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RE: [FT897] Legalities of tuning on 60m

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  • KW7DSP Steve Pickering
    What Dean and K9ZTV are talking about is the very thing prohibited on 60 meters. No CW at all. Nothing over 50 watts effective power. USB ONLY, EVER. Never on
    Message 1 of 20 , Jun 30, 2005
      What Dean and K9ZTV are talking about is the very thing prohibited on 60
      meters. No CW at all. Nothing over 50 watts effective power. USB ONLY, EVER.
      Never on LSB as this is all Government. No AM ever, period. And no wiggle
      room. The signal width is very narrow and exceeding it will cost us the
      band. There is no provision for on-the-air tuning, and a lot of provisions
      prohibiting it. It is amazing that so many intend to use the 5 CHANNELS, and
      yes they are channels, have a license, which says they know the rules or
      will before using, and this thread is filled with misinformation about the
      60 meter rules. They are simple, straight forward and easy to understand.


      Steve

      D. Stephen Pickering
      Independence, Polk County, Oregon. USA 97351


      KW7DSP and WPSL211 Grid CN84JU

      ARRL, ARES, RedCross, EmComm I, EmComm II
      Listening on 146.78 & 147.16 No PL, 146.52 Simplex, 144.210 USB, 14.070 USB
      PSK31.
      Noontime Net Daily at 7.268.5mhz LSB

      SASS #33962, NRA, CGOA, C&S MC

      KW7DSP@... Home Address

      KW7DSP@...

      dpickeri@... Student Address

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    • Dean Gibson AE7Q
      How about one OFFICIAL quote to support your position? I m willing to admit I m wrong, but you have provided NO references at all for your claim. Thank you,
      Message 2 of 20 , Jul 1, 2005
        How about one OFFICIAL quote to support your position? I'm willing to
        admit I'm wrong, but you have provided NO references at all for your
        claim. Thank you, but I read the rules before making my post, and I
        quoted one of the rule sections that I found applicable (§97.305(b); the
        other is §97.303(s)). I've also read the FCC Report and Order on this
        matter. If you have ADDITIONAL rules or official statements that I've
        missed, I'm all ears.

        For the record, I've submitted relevant portions of this thread to Riley
        Hollingsworth to get an official FCC position, which I will post here.

        -- Dean

        ps: I find your message insulting and condescending.

        On 2005-06-30 22:20, KW7DSP Steve Pickering wrote:

        >What Dean and K9ZTV are talking about is the very thing prohibited on 60 meters. No CW at all. Nothing over 50 watts effective power. USB ONLY, EVER. Never on LSB as this is all Government. No AM ever, period. And no wiggle room. The signal width is very narrow and exceeding it will cost us the band. There is no provision for on-the-air tuning, and a lot of provisions prohibiting it. It is amazing that so many intend to use the 5 CHANNELS, and yes they are channels, have a license, which says they know the rules or will before using, and this thread is filled with misinformation about the 60 meter rules. They are simple, straight forward and easy to understand.
        >
        >Steve
        >
        >D. Stephen Pickering
        >Independence, Polk County, Oregon. USA 97351
        >
        >
      • Mark@n6ea.com
        Dean, The faq you posted the link for has the info about emission type needing to be USB only. An amateur station having an operator holding a General,
        Message 3 of 20 , Jul 1, 2005
          Dean,

          The faq you posted the link for has the info about emission type needing to be USB only.

          "An amateur station having an operator holding a General, Advanced or Amateur Extra Class license may only transmit single sideband, suppressed-carrier (emission type 2K8J3E) upper sideband on the channels 5332 kHz, 5348 kHz, 5368 kHz, 5373 kHz and 5405 kHz."

          It was always my impression that tuning needed to be with that emission as it is the only allowed.

          73,

          Mark N6EA

          ----- Original Message -----
          From: Dean Gibson AE7Q
          To: FT897@yahoogroups.com
          Sent: Thursday, June 30, 2005 5:00 PM
          Subject: [FT897] Legalities of tuning on 60m


          The question is, is briefly tuning up by modulating a 60m channel with a
          USB 1500Hz tone legal? If so, how can anyone distinguish between such a
          transmission, and a brief CW emission? There's not only no practical
          difference; there's not even a mathematical difference. The only
          difference is in the knobs on the front of the radio.

          The ARRL has an FAQ on this topic:
          http://www.arrl.org/FandES/field/regulations/faq-60.html#q5

          However, here's what the FCC rules say:


          §97.305 Authorized emission types.

          (b) A station may transmit a test emission on any frequency authorized
          to the control operator for brief periods for experimental purposes

          -- Dean

          On 2005-06-30 16:30, Mark@... wrote:

          >...
          >
          >Unless something has changed that I'm not aware of, tuning with any carrier is not legal on 60m.
          >Mark N6EA
          >
          >









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        • whynotbecreative
          ... Actually, their methods make perfect sense, as long as you make sure that whatever method you use to generate a carrier, the carrier has to be within the
          Message 4 of 20 , Jul 1, 2005
            --- In FT897@yahoogroups.com, "KW7DSP Steve Pickering" <KW7DSP@h...>
            wrote:
            > What Dean and K9ZTV are talking about is the very thing prohibited
            > on 60 meters. No CW at all.

            Actually, their methods make perfect sense, as long as you make sure
            that whatever method you use to generate a carrier, the carrier has to
            be within the bandwidth limits of the channel. An unmodulated AM
            carrier, an unmodulated CW carrier or a continuous tone in SSB all
            have the same spectrum signature.

            Steve, why don't you educate us and provide us with an answer instead
            of a rant? With all those proud credentials in your signature, I'm
            sure you can do this. It is your moral (and legal!) obligation to
            educate on the proper procedure(s) when you think a fellow ham is
            about to break the rules or is advocating incorrect procedures.

            73,
            --Alex KR1ST
            http://www.kr1st.com
          • Ed Thierbach
            ... I have yet to see any rule or interpretation that allows equivalent spectrum signatures. Part 97 does make it clear that we are not to transmit a carrier:
            Message 5 of 20 , Jul 1, 2005
              > Actually, their methods make perfect sense, as long as you make sure
              > that whatever method you use to generate a carrier, the carrier has to
              > be within the bandwidth limits of the channel. An unmodulated AM
              > carrier, an unmodulated CW carrier or a continuous tone in SSB all
              > have the same spectrum signature.

              I have yet to see any rule or interpretation that allows equivalent
              spectrum signatures. Part 97 does make it clear that we are not to
              transmit a carrier:

              "§97.303(s)
              An amateur station having an operator holding a General, Advanced or
              Amateur Extra Class license may only transmit single sideband,
              suppressed-carrier (emission type 2K8J3E) upper sideband..." [as
              quoted in the ARRL FAQ, link posted earlier by AE7Q]

              Transmitting AM is not transmitting "suppressed-carrier", of course.
              And since a specific phone emission is specified, I don't believe a
              CW carrier would be legal, either -- remember that, in our other HF
              bands, there is a very sharp distinction between CW emissions and
              phone emissions. I see no reason for us to lose that distinction for
              60M.

              So, for tuning up on 60M, how about this: hold the mic up to your
              trusty old code oscillator and send a tone via USB. Seems like it
              would be the same as (but less "lid-ish" than) the mic-whistling
              mentioned in the ARRL FAQ.

              Just my opinion, I am not a lawyer, and all that.

              73, -Ed- AB8OJ

              Ed Thierbach, AB8OJ (ab8oj@...)
              ARROW Public Service Officer (http://www.w8pgw.org)
              AEC, Eastern Washtenaw County, MI
            • whynotbecreative
              ... I m sure you re right. I just try to be practical about it without trying split hairs on the law. These issues can be made infinitely complicated if one
              Message 6 of 20 , Jul 1, 2005
                --- In FT897@yahoogroups.com, Ed Thierbach <ethierba@u...> wrote:

                > I have yet to see any rule or interpretation that allows equivalent
                > spectrum signatures.

                I'm sure you're right. I just try to be practical about it without
                trying split hairs on the law. These issues can be made infinitely
                complicated if one wants to. For instance, would it be allowed to tune
                up using CW with a rig that uses a side tone to generate CW? ...

                > -- remember that, in our other HF
                > bands, there is a very sharp distinction between CW emissions and
                > phone emissions. I see no reason for us to lose that distinction for
                > 60M.

                You are so ready for that regulation by bandwidth proposal from the
                ARRL. :-)

                > So, for tuning up on 60M, how about this: hold the mic up to your
                > trusty old code oscillator and send a tone via USB. Seems like it
                > would be the same as (but less "lid-ish" than) the mic-whistling
                > mentioned in the ARRL FAQ.

                I bet they mentioned mic-whistling because they wanted to keep things
                simpe. If you'd want to use CW or AM, then you also have to change
                frequencies from the ones they (ARRL) posted in order to get the
                carrier within the allowable bandwidth. That can get real interesting
                when you have a rig that automatically adjusts the frequency when you
                switch from USB to CW, like the 897 does.

                Yes, your code oscillator trick is much nicer than mic-whistling.
                Thanks for posting a solution.

                I've actually been using a 1kHz tone generated by a piece of software
                like SpectranPlus since the rigs are all hooked up to the computer.

                > Just my opinion, I am not a lawyer, and all that.

                Same here.

                73,
                --Alex KR1ST
                http://www.kr1st.com
              • Ed Thierbach
                ... I think that s a great approach. While I admire it, I don t like to assume that enforcement agencies share it unless I hear em say it. So the reply
                Message 7 of 20 , Jul 1, 2005
                  >> I have yet to see any rule or interpretation that allows equivalent
                  >> spectrum signatures.
                  >>
                  >
                  > I'm sure you're right. I just try to be practical about it without
                  > trying split hairs on the law.

                  I think that's a great approach. While I admire it, I don't like to
                  assume that enforcement agencies share it unless I hear 'em say it.
                  So the reply directly from Riley was great news, and will let me keep
                  some hairs intact. :-)

                  > You are so ready for that regulation by bandwidth proposal from the
                  > ARRL. :-)

                  :-) :-) I admit, I do like it much better than what we've got now.

                  > I've actually been using a 1kHz tone generated by a piece of software
                  > like SpectranPlus since the rigs are all hooked up to the computer.

                  That's another good solution; thanks for sharing it. Given Riley's
                  reply, though, we'll all probably just go back to the TUNE button. :-)

                  > 73,
                  > --Alex KR1ST

                  73 to you as well, and thanks for the good discussion.
                  -Ed- AB8OJ
                • Dean Gibson AE7Q
                  Here s how I look at it: Whether you briefly transmit a CW signal in the middle of a 60m channel, transmit a 1500Hz tone on USB, or transmit an AM or FM
                  Message 8 of 20 , Jul 1, 2005
                    Here's how I look at it:

                    Whether you briefly transmit a CW signal in the middle of a 60m channel,
                    transmit a 1500Hz tone on USB, or transmit an AM or FM carrier in the
                    center of the channel without modulation, the emitted signal is
                    identical. The FCC does not get brownie points or additional funds from
                    Congress for going after people who "set their knobs wrong" but
                    otherwise transmit a signal that is indistinguishable from another
                    license who "set his knobs correctly". The FCC has an extremely limited
                    budget and has better things to do (not to mention that the FCC *has no
                    way of knowing* how your radio's knobs are set). The INTENT of the
                    rules is to allow or prevent certain distinguishable emissions. HOW
                    those emissions are generated is an artifact of the transmitter that is
                    used, and the emissions coding referenced in FCC rules part 2 reflects
                    that (see
                    http://edocket.access.gpo.gov/cfr_2004/octqtr/47cfr2.201.htm). Since
                    the normal purpose of transmitting a signal is to modulate it with
                    information, the emissions coding (eg, J3E for SSB voice) reflects that
                    as well. However, when you tune up a transmitter with a brief carrier,
                    you are not transmitting any information (the third letter of the
                    emissions coding is "N"), and except for SSB, you are not modulating the
                    signal (the second letter of the emissions coding is "0") and most of
                    the emissions coding become equivalent; eg: N0N = A0N = F0N = J3N (with
                    a single tone).

                    Note that use of the term "CW" can be confusing, since it refers both to
                    an unmodulated carrier (eg, N0N, A0N, F0N), and also to Morse code
                    transmittion of information (eg, A1A); the emissions coding makes a
                    distinction. In other words, on the 60m channels, a brief N0N emission
                    is OK; an A1A (Morse code) emission is not.

                    -- Dean

                    On 2005-07-01 10:23, Ed Thierbach wrote:

                    >>>I have yet to see any rule or interpretation that allows equivalent spectrum signatures.
                    >>>
                    >>>
                    >>I'm sure you're right. I just try to be practical about it without trying split hairs on the law.
                    >>
                    >>
                    >
                    >I think that's a great approach. While I admire it, I don't like to assume that enforcement agencies share it unless I hear 'em say it. So the reply directly from Riley was great news, and will let me keep some hairs intact. :-)
                    >
                    >
                  • kw7dsp
                    ... What the FCC Rules Say: §97.303(s) An amateur station having an operator holding a General, Advanced or Amateur Extra Class license may only transmit
                    Message 9 of 20 , Jul 1, 2005
                      --- In FT897@yahoogroups.com, Dean Gibson AE7Q <yahoo1@m...> wrote:
                      > How about one OFFICIAL quote to support your position?

                      What the FCC Rules Say: §97.303(s)

                      An amateur station having an operator holding a General, Advanced or
                      Amateur Extra Class license may only transmit single sideband,
                      suppressed-carrier (emission type 2K8J3E) upper sideband on the
                      channels 5332 kHz, 5348 kHz, 5368 kHz, 5373 kHz and 5405 kHz.
                      Amateur operators shall ensure that their transmission occupies only
                      the 2.8 kHz centered around each of these frequencies. Transmissions
                      shall not exceed an effective radiated power (ERP) of 50 W PEP. For
                      the purpose of computing ERP, the transmitter PEP will be multiplied
                      with the antenna gain relative to a dipole or the equivalent
                      calculation in decibels. A half-wave dipole antenna will be presumed
                      to have a gain of 0 dBd. Licensees using other antennas must
                      maintain in their station records either manufacturer data on the
                      antenna gain or calculations of the antenna gain. No amateur station
                      shall cause harmful interference to stations authorized in the
                      mobile and fixed services; nor is any amateur station protected from
                      interference due to the operation of any such station.

                      --------------------------------------

                      Everything I had to say is right here. My post was not a flame but a
                      fact filled informational post ment to counter the disinformation.
                      This is straight from the FCC. Riley often returns the simple answer
                      of "I see no problem with it" almost a form letter. The FCC Rules do
                      not agree. They will not take your license for what Riley says, but
                      the will for what the rules say, and these channels are shared with
                      with Government users just waiting for us to screw up and use
                      anything other then USB.

                      The actual docket is .....................

                      RM-10209
                      Amendment of Parts 2 and 97 of the
                      Commission's Rules Regarding an Allocation of a Band near 5 MHz for
                      the Amateur Radio Service

                      5250-5400 kHz Band (RM-10209)
                      C. Decision
                      31. We believe that frequencies in the 5250-5400 kHz range may
                      be useful for completing disaster communications links at times when
                      the 3 and 7 MHz bands are not available due to ionospheric
                      conditions, and appreciate the desire of the amateur radio community
                      to assist with disaster communications. At the same time, since the
                      majority of the affected users are Federal Government licensees with
                      homeland security responsibilities, we give considerable weight to
                      the concerns NTIA has expressed about the potential for interference
                      to these users. Thus, we conclude that it is not reasonable to
                      grant ARRL's original request for the whole of the 5250-5400 kHz
                      band. However, as indicated above, NTIA has reviewed its
                      assignments and has found that 5 channels are lightly used and could
                      be used on a secondary basis by amateur stations. While we
                      recognize that these five channels will not give the amateur service
                      the 150 kilohertz of spectrum in the 5000 kHz range it originally
                      asked for or the flexibility to use multiple transmission modes,
                      this appears to be the best compromise available to give the amateur
                      service access to new spectrum while assuring the Federal Government
                      agencies that their use is protected. We also concur with NTIA's
                      basic proposals that amateur service operations on these channels be
                      limited to SSB-SC modulation, upper sideband voice transmissions
                      only, with power not to exceed equivalent of 50 W PEP transmitter
                      output power into an antenna with a gain of 0 dBd, or 50 W e.r.p.
                      These operating rules will decrease the interference potential
                      between amateur stations and Federal Government users. Accordingly,
                      we are amending sections 2.106, and 97.303 of our rules to provide a
                      secondary allocation to the amateur service on the channels 5332
                      kHz, 5348 kHz, 5368 kHz, 5373 kHz and 5405 kHz as specified by NTIA,
                      and to require that amateur operations be limited to an effective
                      radiated power (e.r.p.) of 50 W, and emission type 2K8J3E, upper
                      sideband voice transmissions only centered on each frequency. For
                      the purpose of computing e.r.p. the transmitter peak envelope power
                      will be multiplied with the antenna gain relative to a dipole or the
                      equivalent calculation in decibels. A half wave dipole antenna will
                      be presumed to have a gain of 0 dBd. Licensees using other antennas
                      must maintain in their station records either manufacturer data on
                      the antenna gain or calculations of the antenna gain. In addition,
                      because we are permitting amateur stations to transmit on 5 discrete
                      frequencies and limiting the transmission mode to single sideband
                      only, dividing the band into smaller sub-bands to be used for other
                      emission types is not practical or necessary. Lastly, we will
                      permit these frequencies to be used by amateur service licensees
                      with a General Class, Advanced Class, or Amateur Extra Class
                      operator license. We believe that the limited number of frequencies
                      and the emission restriction will protect against interference to
                      primary service operations.
                    • Dean Gibson AE7Q
                      ... You previously said: It is amazing that so many ... have a license, which says they know the rules or will before using, and this thread is filled with
                      Message 10 of 20 , Jul 2, 2005
                        On 2005-07-01 23:53, kw7dsp wrote:

                        >--- In FT897@yahoogroups.com, Dean Gibson AE7Q <yahoo1@m...> wrote:
                        >
                        >
                        >My post was not a flame but a fact filled informational post meant to counter the disinformation.
                        >
                        You previously said: "It is amazing that so many ... have a license,
                        which says they know the rules or will before using, and this thread is
                        filled with misinformation about the 60 meter rules. They are simple,
                        straight forward and easy to understand."

                        Well, I certainly would have thought so before this thread. Tell me,
                        what is the difference, signal-wise, between:

                        1. A 1500Hz tone modulating a USB signal (J3E) for a channel in question.
                        2. An unmodulated CW signal at the center of the channel (N0N).
                        3. An unmodulated FM carrier at the center of the channel (F0N).
                        4. An unmodulated AM carrier at the center of the channel (A0N).

                        If you claim there is a difference, tell us how ANYONE monitoring the
                        signal can tell the difference. For the purpose of this question,
                        assume that the entire radio monitoring capability of the US Gov't (FCC,
                        military, CIA, and NSA) are sitting right outside my house with the most
                        sophisticated monitoring equipment available, ready to pounce when I
                        transmit a N0N, F0N, or A0N emission instead of a J3E emission.
                        However, they are not allowed to use mind readers, telepaths, or aliens.

                        >
                        >They will not take your license for what Riley says, but they will for what the rules say, ...
                        >
                        That makes absolutely no sense at all. First of all, who is "they" but
                        effectively Mr. Hollingsworth??? Second, when you ask a gov't lawyer
                        for a "legal opinion" (as I did; see the eMail) in the field for which
                        he is responsible for enforcement, and you get a reply, that reply can
                        be safely acted upon. It's the same principle as with the IRS, when you
                        ask for a "determination letter" (the IRS's version of a legal opinion
                        regarding its own rules); that "determination letter" is legally
                        binding upon the IRS. Even if issued in error.

                        -- Dean
                      • Howard Small
                        I realise this topic gets at people but it doesn t have anything to do with 897s really nor does it (FCC rules and everyone s interpretations of them) have
                        Message 11 of 20 , Jul 2, 2005
                          I realise this topic gets at people but it doesn't have anything to do
                          with 897s really nor does it (FCC rules and everyone's interpretations
                          of them) have anything to do with those list members who are not in
                          the US.

                          Could we please let it drop now?

                          Thanks,

                          Howard, VK4BS
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