for FreeDV right now on 20 meters?

 

 

Walter/K5WH

Bruce Perens

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Oct 3, 2021, 1:19:03 PM10/3/21
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I don't see any regulatory problem with running FreeDV in "CW" bands. They are authorized for digital modes. Some people will consider it discourteous, and some will gripe. Right now we have people who deliberately transmit over us. I doubt it's going to be worse wherever we go.

Mooneer Salem

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Oct 3, 2021, 2:15:55 PM10/3/21
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Hi all,

The ARRL interpreted digital voice as "J2E" back in 2000 (http://www.arrl.org/files/file/Technology/tis/info/pdf/0056x003.pdf) based on the following reasoning:

Q. What is the emission designator for HF digital voice?
A. Digital voice is Phone, defined in §97.3(c)(5) as: “Speech and other sound

emissions having designators with A, C, D, F, G, H, J or R as the first symbol;
1, 2 or 3 as the second symbol; E as the third symbol.” (It rambles on…)
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.)
The second symbol in this case is “2,” meaning: “A single channel containing quantized or digital information with the use of a modulating subcarrier, excluding time-division multiplex.”
The third symbol is “E” for “Telephony.”
So, the most likely HF digital voice emission symbol will be “J2E.”


However, that may not take into account exactly how the DV modes are implemented. For instance, D-Star is F7W by Icom's own documentation (example: https://fcc.report/FCC-ID/AFJ386700/5039431.pdf page 34) yet there has been use of it on HF. 

Regardless, the IARU presentation specifically says that any country-specific rules take precedence, so 14.130 would likely still not be usable by US hams for FreeDV (assuming it's still interpreted as a voice mode).

Thanks,

-Mooneer K6AQ

Bruce Perens

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Oct 3, 2021, 2:26:53 PM10/3/21
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I have a problem with "J". Single sideband is modified amplitude modulation with the carrier and the second sideband filtered out. It makes sense when you apply it to analog voice. With anything else, a single sideband transmitter is actually a baseband to RF transverter. It is thus not any particular form of modulation. It can accommodate any modulation that fits in the bandwidth.

So "J" seems meaningless to me. I don't think it's more than a polite fiction meant to fit an unplanned-for modulation into an aged and obsolete form of representation that is unfortunately hard-coded into regulation.

Ultimately it just doesn't make sense to refer to anything but bandwidth in regulation.

wrxp...@gmail.com

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Oct 3, 2021, 3:09:07 PM10/3/21
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Designators are for a by-gone tyme. 

What if the words are never spoken and just read? Like that has never been done before and is.

If I have my computer setup to receive & translate Morse code (or RTTY) to words and pipe that output into a language reader, am I not hearing "digital voice"?

If I have a microphone on my computer (or thru a device as Alexa, Apple Siri, etc) ... ... translate to Morse & the key transmitter, am I not sending "digital voice"? And there are simpler free methods to do this by not using one of those devices. Does language matter? English, Spanish, Chinese, Klingon?

On the other hand if I do have one of those devices, it could automatically send a message (initiated from my dog, such as 2 barks and a whine resulting in the sending of Morse code or RTTY or whatever) that "he is out of dog bones" at >100 WPM. At that speed, who would know?

Mel Whitten

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Oct 3, 2021, 3:24:29 PM10/3/21
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Early in the days of DV, I asked the ARRL about this and ARRL’s Paul Rinaldo told me DV was “J2E” and had to be used in the SSB segments of the our bands.  There were not many popular “wide” digital modes on HF like DRMDV/WinDRM DV back then.  Perhaps, DV’s wider BW at the time had something to do with its classification to keep it in the SSB segment.

 

As Bruce and others have said, regulate by BW as nothing else makes sense.

 

Mel, K0PFX

glenn...@gmail.com

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Oct 3, 2021, 3:51:56 PM10/3/21
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Digital Mode references computer to computer text not computer to computer VOICE.  There is the difference, not the wave form type.

ger...@burian.pro

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Oct 3, 2021, 5:15:53 PM10/3/21
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Hi all,

Here in Austria we only have BW regulations and we can use any mode within, but it has to be documented somewhere.

73 de Gerhard OE3GBB

Bruce Perens

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Oct 3, 2021, 7:08:07 PM10/3/21
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Glenn, Unfortunately this is taking us back to the previous age where modulation designators made sense. There used to be a thing called a radio, and a teletype, and a television and they each did one thing that the other two did not.

Once you go digital, every signal is text. The momentary content may have originated with a voice or the output of a camera. But it can be something else from one datagram to the next. 

Thanks

Bruce

Mooneer Salem

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Oct 3, 2021, 8:55:36 PM10/3/21
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Interestingly, the ARRL also uses "J" for PSK31 (http://www.arrl.org/psk31-spec), which makes me think that they're generally interpreting the first letter of the designator as what's ultimately used to transmit the signal. As FreeDV uses QPSK modulation much like PSK31 is able to (https://github.com/drowe67/codec2/blob/master/README_freedv.md), it would follow that FreeDV is also "J2E" as per the article I previously linked. Of course, as others have mentioned, that interpretation is possibly not the most correct one to use.

That said, I agree with others in that the rules should be updated. However, I remember the last time we tried to switch to regulation by bandwidth and it didn't go well, so I don't see another attempt happening any time soon.

-Mooneer K6AQ

Bruce Perens

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Oct 3, 2021, 10:26:56 PM10/3/21
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The last time, ARRL submitted the rule-making. Unfortunately, ARRL's
membership doesn't position them to drive the future of Amateur Radio.
Nice as all of our friends on the board are, etc., the membership
won't let them do it.

Thanks

Bruce
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wrxp...@gmail.com

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Oct 3, 2021, 11:10:45 PM10/3/21
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Digital to digital does not have to be computer to computer. Thus enter the age of FPGAs ($) and ASICs ($$$) ... decades ago. 

Take DMR. No computers, yet digital up to nearly the speakers & mic.

Jeff AE8W

G D

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Oct 4, 2021, 6:17:43 AM10/4/21
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Also not sure how many but there are many, qho do not use their ears at any time when using digital modes.  The whole arguement about digital has become very confusing for many.  Just like radios at work the voice modulation is either analog or "digital".  Perhaps we should stop calling DV digital voice and call it by the modulation designators.  This would clear up peoples apparent confusion about the differences.  But then there would be many complaining about having things spelled out to specific modulations or waveforms being used in specific places.  The generic voice and digital were or are used to make it generic and allow for experimentation and development of new modulations.  But perhaps those days are over as 95% of amateurs no longer create or develop they simply use.

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Tony Langdon

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Oct 4, 2021, 4:44:33 PM10/4/21
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On 4/10/21 11:55 am, Mooneer Salem wrote:
> Interestingly, the ARRL also uses "J" for PSK31
> (http://www.arrl.org/psk31-spec), which makes me think that they're
> generally interpreting the first letter of the designator as what's
> ultimately used to transmit the signal. As FreeDV uses QPSK modulation
> much like PSK31 is able to
> (https://github.com/drowe67/codec2/blob/master/README_freedv.md), it
> would follow that FreeDV is also "J2E" as per the article I
> previously linked. Of course, as others have mentioned, that
> interpretation is possibly not the most correct one to use.

How to muddy the waters. I'm with Bruce in that I believe this
interpretation is at best misleading, at worst, totally wrong. I
consider the SSB radio in these setups to be an IF stage with a passband
in the 300-3000 Hz range (approx). The actual modulation (and therefore
emission generation) is done by the computer. Once the signal leaves
the computer, it is unchanged, except for frequency conversion and
amplification.
>
> That said, I agree with others in that the rules should be updated.
> However, I remember the last time we tried to switch to regulation by
> bandwidth and it didn't go well, so I don't see another attempt
> happening any time soon.

It's way beyond time the US caught up with the rest of the world!


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http://vkradio.com

Bruce Perens

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Oct 20, 2021, 1:27:19 AM10/20/21
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One more thing to complicate this issue: Many modern amateur transmitters create a CW signal using their SSB modulator. It is thus entirely ambiguous whether the CW signal should have a J in its modulation designator, and whether it is CW or MCW.

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Robert Tiller

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Nov 14, 2021, 2:11:41 PM11/14/21
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The Sumter County Digital group has a web page listing 10.124 - 10.127Mhz as DSSTV/DVOICE. 
Looking at the 30M tab. 

73,
Robert
AE5YG

Mooneer Salem

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Nov 14, 2021, 2:52:28 PM11/14/21
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Is 10.124-10.127 commonly used for those outside the US? There are a few countries that allow voice on 30m so their pages may be listing everything used worldwide instead of just in the US.

-Mooneer K6AQ

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