[RTTY] Question about RM-11708/Docket No. 16-239 NPRM

[William Lisk]

Could someone help me understand the Commission's line of reasoning 
about the intrinsic bandwidth limitations of the schemes listed in 
97.309(a)?If the symbol rate limit is removed, It would appear that data 
could be transmitted at any desired rate using any published technique, 
as described in 97.309(a)(4).Further, it would seem that any technique 
could quickly be published online and thus comply with this rule.

Thanks for any insights.

Bill/KC2EMH

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_From the Conclusion section of the NPRM_:

We do not, however, propose a bandwidth limitation for data emissions in 
the MF and HF bands to replace the baud rate limitations, /because the 
rules’ current approach for limiting bandwidth use by amateur stations 
using one of the specified digital codes /[those listed in 
97.309(a)—shown below]/to encode the signal being transmitted appears 
sufficient to ensure that general access to the band by licensees in the 
amateur service does not become unduly impaired./

*§97.309   RTTY and data emission codes.*

(a) Where authorized by §§97.305(c) and 97.307(f) of the part, an 
amateur station may transmit a RTTY or data emission using the following 
specified digital codes:

(1) The 5-unit, start-stop, International Telegraph Alphabet No. 2, code 
defined in ITU-T Recommendation F.1, Division C (commonly known as 
“Baudot”).

(2) The 7-unit code specified in ITU-R Recommendations M.476-5 and 
M.625-3 (commonly known as “AMTOR”).

(3) The 7-unit, International Alphabet No. 5, code defined in IT--T 
Recommendation T.50 (commonly known as “ASCII”).

(4) An amateur station transmitting a RTTY or data emission using a 
digital code specified in this paragraph *may use _any_ technique whose 
technical characteristics have been documented publicly*, such as 
CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.