I share the concerns of those have participated in this thread. A
suggestion: Many of us understand the basic problem but are not good at
framing the issues in the right technical language or giving the FCC
what they are asking for in their request for comments. Perhaps some
among us who feel competent in these areas could post a proposed comment
on this reflector that could be used by others as the basis of a comment
filing.
Thanks.
Bill/KC2EMH
On 8/8/2016 10:27 AM, Michael Adams wrote:
Just to repeat and expand upon something I wrote earlier:
The FCC's comments make pretty clear that they accept the arguments for
removing the symbol rate limit, and that they think that removing the bandwidth
limit on at least some of the HF amateur spectrum is beneficial to
experimentation (and, presumably, alleviates the potential for a future
petition if/when wider data modes come to pass).
However, they left the door open for feedback to impose a bandwidth limit on
_part_ of the CW/data subbands....but they also were rather explicit in
requesting technical reasons for doing so.
Nothing in RM-11708 proposes moving or expanding the automated subbands.
In my feedback, I suggested that a 500Hz limit below the automated subbands
would be appropriate to reduce interference issues between narrow and wide
signals. I'm sure there are others on this reflector who could put together a
more technical / eloquent reasoning for that.
I opted for 500Hz to accommodate all of the narrow-ish modes I'm aware of that are in use
today, and to avoid the potential for conflict from users of those modes. I opted for a
"below the automated subbands" demarcation for simplicity.
Regardless of whether you agree or disagree with my idea, I would encourage
folks who want to submit similar ideas to focus strictly on
technical/interference reasoning, and for their ideas to accommodate some space
for wideband data.
It's clear to me that complaints about Winlink or general fear about wideband
data (which is already allowed all the way down to the bottom of the band under
Part 97, FWIW) will probably be ignored as out-of-scope if submitted as a reply
to the NPRM.
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