I'm certainly not the right person to suggest a detailed technical argument.
I'm more of an appliance operator...but I do have experience from my day job in
getting the attention of legislators and regulators.
I'd think that if one or two detailed technical arguments against narrow- and
wide-band data attempting to coexist in the same spectrum were submitted,
supported by several dozen shorter responses, it should be enough to give the
FCC a reason to impose a bandwidth limit on part of the data bands.
I am reluctant to suggest precise language for the shorter responses. If many
folks just copy-paste the same wording into the ECFS form...such efforts are
too easy to dismiss. Using individuals' own words to make essentially the same
point is more effective.
(Note that the anti-boilerplate point has been raised on a Winlink reflector,
in their effort to get comments in support of the NPRM in.)
For those who need an outline to work from, try this:
* Express concern about interference that inevitably happens when wide- and
narrowband signals attempt to operate in the same spectrum. (There's no need
to attempt detail if you don't feel comfortable doing so.)
* Suggest a maximum bandwidth for part of the data subbands.
* Suggest what portion of the subbands that bandwidth should apply to.
...and leave it at that.
In my case, I suggested 500Hz below the automated subbands. I think there are
folks on this reflector who feel that 400Hz is a better limit. Enthusiasts of
CW or other digital modes might have their own opinions on the matter.
Rather than torture those details, I'll suggest relying on your preferences in
expressing such an opinion, with a caveat that simple is better this time
around.
--
Michael Adams | mda@n1en.org
-----Original Message-----
From: RTTY [mailto:rtty-bounces@contesting.com] On Behalf Of William Lisk
Sent: Monday, 8 August, 2016 10:51
To: rtty@contesting.com
Subject: Re: [RTTY] If you care about CW and RTTY - time is of the essence
I share the concerns of those have participated in this thread. A
suggestion: Many of us understand the basic problem but are not good at
framing the issues in the right technical language or giving the FCC what they
are asking for in their request for comments. Perhaps some among us who feel
competent in these areas could post a proposed comment on this reflector that
could be used by others as the basis of a comment filing.
Thanks.
Bill/KC2EMH
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