[RTTY] RM-11708

[Michael Adams]

Note this paragraph:

"12. While we tentatively conclude that a specific bandwidth limitation for RTTY and data emissions in the MF/HF bands is not necessary, we nonetheless request comment on whether we should establish emission bandwidth standards for amateur service MF/HF RTTY and data emissions. Commenters favoring such action should address what the maximum bandwidth should be, the basis for the particular limitation the commenter proposes, and whether the limit should apply across the bands or only in particular subbands. Commenters should explain the grounds for departing from the generally applicable standards."

Reading between the lines, it seems like the FCC hasn't ruled out the possibility of accepting a bandwidth limit on part of the data bands, provided there is some spectrum available for experimentation with wider transmissions, and provided that arguments for such a limit focused strictly on points they feel is within their purview....minimizing harmful interference, for example.

Back during the original RM-11708 comment period, didn't someone put together a pretty decent argument about why it's a bad idea for wide- and narrow-band signals to seek to exist on the same spectrum, due to interference issues?

If so, I'd think that dusting off that argument, proposing that a _simple_ narrow-band limit be imposed on part of the data subband (perhaps 500Hz below the automated frequencies?), while leaving some space available for the kind of experimentation the FCC seems receptive to allowing, and omitting rants against certain organizations or users of that spectrum, might be well-received at the Commission.

(Note that I'm not saying there aren't issues; just that this might not be the time to highlight those issues, given the specific request made.)

-- 
Michael Adams | mda at n1en.org