Chris, I for one would appreciate receiving a version of the "talking points." Right now (so far), I haven't received any comments on the petition either way, but I'd like to be prepared to give a reasonably correct version of what is actually proposed. 73, Greg, K0GW On Tue, Nov 26, 2013 at 3:09 PM, Chris Imlay <w3kd@aol.com> wrote:
Here is the Erratum that I just filed with FCC a few minutes ago. This addresses those concerns related to the allegation that the symbol rate petition would permit unspecified digital codes at HF, which the Symbol Rate Committee did not intend to do, but the error crept into the final report.
However, there is some substantial feedback being received at Headquarters about the Petition in other respects, most notably with respect to the 2.8 kilohertz proposed occupied bandwidth limit for data communications. The principal *misunderstanding* found in these complaints is related to the classification of digital voice. According to the FCC rules, digital voice is classified as voice, not data. This petition, if granted, would not allow digital voice where voice is not now permitted by the rules. Furthermore, where data is now permitted by the rules, there is no maximum bandwidth. ARRL proposes one in the Petition. So we are not compromising the RTTY operations by this proposal. In fact, the Petition would insure for the first time that data communications in the same subbands do NOT usurp the limited spectrum available. Brennan Price has provided Dan Henderson with some "talking points" that will hopefully clarify this for people who inquire. If it would be helpful in dealing with member inquiries, a version of this could be provided to you as well.
73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ, K1ZZ <dsumner@arrl.org> To: arrl-odv <arrl-odv@arrl.org> Sent: Tue, Nov 26, 2013 12:54 pm Subject: [arrl-odv:22106] RM-11708 erratum
In one respect the criticism being voiced about our RM-11708 petition has some merit. This is with regard to the addition of "unspecified digital codes" language to 97.307(f)(3). This change is not discussed at all in the body of the petition and was not intended to be included in the proposal. Chris is filing an erratum with a corrected appendix later today.
The revised proposed 97.307(f)(3) will read: "Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The authorized bandwidth is 2.8 kHz."
By the way, in 1995 the FCC clarified that "specified digital code" is any digital code that has its technical characteristics publicly documented.
All of us who reviewed the draft and missed this are deeply sorry for the confusion thus caused.
73, Dave K1ZZ
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