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

Joe Subich, W4TV lists at subich.com
Mon Dec 23 11:47:04 EST 2013


 > 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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