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

[Joe Subich, W4TV]

 > [2] - Page 11: "PACTOR 3 ... is now permitted and ... has an occupied
 > bandwidth of 2.4 kilohertz."

PACTOR III is *NOT* currently permitted under the rules.  Its use has
been *overlooked* by enforcement organizations as it *absolutely* can
not be justified under the *dual standard* in 97.307(f)(3) which has
both 300 baud and 1000 Hz shift limits.

In order for PACTOR III to occupy 2.4 KHz with a symbol rate less than
300, the shift [F(max)-F(min)] *must* be greater than 1000 Hz (about
*twice* the limit in this case).

> 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,

ARRL have only made a case for 2400 Hz *in absence of enforcement*
against PACTOR III.   *DO NOT* reward them for violating the
regulations.


73,

    ... Joe, W4TV


On 11/24/2013 1:07 PM, Kai wrote:
> 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
>> _______________________________________________
>> RTTY mailing list
>> RTTY at contesting.com
>> http://lists.contesting.com/mailman/listinfo/rtty
>>
> _______________________________________________
> RTTY mailing list
> RTTY at contesting.com
> http://lists.contesting.com/mailman/listinfo/rtty
>