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

To: William Lisk <wglisk@outlook.com>
Subject: Re: [RTTY] Question about RM-11708/Docket No. 16-239 NPRM
From: Al Kozakiewicz <akozak@hourglass.com>
Date: Tue, 9 Aug 2016 18:28:34 +0000
List-post: <rtty@contesting.com">mailto:rtty@contesting.com>
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@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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