GM Rick,

The FCC needs to attend some "Keep It Simple Servant" a.k.a. KISS 
training seminars as well as bring FCC Part 97 into the modern world. 
Those members of this forum that on OCONUS for the most part must 
laugh themselves silly at all this non-sense.

In my personal opinion, there are a number of data modes being used 
by U.S. Amateurs that are in gray areas or outright illegal taking 
into account FCC Part 97 and many Amateurs have no clue that this is 
the case do the complexity of the Part 97 and even the lack of 
enforcement of the rules on the part of the FCC, some good hardware 
protocol examples are the use of PACTOR III and MIL-STD-188-110 
modems, but for different reasons as detailed via this forum on many 
occasions by various individuals.

I believe that the FCC should simplify things regarding these issues 
and open the door to more experimentation and enhancement of data 
communications by U.S. Amateurs by simply allowing for 3Khz BW 
maximum and data rates through 3600bps ( baud rate will vary by data 
content, but average at 1200 baud ) where all protocols must be fully 
documented in public view so that anyone can develop the capability 
to monitor the transmissions, this includes any data compression 
formats being applied.

/s/ Steve, N2CKH


At 10:16 AM 12/14/2006, you wrote:
>Jim,
>
>Pactor 3 is not classified as a narrowband mode. It is a fairly wideband
>digital mode.
>
>The FCC made a very incorrect claim in the Report and Order, that stated:
>
>"The Rules also subdivide all but two of these bands into a frequency
>segment in which amateur stations may transmit only emissions that
>require a narrow bandwidth, such as telegraphy, data or radio teletype
>(RTTY) emissions, and a frequency segment in which amateur stations may
>also transmit emissions that require more bandwidth, such as voice or
>image emissions."
>
>The fact is that there are other modes such as P3, wide versions of
>Olivia, MT-63, that are similar to the bandwidth needed for voice
>communication.
>
>They go on further to make it very clear that they view the Data/RTTY
>area as narrowband and the voice/image area as wideband and divided up
>80 meter band to "result in a more equitable division of spectrum
>between users of narrowband and wideband mode."
>
>Footnote 60 is most interesting:
>
>"... this division would result in two hundred channels for stations
>transmitting telegraphy and other narrowband emissions and one hundred
>thirty three channels for stations transmitting voice and other wideband
>emissions."
>
>They also seem to be suggesting that 500 Hz is the maximum size that is
>appropriate for narrow band modes and why they made the limit at that
>point, but they also would not go along with the ARRL request that they
>not impose a 500 Hz BW limitation on data emissions an d would not make
>it 3 KHz, yet they allowed the previous modes to be wider.
>
>73,
>
>Rick, KV9U


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