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Re: [RTTY] How to submit a reply to a RM-11708 comment?

To: rtty@contesting.com
Subject: Re: [RTTY] How to submit a reply to a RM-11708 comment?
From: "Joe Subich, W4TV" <lists@subich.com>
Date: Mon, 23 Dec 2013 11:47:04 -0500
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>

> If you believe the ARRL memorandum, you have something like until
> January 7 to submit a reply, I may have forgotten the exact date
> though.

ARRL's own "Comments of Petitioner" were filed over the weekend:
http://apps.fcc.gov/ecfs/document/view?id=7521063715.  They provide an
attractive target for Reply Comments - particularly the assertion that
the petition "would *not* [their emphasis] ... B. Have any effect on CW operation in the HF bands." or "the petition would not initiate any
broad plan to convert to regulation of emissions by bandwidth rather
than by emission type."

Both assertions are open to vigorous debate.  As is the wisdom of
rejecting 80 years of a regulatory framework which specifically seeks
to protect narrow bandwidth modes against interference from wide
bandwidth modes as reaffirmed by the Commission a recently as WT Docket 04-140 which states in 13 (page 9): " ... we note that eliminating or relaxing the bandwidth limitation would de facto eliminate the separation of narrow bandwidth and wide bandwidth emissions. We believe that separation of emission types by bandwidth is accepted in the amateur service as a reasonable means to minimize interference on shared frequencies and bands ..."

73,

   ... Joe, W4TV


On 12/23/2013 11:13 AM, Kok Chen wrote:

On Dec 23, 2013, at 8:01 AM, Peter Laws wrote:

I was under the impression that there was a separate period for Reply
Comments?  Not true?

I have already seen a couple of replies to Comments.  I don't know if they had used 
"Comments" or "Reply to Comment" in their submission, but they do target 
specific comments.

If you believe the ARRL memorandum, you have something like until January 7 to 
submit a reply, I may have forgotten the exact date though.

I don't know for certainty, but I suspect that you do not need to always oppose a Comment 
in a Reply.  I think you can also "discuss" an earlier Comment which you agree 
with.

73
Chen, W7AY

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