Bonnie's argument will be moot when the FCC issues its erratum. However, the only reason Pactor III can be used is that its technical characteristics are documented publicly. See http://www.arrl.org/FandES/field/regulations/techchar/ There it states that Pactor III is J2D. Dave -----Original Message----- From: Andy Oppel [mailto:andy_oppel@earthlink.net] Sent: Tuesday, November 28, 2006 12:50 AM To: arrl-odv Subject: [arrl-odv:14845] Re: Petition to Reconsider? We have a previous member, KQ6XA claiming that Pactor III is G1D / G1B / G1C and not J2D and therefore not affected by the rule change. Her arguments sound convincing and I just don't know enough to be able to see the error in them (assuming there is one). It's this soft of debate that underscores the folly of regulating by emission mode -- we waste time and energy arguing over what mode is being used than where wider signals should be placed in the band allocations. -- Andy Oppel, N6AJO At 09:11 AM 11/24/2006, Tom Frenaye wrote:
At 11:06 AM 11/24/2006, w3kd@aol.com wrote:
Kay, good points, all. Sadly, however, there is only a very limited time to file (or not file) a petition for reconsideration. It would be due by the 15th of December. Since the timetable is statutory, FCC can't waive it. So we must fish or cut bait by the 15th of December; a short fuse indeed for membership input.
Since I sent out the last summary of input on WT 04-140 a week or so ago, another 250+ comments have come in to the bandplanning@www.arrl.org e-mail address - and are all available here -> http://www.arrl.org/members-only/mailresp.html
I've attached an easier-to-use summary of those last 250+ comments as a MS Word file. I'll also send summaries to the Directors who previously wanted just to see input from their own Divisions.
My comments on this last bunch:
1) Of the 250+ comments, 90 are from the Northwestern Division. The WWA Section Manager sent out a message to his SM mailing list encouraging members to send input. Most other Divisions had less than additional messages.
2) The strongest input comes from wideband digital users (like Pactor III).
3) There are much fewer comments from people who say they like the changes - this last batch of input is pretty one-sided, saying that the ARRL has to ask the FCC to reconsider some portions of 04-140. The comments were much more focused than the first group.
4) At least ten people sent in copies of letters they have sent to FCC Commissioners, to their Congressmen and their Senators. I'm not sure that's a good thing, even if most letters were pretty factual (and too technical).
5) A large portion of the Winlink/Pactor III comments and Congressional letters appear to have been generated by encouraging it from the Winlink folks(K4CJX).
6) Our web article said that we'd take input until a week after WT 04-140 was published in the Federal Register - until Nov 22nd. There are still some comments coming in today though.
The newest group of e-mails doesn't change my mind - I do think we need to file a Petition for Reconsideration. Even if the FCC comes out with a statement about J2D, we should probably plan to include a request to fix it in the petition. I still think we should ask for SSB to go down only to 3700 (or 3650 as a fall back), and allow auto control in a small segment to be consistent with the current practice on other bands. There are dozens of messages with very quotable input from hams involved in EmComm in state or local EOCs that can be used to support the digital issues.
-- Tom
===== e-mail: k1ki@arrl.org ARRL New England Division Director http://www.arrl.org/ Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093 Phone: 860-668-5444