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@n1en.org
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