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

[Al Kozakiewicz]

I believe the RTTY variants are limited in bandwidth by stipulation of the maximum shift frequency outlined elsewhere in the regulations.

I don't get that same warm fuzzy with respect to paragraph 4.

Al
AB2ZY

Sent from my iPhone

> On Aug 9, 2016, at 8:09 PM, William Lisk <wglisk at outlook.com> wrote:
> 
> 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
> 
> -------------------------------------------------------------
> 
> _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.
> 
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