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

[Kok Chen]

On Nov 24, 2013, at 8:39 PM, Kai wrote:

> QRM is not raised in the ARRL ruling, so we should somehow find language shows BW of even 2200 Hz is already harmful, so we don't want them to increase beyond that (except above 28 MHz maybe).

I can see the attractiveness of setting 2200 Hz in 97.307(b)(3) (assuming '221 does not get altered in this go round after the FCC lawyers are done with the petition), it is almost precisely the same as stating:

"lets leave things exactly as they were before the ARRL started all this idiotic mess."

Basically, any equipment that were not legal yesterday will still not be legal in the future.  Any equipment that were legal yesterday will still be legal and completely functional tomorrow.  (Correct, STANAG modems will still not be legal -- you will need to go over to MARS frequencies to use it.)

Anyhow, the main argument for settling on 2200 Hz is to tell the commissioners that it keeps everything the same and still comply with the ARRL's stated desire to get rid of the Symbol Rate requirement.  The automatic station keeps exactly what they currently have. Keyboard guys get exactly the same QRM level -- no more and no less than during CQWW RTTY.  

Think of it as a perfect political compromise.  Nobody wins, nobody loses, and lawyers get their billable hours.   

It is almost the same as if the ARRL had withdrew the petition, but they get to save face this time, not like during RM-11306.  We go back to washing dishes and taking out the garbage.

The only real change to 97.307 would be to effectively legitimize encryption (not formal one-way encryption, but encryption through trade secrets and DMCA).

73
Chen, W7AY