[RTTY] Hints and tips on how to file comments on RM-11708

[Kai]

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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