Yeah, the symbol rate petition got all conflated with Winlink and HF e-mail. Any time there are many comments on a petition with about 50/50 for/against, the FCC punts.
I'm wondering if a very specific petition could work. Just change one line in 97.305(c).
Change:
70 cm Entire band MCW, phone, image, RTTY, data, SS, test (6), (8)
To:
70 cm Entire band MCW, phone, image, RTTY, data, SS, test (7), (8)
Essentially make 70 cm equal to 33 cm and above (except for F8E, which is fine).
Ron W6RZ
On 3/24/19 14:45, Steve L via 44Net wrote:
Ron, Every chance I get to make FCC comment I mention this. That is just a comment though, not an actual petition. Either way it takes patience and a long life to get anywhere with getting regulations changed.
Since this uses TDMA modulation I'd say it could be classified as spread spectrum? Either way if this thing becomes an option in the US to buy or build as a kit, rest assured whatever archaic regulations still exist will be ignored by myself.
Since you asked: The ARRL has sort of (half-assed/not well thought*) tried to address this half-ass symbol rate business. Their efforts date back to September 2013. The Dec 23 2013 comment deadline, yielded more than 850 comments had been filed, which was a large number indicating that the issue of data communications is an important one in the Amateur Radio Service.
From the conclusion of the rule making proposal (7/28/16):
In summary, we believe that the public interest may be served by revising the amateur service rules to eliminate the current baud rate limitations for data emissions consistent with ARRL’s Petition to allow amateur service licensees to use modern digital emissions, thereby furthering the purposes of the amateur service and enhancing the usefulness of the service. We do not, however, propose a bandwidth limitation for data emissions in the MF and HF bands to replace the baud rate limitations, because the rules’ current approach for limiting bandwidth use by amateur stations using one of the specified digital codes to encode the signal being transmitted appears sufficient to ensure that general access to the band by licensees in the amateur service does not become unduly impaired.
In short:. They agree that a hard baud limit is not good, but the bandwidth limit proposed by ARRL isn't any better, so FCC denied the request. And I haven't see the league make any subsequent revised proposals or petitions.
*The proposal to modernize the rules for data transmissions called for the baud rate limits to be removed, and will governed by just the maximum bandwidth portion of the existing rules. The present rule for the 70 centimeter band is 56 kilobauds/100 kHz. If the FCC would have approved the request we'd have just a 100 kHz wide limit. With present technology, using 4FSK or QPSK Modulation is should be possible to achieve near 170kbps in that 100 kHz. The petition does fall short of addressing bandwidth for image (6 MHz) verses data emissions (100 kHz), which is very disappointing.
On Sun, Mar 24, 2019 at 3:13 PM Ron Economos via 44Net 44net@mailman.ampr.org wrote:
This keeps coming up. Has anyone ever submitted a petition for rule making to the FCC? Or are folks afraid that stirring the pot will get DATV banned on 70 cm?
Ron W6RZ
On 3/24/19 12:09, Mark Phillips wrote:
I had another thought about the bandwidth.
Why can digital ATV get away with it and we cannot? Their data rates get up to mbps. They justify it by calling it "TV" rather than data.
On Sun, Mar 24, 2019 at 2:52 PM Mark Phillips g7ltt@g7ltt.com wrote:
We keep hitting this bandwidth wall. I say we should just ignore it. We are never gonna get a change if we don't show the need for it.
On Sun, Mar 24, 2019 at 2:36 PM K7VE - John k7ve@k7ve.org wrote:
I note that at the advertised bit rates, the OBW (occupied bandwidth) may exceed US Regulations for 70cm. However, the chip used, is also claimed to support 33cm.
I am interested in the new packet protocol proposed by the project. Even at a lower bps on 70cm (for the US), and full rate at 33cm, this has real potential for mid-tier data communications.
CFR 47 Part 97.307 (f) 6
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