While they don't propose our 2.8 kilohertz bandwidth limitation for MF and HF data after elimination of the symbol rate, they do leave the door open for generalized emission bandwidth limitations. There is a lot wrong with this NPRM but nothing that we can't sort out in the long comment period that they have established for this.
Apparently there was very little thought given to this NPRM after Cross drafted it two years ago and sent it to the WTB front office.
However, in jimmying up our comments on the TAC noise study this week, I noticed that the first task given by FCC to the TAC in 1999 when the TAC was first created by FCC was to study the noise floor in various bands and report back. The TAC is just now getting to that task. So speed is not a well-established characteristic of this agency in particular.
We will have some recommendations for the EC and the Symbol Rate Committee members who are still on the Board shortly.
73, Chris W3KD