> [2] - Page 11: "PACTOR 3 ... is now permitted and ... has an occupied
> bandwidth of 2.4 kilohertz."
PACTOR III is *NOT* currently permitted under the rules. Its use has
been *overlooked* by enforcement organizations as it *absolutely* can
not be justified under the *dual standard* in 97.307(f)(3) which has
both 300 baud and 1000 Hz shift limits.
In order for PACTOR III to occupy 2.4 KHz with a symbol rate less than
300, the shift [F(max)-F(min)] *must* be greater than 1000 Hz (about
*twice* the limit in this case).
I think that the ARRL have made a solid case for BW up to 2400 Hz in
view of /Mark Miller/ and currently permitted PACTOR 3,
ARRL have only made a case for 2400 Hz *in absence of enforcement*
against PACTOR III. *DO NOT* reward them for violating the
regulations.
73,
... Joe, W4TV
On 11/24/2013 1:07 PM, Kai wrote:
I've now studied the ARRL proposal and take the position that symbol
rate language is indeed unnecessarily restrictive for modern advances in
the state of the amateur radio arts. So most of the ARRL proposal looks
OK to me, except for their proposed bandwidth number. To change that,
here is the basis for my argument, based on language in the ARRL
proposal, and adding no new matter to the proposal:
[1] - Note 23 on page 11: "As the commission noted in Mark Miller,
supra, changing the rules to prohibit a communications technology that
is currently in use is not in the public interest." [note 21: See the
Order, Mark Miller, DA 08-1082, 23 FCC Rcd. 7449 (2008).
[2] - Page 11: "PACTOR 3 ... is now permitted and ... has an occupied
bandwidth of 2.4 kilohertz."
[3] - Page 6: "the dual "wideband" and "narrow band" nature of the 10
meter band ..." presents an argument for a higher bandwidth in the
28.0-28.3 segment listed in Table (c) p 14.
[4] - The "Unspecified code" language already exists in 97.205(c) (5)
and (6), so per /Mark Miller/ it would remain.
I think that the ARRL have made a solid case for BW up to 2400 Hz in
view of /Mark Miller/ and currently permitted PACTOR 3, and including
the "unspecified digital code" language - because all of these are
currently permitted in the present regulations and "As the commission
noted in Mark Miller, supra, changing the rules to prohibit a
communications technology that is currently in use is not in the public
interest."
But they have not made a case for 2.8 kHz, except at 10m.
The ARRL proposed changes rightly delete the baud rate language and
instead they propose to change 97.205(c) (3) so it reads: "A RTTY or
data emission using a specified digital code listed in 97.309(a) of this
part may be transmitted. A RTTY, data or multiplexed emission using an
unspecified digital code under limitations listed in 97.309(b) of this
part also may be transmitted. The authorized bandwidth is 2.8 kHz.
Except for the 2.8 kHz figure, all of that language already exists in
97.205(c) (5) and (6), including the "unspecified digital code"
language, so per /Mark Miller/ ruling it should remain.
I can see a 2.4 kHz BW limit below 28 MHz, and 2.8 kHz above 28 MHz.
If I make comments, they will be to support the ARRL proposal in
general, EXCEPT to modify the ARRL proposal such that Table (c) make no
changes, then in (3) change 2.8 to 2.4; do not delete (4) but instead
use the language proposed (3) with the 2.8 kHz limit.
The net effect of the proposal is most clearly shown in the Table of
page 2, the "Maximum Symbol Rate" column would be deleted, and in the
"Authorized Bandwidth" column, the entry for 160-12 m would be 2.4 kHz
(ARRL wants 2.8 kHz), and the 10 m entry would be 2.8 kHz.
Respectfully and 73,
Kai
On 11/24/2013 10:42 AM, Dick Kriss wrote:
I recall from the past somebody prepared a very good argument for the
FCC to turn down a request and then posted it and people could sign on
and there name and call would be added to the comments.
If someone would prepare such an argument, I would sign on but I do
not feel qualified to counter the lawyered up RM-11708. I do question
the true intent.
Dick AA5VU
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