Marty, nothing in the petition affects any HF subbands other than those to which the current 97.307(f)(3) and (4) apply, which are the subbands in which RTTY/data emissions are permitted. The phone/image emission subbands are not affected except on 160 meters, where the two happen to coincide (i.e. both RTTY/data and phone/image are authorized in the entire band). Phone is defined as “speech or other sound emissions,” whether analog or digital. Data is specifically defined as “telemetry, telecommand and computer communications emissions.” Section 2.201 may be helpful if Part 97 is not sufficiently clear. Dave From: Imlay, Chris, W3KD Sent: Tuesday, November 26, 2013 2:33 PM To: Woll, Marty, N6VI; Sumner, Dave, K1ZZ; arrl-odv Subject: Re: [arrl-odv:22109] Re: RM-11708 erratum Marty, I think the answer to your question is no, there is no inadvertent effect on digital voice modes which are currently permitted in the HF bands, though the symbol rate committee members are better able to address that point than I am. This erratum is both urgent and delicate, however, in terms of the perception of our petition as it was originally filed; and incorporating any other changes now is (in my view) unnecessary and risky. 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<mailto:W3KD@ARRL.ORG> -----Original Message----- From: Marty Woll <n6vi@socal.rr.com<mailto:n6vi@socal.rr.com>> To: 'Sumner, Dave, K1ZZ', K1ZZ' <dsumner@arrl.org<mailto:dsumner@arrl.org>>; 'arrl-odv' <arrl-odv@arrl.org<mailto:arrl-odv@arrl.org>> Sent: Tue, Nov 26, 2013 2:14 pm Subject: [arrl-odv:22109] Re: RM-11708 erratum Before we file the erratum, is there any chance our petition could inadvertently affect any digital voice modes currently permitted in the HF bands (i.e., the old is-it-phone-or-is-it-data question)? If so, should our amendment contain an explicit exclusion for digital voice? 73, Marty N6VI ________________________________ From: arrl-odv-bounces@reflector.arrl.org<mailto:arrl-odv-bounces@reflector.arrl.org> [mailto:arrl-odv-bounces@reflector.arrl.org<mailto:arrl-odv-bounces@reflector.arrl.org?>] On Behalf Of Sumner, Dave, K1ZZ Sent: Tuesday, November 26, 2013 9:54 AM To: arrl-odv 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 _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> http://reflector.arrl.org/mailman/listinfo/arrl-odv