On Nov 23, 2013, at 4:44 PM, Joe Subich, W4TV wrote:
> 9) In their appendix - at page 15 - in their proposed revision of
> 97.307(f)(3) - ARRL add "A RTTY, data or multiplexed emission
> using an unspecified digital code under the limitations listed in
> this part may also be transmitted." This change is completely
> unsupported by the petition and would eliminate the need to
> document "unspecified digital codes" effectively providing *data*
> *encryption* and gutting any possibility of enforcement by either
> the Commission or self-enforcement by the amateur community.
Joe is correct (at least it is also my interpretation)...
This part falls under the "outside the scope of the petition" (some lawyers can
correct me if this is incorrect) since it is not mentioned anywhere in the body
of the petition (I have not yet found it mentioned anywhere outside the
Appendix itself -- it suddenly popped up as a proposed change to the rules):
Basically, plead to the Commissioners that the part about "unspecified code"
that ARRL added to 97.307 (b) (3) (the last page, 4 paragraphs from the end) be
completely stricken.
The 2.8 kHz part of that paragraph is a separate item that needs technical and
operation explanation, but the part about "unspecified code" is a legalistic
thing, if I am not mistaken.
Why is "unspecified code" important? Since the ARRL does not explain anywhere
in their petition what they added the rule, we can for example state that
1) as it is currently stands, hams already receive a lot of interference from
automatic stations, including hams who are "trying to send an emergency
message" -- this phrase is the Amateur Radio equivalent of "it is for the kids"
HI HI -- use it liberally :-),
2) to communicate with the station operators of the offending stations, we need
to know *who* the station operator is, and
3) for ham radio to be self policing, we need to be able to report the
offending stations.
We can neither achieve 2) or 3) if we cannot decode the contents of their
messages. We cannot do that if the "unspecified code" is not publish as
required today by 97.307 (b) (3) and 97.309(a).
The ARRL petition basically renders 97.309(a) void by adding the permission to
use "unspecified codes" to 97.307 (b) (3).
73
Chen, W7AY
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