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All,
Here are the responses I received, in July, from 
K1ZZ, and W4PWF my Roanoke Division director. 
Ben - WB2RHM
From: Ben Antanaitis - WB2RHM [mailto:wb2rhm@wb2rhm.com]
Sent: Wednesday, July 24, 2013 1:33 PM
To: w4pwf@arrl.org; N2ZZ@arrl.org; n2cop@arrl.org
Subject: RE: "asking the FCC ?to apply to all 
amateur data emissions below 29.7 MHz the 
existing bandwidth limit, per §97.303(h), of 2.8 kHz.? 
Per the ARRL news:
***************************************************************************************
On the motion of ARRL West Gulf Division Director 
Dr David Woolweaver, K5RAV, on behalf of the Ad 
Hoc Symbol Rate Rule Modernization Committee, the 
Board directed ARRL General Counsel Chris Imlay, 
W3KD, to prepare a Petition for Rule Making with 
the FCC seeking to modify §97.307(f) to delete 
all references to symbol rate. The Petition would 
ask the FCC ?to apply to all amateur data 
emissions below 29.7 MHz the existing bandwidth 
limit, per §97.303(h), of 2.8 kHz.? 
The committee determined that the current symbol 
rate restrictions in §97.307(f) ?no longer 
reflect the state of the art of digital 
telecommunications technology,? and that the 
proposed rule change would ?encourage both 
flexibility and efficiency in the employment of 
digital emissions by amateur stations.? The Ad 
Hoc Symbol Rate Rule Modernization Committee was 
dissolved with the thanks of the Board. 
***************************************************************************************
Gentlemen,
I hope that the process on this idea is not too far down the road to TURN BACK.
In my opinion, what you are proposing will have 
the potential to destroy the data segments that 
we now use in the HF bands.........  eg PSK is 
structured, and voluntary frequency segmented, to 
allow many many QSOs to operate in a vastly 
smaller piece of spectrum than 2.8KHZ per 
signal.  RTTY operators can chat, work DX, and 
Contest in something around 300Hz bandwidth and 
they operate in their 'piece of the spectrum pie in each HF band........... 
Now you are thinking of requesting that frequency 
hogging 2.8KHz, uncontrolled data signals, of any 
nature, spread out over the entire DATA Mode 
spectrum of the HF bands.......   blasting away 
the possibilities for hundreds of CW/PSK/Hell/RTTY/MSK operators....... 
If you follow through on this ill-advised and 
ill-concieved plan, you might as well cancel any 
ARRL PSK, RTTY, or CW contests you current 
sponsor...........   The entry numbers in these 
contests, DXing activities, and rag-chewing in 
these band segments and modes has steadily grown, 
not diminished, over recent 
years............   Why propose something that 
has the oh so easy potential to 'jam' and 
'crowd-out' current spectrum users???? 
I protest this idea most strongly, and will file 
comment against the proposal, with the FCC, should it get that far. 
73,
Ben Antanaitis  -  WB2RHM
ARRL Life Member
ARRL 50 Year Member
***********************************************************************
From: "Sumner, Dave,  K1ZZ" <dsumner@arrl.org>
Subject: RE: "asking the FCC "to apply to all amateur data em
        issions below 29.7 MHz the existing bandwidth limit,
        per §97.303(h), of 2.8 kHz."
Date: Wed, 24 Jul 2013 15:22:28 -0400
To: "Ben Antanaitis - WB2RHM" <wb2rhm@wb2rhm.com>,
        "Craigie, Kay (President)" <n3kn@arrl.org>
Cc: "Bodson, Dennis (Dir, Roanoke)" <w4pwf@arrl.org>
Ben, I will forward your comments to your Director, Dennis Bodson, W4PWF.
However, you should welcome a limit being placed 
on the bandwidth of HF digital data signals. At 
the present time there is no bandwidth limit 
whatsoever on digital data signals as long as the 
300 baud limit is observed. It is legal today for 
a signal with multiple carriers, each with 
multiple-bit-per-symbol modulation, to be 
considerably wider than 2.8 kHz. The 2.8 kHz 
value accommodates digital emissions now in 
common use while putting a cap on the bandwidth 
that a station could occupy in the future.
73,
David Sumner, K1ZZ
Chief Executive Officer, ARRL
****************************************************************************************
 
From: "Dennis Bodson" <bodsond@verizon.net>
To: "'Ben Antanaitis - WB2RHM'" <wb2rhm@wb2rhm.com>,    <w4pwf@arrl.org>,
        <N2ZZ@arrl.org>,        <n2cop@arrl.org>
Subject:
 RE: "asking the FCC "to apply to all amateur data emis
        sions below 29.7 MHz the existing bandwidth limit, per
        §97.303(h), of 2.8 kHz."
Date: Wed, 24 Jul 2013 18:45:53 -0400
Ben:
Thank you for your input relating to the subject 
topic. Dave Sumner has responded to you. His 
response is accurate. I would like to call to 
your attention Dave?s column in the September 
2013 issue of QST. You should be receiving it 
within the next 30 days. This article presents, 
in my opinion, a complete and in-depth 
explanation of how we got to where we are today 
and why it is appropriate to move forward.
Regards,
Dennis Bodson, W4PWF
ARRL Director
Roanoke Division
 
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