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

[Kok Chen]

On Nov 24, 2013, at 7:46 PM, Joe Subich, W4TV wrote:

> > So, 500 Hz definitely does not mesh with the current rules.
> 
> 500 Hz does not mesh with the maximums *implied by* the current
> rules. However, *it does* confirm with the Commission's stated
> intent when they established the current rules and the explicit
> rule which applies to automatically controlled digital transmissions.

Joe, I still don't think that works.

The FCC has always allowed 850 Hz shift at 45.45 baud from the moment hams were first permitted to use FSK.  It was initially the *only* thing allowed, and it was later (February 1956) that they allowed 170 Hz shift.  It is a historical precedence.  And it has never been taken away.

So, I don't think it is correct to say that 500 Hz is their intent.  

73
Chen, W7AY