| NU9N
RESPONSE TO RILEY HOLLINGSWORTH'S ADVISORY NOTICE - 04-08-03 : Dear Mr. Hollingsworth, I have been tempted many times to speak with you regarding the FCC position on SSB Hi-fi experimentation as well as the shared excitement and unfortunate grief that I have experienced as an active participant with such experimentation. However, I have been reluctant to do so (until now) because I believed that for the most part, Amateur Radio operators should be able to settle their differences in a diplomatic and responsible manner. Furthermore, knowing that you and the commission have better things to do than get in the middle of every single dispute, I was counting on the fact that, for every negative remark that's given to SSB experimentation, there are hundreds of positive remarks! This aspect of the hobby has generated excitement and even some new license holders interested in high-quality SSB audio, for which reason they even entered the fraternity. Since you have contacted me regarding this subject, and in response to the certified letter that you sent, received on 04/07/03, I would like to respectfully respond and open a dialog with you. I will comment on each issue that you addressed... RH "The Commission has received numerous complaints regarding the operation of your station. The complaints allege that your station is transmitting an 'Enhanced Single Sideband' emission with a bandwidth wider than necessary and contrary to good engineering practice." JA Riley, I know that there are a select few who would love to see any SSB experimentation involving improved audio characteristics, banished from planet earth. If these stations would spend as much time contributing to the "'Art" and "Goodwill" of amateur radio, as they do complaining about everyone else, not only would the Amateur Radio service richly benefit and not be looked upon so negatively, but 10kHz of our precious bandwidth could be reclaimed! The very folks that are complaining here, are themselves in violation of the "Minimum Power" rule, which IS clearly defined! They all come on the air with their full legal limit, 2.7kHz audio and occupy, in some instances up to 10kHz via their I.M.D. products. They move within 3 to 4kHz from the group participating in audio experimentation and then complain that we are interfering with them. The real issue here is that they are interfering with us! They willfully move into a passband they know is already occupied instead of just starting up a few kHz higher. And, most of the time, the band is clear enough that they could start up their QSO just about anywhere! But they would rather create a false case against us to somehow justify getting us off the air completely. I'm growing tired of their unfounded and illegitimate complaints and suggest that you remind them that this is a shared service that they are interfering with. If they can't hold their bashing tongues, then maybe they should be put on notice for the good of the Amateur Radio Service! RH "While precise measurements of bandwidth may be somewhat complex and the reception of a signal depends, to some extent, on the engineering characteristics of the receiver being used, it is important for you to understand that Section 97.307(a) of the Commission's Rules requires that 'no Amateur station transmission shall occupy more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good Amateur practice (emphasis added).' Wide band overly-processed audio, especially when coupled with high intermodulation levels of certain amplifiers, results in the use of bandwidths extremely inconsiderate of other operators. Transmitting an emission that occupies more bandwidth than necessary is contrary to the Commission rules and to the expectation that the Amateur Service be largely self-regulated." JA I have yet to find in the FCC rulebook, or elsewhere, any definitive explanation of exactly what the term "Necessary Bandwidth" means... It can be argued that "Necessary Bandwidth", as applied to "Desired Quality" can vary from 2.4kHz to 6kHz depending on how "Quality" is defined. As you may know, fidelity is directly proportional to bandwidth. There is no escaping this fundamental law of audiophonics and how our ears perceive speech characteristics. This is one of the reasons why the Amateur Radio AM mode is still alive and well... Fortunately, quality modulation is still important to many, and more and more SSB operators are finding that SSB does not have to sound like a "tin-can" anymore, even at a 3 or 4kHz bandwidth. Additionally, the "emission type" being used, J3E, can have many technical variations, i.e. 3K00J3E, 4K00J3E, 6K00J3E, etc... So, if the emission type 6K003JE is being used, then 6kHz is the corresponding bandwidth being used. The J3E specification in and of itself only describes the way that the signal is being modulated and the information is carries. Not bandwidth! As you know, there is no absolute bandwidth rule or law, nor should there be. This is only Amateur Radio for heaven sake. And experimentation is fundamental at the very crux of this hobby, as it has always been and should continue to be !! Also, "Good Amateur Practice" is another one of these hard to define terms. In essence, I think that most would agree that good amateur practice as relevant here for SSB would be simply this: Minimum power needed, low I.M.D. products, good carrier suppression, courteous and professional operating, a helpful attitude, and a desire to contribute to the Amateur Radio fraternity in a way that has a positive effect. I have tried very hard to meet all of these criteria, despite the few who have tried to discourage me from raising the bar of quality in the name of Amateur Radio experimentation. By the way, I agree that over-processed audio can be very irritating. But this is true of any station, wide medium or narrow bandwidths, as overprocessing usually results in increased I.M.D. and splatter. But this is certainly not unique to just extended SSB, as can be heard on all phone segments of all of the HF bands. Just listen to a DX contest where "2.4kHz Narrow-band" operators splatter above and below their carrier point by 6kHz or more each direction resulting in occupied bandwidths of 12kHz plus!! In fact, those who have complained about my operations are more than likely using more RF spectrum via splatter & I.M.D. than I am with a pure and clean Hi-fi modulated signal. RH "The Amateur Service is allocated spectrum that must be shared by thousands of individual stations. The rules require that control operators make the most effective use of Amateur frequencies. The Amateur Service is not a substitute for the broadcast service, and the frequencies allocated to the Amateur Service were not allocated for a "broadcast quality" audio emission or sound. Section 97.101 sets out the general standards Amateur stations must follow:" (a) In all respects not specifically covered by FCC rules each Amateur station must be operated in accordance with good engineering and good Amateur practice. (b) Each station licensee and each control operator must cooperate in selecting transmitting channels and in making the most effective use of the Amateur Service frequencies (emphasis added) No frequency will be assigned for the exclusive use of any station. "Furthermore, Section 97.101(d) states that no Amateur operator shall willfully or maliciously interfere with cause or interference to any radio communication or signal, and Section 97.101 applies to all Amateur stations at all times. When an Amateur station transmits a voice emission that occupies more bandwidth than necessary in order to achieve a 'great audio' sound, that emission occupies spectrum that could be utilized by several other Amateur stations. To occupy more bandwidth than necessary in a heavily used Amateur band is not only extremely inconsiderate, but is contrary to the requirement that Amateur operators cooperate in the utilization of frequencies allocated to them and make the most effective use of them. Such shortsightedness on the part of the control operator that causes a station to transmit an 'enhanced Single Sideband' emission inevitably leads to ill will between operators and likely will result in petitions for rule making requesting that the Commission establish bandwidth limitations for Amateur station emissions." JA FCC Part 97 in no way ever addresses how an Amateur Station is supposed to "sound". Whether good or bad, the overall "sound" is very subjective to say the least. A "great audio sound" is no more a violation than a "crappy audio sound" that's equally as wide via splatter! I don't know how I could ever come close to achieving real "Broadcast Quality" audio on SSB, since AM broadcasters have 19kHz of RF spectrum at their disposal (9.5kHz audio bandwidth) and are allowed to broadcast. This is not my desire, nor anyone else's for SSB. However, I do know that Amateur Radio AM is alive and well. And some of these stations are occupying this bandwidth with their old refurbished commercial AM transmitters, which by the way I think is great! This is an important and nostalgic part of our hobby. But let me point out, that the SSB experimentation that some of us have been playing with is less than 1/3 of the bandwidth used by some AM stations. It's more efficient, has no carrier, and no opposite sideband to deal with. Yet, it has a good frequency response through careful processing and good quality is still achieved while maintaining a bandwidth within 6kHz. This is something that AM just can't do! This is an important step forward for SSB, even though some do not agree with its implementation. Above all however, is the fact that those of us experimenting with Hi-fi SSB are producing some of the cleanest SSB signals on the planet, simply because clean sounds better, aside from any technical reasons or good engineering practices. I and many others believe this is a huge contribution in "advancement of the radio art". I and others have received hundreds if not thousands of e-Mails from Amateur operators who applaud our efforts and who are interested in this aspect of the hobby. Additionally, I have to date, over 27,000 hits on my NU9N.COM SSB Audio website in the last year alone! DSP technology is changing the way SSB operators are operating. And weather wide or narrow, DSP produces relatively clean signals compared to its analog counterpart. Look at any of the Amateur radio sales outlets like Heilsound, W2IHY, Kenwood, Yeasu, etc... in the last three years... It's amazing how many operators have become bored with the same old tin-can audio of our analog yesteryear, in favor of a new exciting aspect of this hobby that is multiplying exponentially. Hey, SSB can sound good, and still be SSB and still be relatively narrow when comparing it to AM !!! This aspect of the hobby need not lead to "ill will". Those who do not like good quality audio don't have to listen or participate if they don't want to. It's their choice if they want to feel "ill" over this. But they should realize that this hobby is for everyone and they should give us some slack. I'm not a DXer, but I respect DXing. I'm not a contester, but I respect contesting. I'm not into bashing others on-the-air about their operating practices or their disrespect for us, but I respect the opinions of those who disagree with my philosophies about Amateur Radio and the art of great audio. All I ask for is the same operating privileges (that I worked hard for) as everyone else. I'm not interested in starting fights, interfering with others, or making a big deal out of nothing like some. I love this hobby and my Amateur friends too much to waste time complaining about everything that don't meet my personal standards. The HF Amateur frequencies were originally allocated before anyone ever heard of "Single Sideband", when AM was the standard phone mode. Broadcast quality was never referenced to simply because no one had yet heard of the "Tin-Can" sound of single sideband. Yes, modes have changed, the bands are much more crowded now than they were back then (although I remember the ARRL getting nervous in the 80's about Amateur Radio dying because of the low influx of new HF operators) but should we abandon the spirit of Amateur Radio that pushes new and exciting ways of operating because of a few whiners that petition the FCC? We have as much stake in this hobby as they do... and perhaps more since so many are re-defining the 'State-of-the-Art" in Amateur SSB audio technology, including numerous transceiver manufacturers. Also, don't let these complainers fool you into thinking that we are "ripping out" our transceiver's filters. We are using stock transmitting gear that was FCC type accepted and approved. No one group or individual "owns" a frequency. I absolutely agree. And it is because of this fundamental rule that I get so frustrated with stations who insist on using a frequency just 4kHz above mine ( at 40 dB / 9 signal strengths ) after I have established my frequency long before they start operating. This is inconsiderate of them, or anyone that moves into someone else's passband! Do they own the frequency above me? It's first come, first serve no matter what bandwidth is being used... Period! However, it would be advantageous for the hobby to set aside a frequency or two, just for extended SSB operations, so there could be acknowledged partitions between those who want to participate and those who do not, just like the AM calling window at 14.286, or the SSTV frequencies at 14.225, etc... Most SSB audio enthusiasts usually stay on just one or two frequencies anyway out of respect for the other groups of interest on the 20m band. I and other audio enthusiasts never operate near the DX windows of any band if using an extended SSB mode. Oh yea, there's a "DX Window" that's acknowledged on every band also! There must be a place in Amateur Radio for Extended SSB operations... It only makes sense to me, and I'm sure to many others as well. RH "A hallmark of the Amateur Service is its contribution to the advancement of the radio art. As new technologies have become available to Amateur radio operators or as they have developed them, control operators have endeavored to introduce these technologies into Amateur Service communications in a way that does not have a negative impact on other Amateur stations or their operations. In many cases, this has been done by operating on uncrowded Amateur spectrum or at times when spectrum used by many Amateur stations is not heavily utilized. The many complaints that we are receiving regarding the operation of your station leads to the conclusion that your operation is having a negative impact on the Amateur Radio Service." JA Riley, you know as well as I do that we can't please everybody, no matter how careful we are. For every complaint you may receive about me or others, you are only hearing one side of the story. I have NEVER started a QSO using extended SSB audio if a frequency within my desired passband was occupied! I either move to a clear window and ask if the frequency is in use, or I simply narrow my TX passband to accommodate the operating conditions. This is just common sense which, unfortunately, these individuals who are complaining to you don't have evidently. You will probably never hear the positive side of what I (we) have done, since you only get letters from disgruntled operators who make it their business to clean-up activities that do not suit their personal taste. Again, for every complaint that you may receive about what I do, there are hundreds, if not thousands who support it passionately! However, I understand that you must address the complaints as they are received. I think it's time that some of us who put up with jammers and trouble makers start getting a little oil on our squeaky wheel also, even though I still prefer to not make a federal case out of it...(No pun intended). RH "In conclusion, no frequencies in the Amateur Service are designated as "wideband audio" frequencies, either by Commission rule or in any informal band plans. Accordingly, you are requested to fully review the rules referenced above, make certain that your station conforms to them and that you operate in the best interests of the Amateur Radio Service as a whole." JA In concluding, let me boast for a minute about what I have done the last five years for the Amateur Radio community: - Assisted hundreds with their audio setup, and every aspect of it from AC, DC, RF, RFI, Grounding, Cabling, EQing, Compression, Gating, Hum/Buzz cures, etc... - Developed and perfected on-air recording/playback techniques to aid in audio setup - Spent hundreds of hours performing spectral analysis and e-Mailing results to participating stations - Developed and maintain a very intensive website devoted to SSB Hi-Fi Audio ( I lost count of the hours and sleepless nights spent developing this site ! ) - Answer on average, 50 e-Mails a week regarding SSB audio related questions ( I've spend my first hour every day doing this and have for the past year or so ! ) - I have helped and assisted K9EID, W2IHY and KF6DX in some manner or another enhance their products for the Amateur Radio market. - Given my heart, my soul and my "blood sweat and tears" ( not to mention many bottles of Extra strength Excedrin ) in an unselfish attempt to better relations and build lasting relationships through the experimental aspect of Amateur Radio. - Administered ARRL VEC testing sessions - Helped countless new Amateur operators get their antennas and equipment set up I received one "OO" notice, and it was a complimentary notice of excellent operating practice. Okay, my boasting session is over. How many of those who complain about me have given this much to the Amateur community? What have they done to better relations and foster good will? Who have they helped? All I ever hear from them is "gripe, gripe,gripe" !!! If I were a short-wave listener and ran across this bunch, I would want nothing to do with Amateur Radio and neither would you! I'll bet you have heard and seen it all in your business... HI Riley, I know the rules well. I am always respectful, even under fire. I'm sure there have been a few occasions in the past where I was clearly wrong, or acted out of frustration. We all have. But again, I love this hobby too much to let a few naysayers ruin this hobby for me. I have even made it clear on my website, that we are responsible for the quality of our signals as related to I.M.D. and splatter and always emphasize on the side of caution. I have done some very in-depth analysis and study of my on-air signal characteristics and can produce my results upon request. I can assure you that my carrier suppression, I.M.D. products and bandwidth are perfectly legal and engineered as perfect as possible within any outlined operating parameters. Additionally, I had an "OO" using a $20,000 Hewlett Packard RF spectrum analyzer give me a green light regarding my operations. He assured me that for 6K00J3E, my signal was impeccable with virtually no I.M.D. products, excellent sideband suppression as well as a beautiful scope pattern and great audio. Besides, I.M.D. products are not desirable for what we are trying to accomplish anyway, since I.M.D. products sounds terrible. Again, this would be counterproductive for what I and others are trying to accomplish with our desired audio quality in the first place! I respectfully request that you and/or the ARRL consider allocating a similar plan for SSB, to the one that AM has in place, by which those of us who are experimenting with extended SSB audio can do so with some immunity from those who prefer to operate narrower. I believe this would be beneficial to all Amateur operators on both sides of the issue. And there are two sides to this issue! If these complaints persist, it's time to put up an RF fence just like one would do with a pesky neighbor. I hate to see it come to this also and would prefer no fence, but what else can be done? Shut down the experimental and adventurous aspect of the Amateur Radio Service for a few complainers? God forbid! If you would like to have a live dialog with me regarding this issue, my phone number is listed below. I would enjoy and welcome a constructive and sensible discussion with you. If you would rather leave me with your office number, I would be more than glad to give you a call as well. Cordially, John Anning - NU9N |