[CW] ARRL's Reply Comment re Baud Rate Petition

[Donald Chester]

ARRL has submitted reply comments regarding their petition.
 
http://apps.fcc.gov/ecfs/document/view?id=7521064769  
 
 
They ignore a couple of things. (1) The INTENT of the baud-rate limit,
albeit based on outdated 1980s technology, was to limit the bandwidth of
data signals transmitted in the CW-RTTY sub-bands to that of then-existing
RTTY  signals, without enumerating any specific b/w limit. The only
justifiable reason for preserving the current mode sub-band structure is to
provide a protected zone for narrow-bandwidth operation, like CW, PSK and
narrow shift RTTY. These would no longer be protected zones if 2.8 kHz wide
signals were permitted inside the sub-bands. The bandwidth of narrow-shift
Baudot and ASCII RTTY is approximately 500 Hz, and that was the limit the
baud rate was intended to preserve.
 
(2) They say the change would have very little effect on CURRENT users of
the bands, but once the 2.8 kHz limit is written into the rules, ANY future
type of emission that could by some stretch of the imagination claim itself
to be digital data, would be allowed to run a signal with the same bandwidth
as a SSB phone signal, in the CW/RTTY/data sub-bands.
 
The do not address the contradiction of why mode sub-bands would remain
justified at all, if any type of wide-band modes are to be allowed in the
protected portions.  Then they go on to claim that without sub-bands, the
only alternative would be the defunct regulation-by-bandwidth proposal,
which they declare was not appropriate after all, resulting in the
withdrawal of their original bandwidth petition. This fails to address the
situation on 160m, where there are no sub-bands nor bandwidth limits either.

Either we have sub-bands segregating wide and narrow bandwidth modes, or we
don't, period. Nevertheless, issues including, but not limited to,
compliance and enforcement would make enumerated bandwidth limits of any
kind in the HF bands, a dangerous precedent. 60m is a special case
irrelevant to this issue. There must be a way to limit signals in the "cw"
bands to their originally intended bandwidths, without imposing specific
limits. The ARRL proposal fails both tests.
 
 
Don k4kyv		 	   		  


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