It sure as heck seems that way Doug. Actually you can thank the fortunately for us now retired Bill Cross for this. He never understood the Symbol Rate Petition despite repeated efforts to explain it to him. He told me two years before this NPRM hit the streets and about six months before he retired that he had drafted an NPRM that eliminated the symbol rate limit but did not propose a maximum bandwidth on data emissions. It took the Wireless Bureau front office two years to make no changes to that proposal and to issue the darn thing. We took a huge amount of heat for our petition which did include a bandwidth limit. It will be interesting to see if there is that much opposition to the FCC proposal that does not contain one. 73, Chris W3KD On Mon, Aug 15, 2016 at 1:14 PM, Doug Rehman <doug@k4ac.com> wrote:
So is this a new FCC tactic to dissuade the filing of petitions?
Doug
K4AC
*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] *On Behalf Of *Christopher Imlay *Sent:* Monday, August 15, 2016 1:10 PM *To:* Price, Brennan, N4QX <bprice@arrl.org> *Cc:* Frenaye, Tom, K1KI <frenaye@pcnet.com>; arrl-odv <arrl-odv@arrl.org> *Subject:* [arrl-odv:25580] Re: RM-11708
Tom Frenaye and Board members, attached is a briefing memo I sent to the Board in December of 2013 about our Petition for Rule Making. As Brennan notes, our argument in our Petition is not changed from our argument now. I hope the attached memo helps you deal with any pushback from members about the FCC NPRM but it is important to note that our Petition had* two* points: It would (1) Remove the symbol rate limitation for data emissions in the band segments where RTTY and data emissions are now permitted; and (2) Establish a maximum bandwidth for data emissions of 2.8 kHz on MF and HF bands (where none currently exists, except for some unattended operations). The MF and HF segments subject to this new maximum bandwidth limit are: 160 meters; 3.5-3.6 MHz; 7.000-7.125 MHz; 30 meters; 14.00-14.15 MHz; 18.068-18.110 MHz; 21.0-21.2 MHz; 24.89-24.93 MHz; and 28.0-28.3 MHz. Both components of our petition were necessary and neither alone is sufficient.
The FCC proposal has only *one* point: it would remove the symbol rate limitation. It would allow unlimited bandwidth emissions in the RTTY/data subbands. Not good. So don't allow ARRL to take the heat for this FCC proposal, because it is literally half-baked.
73, Chris W3KD
On Sun, Aug 14, 2016 at 5:34 PM, Price, Brennan, N4QX <bprice@arrl.org> wrote:
TomF,
ARRL's position is unchanged since the publication of this FAQ on point:
http://www.arrl.org/rm-11708-faq
If we wish to reply to N9NB's latest advocacy directly, we may agree with him that some limitation on wide bandwidth data emissions is necessary and appropriate. On the other hand, N9NB is proposing a regulation-by-bandwidth approach of the type that was resoundingly rejected last decade. We've taken a regulation-of-bandwidth approach for data emissions that actually provides narrow bandwidth emissions more relative protection than they receive now.
That's the best I can do with family by Niagara Falls.
73 de Brennan N4QX/VE3
Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. Original Message From: Frenaye, Tom, K1KI Sent: Sunday, August 14, 2016 16:52 To: arrl-odv Subject: [arrl-odv:25571] RM-11708
TomG/Brendan/Chris -
N9NB's comments about RM-11708 are getting pretty broad distribution. Will we be posting a web story that helps to counter it? Or, is there a summary of points available I can use for responding to the people that have contacted me? I think I understand much of it but it's a complex topic and I want to be sure I get it right.
Thanks
-- 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
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Christopher D. Imlay
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W3KD@ARRL.ORG
-- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG