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

[Joe Subich, W4TV]

 > 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.

If one *must* provide an accommodation for the 2200 Hz garbage systems,
the way to do it is to make the bandwidth limit 2200 Hz only in the
automatic control subbands while making the standard 500 Hz elsewhere.
That meets the "Miller" test (not a ruling) by not eliminating the
operation where it is generally and simultaneously answering the
continued need for protection from wideband interference acknowledged
by ARRL's own comments (Footnote 11, page 7).

I still maintain that correct approach to dealing with 2800 Hz wide
data modes to to eliminate the restriction on "RTTY, data" in those
portions of the amateur bands where "Voice, image" transmission is
permitted and allow data bandwidths of up to 2800 Hz in those areas.
Not only would such a step provide an outlet for the PACTOR III/IV
garbage, it would also allow amateur experimentation with and use of
documented protocols such as STANAG and M110 for digital voice all
while representing a significant simplification of the amateur rules
by eliminating regulation of modes as well as protecting narrow band-
width modes from interference by wide bandwidth modes in significant
portions of the amateur bands.

73,

    ... Joe, W4TV


On 11/25/2013 12:35 AM, Kok Chen wrote:
>
> 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
>
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