[Elecraft] RM-11708: CW and RTTY users please read

[Michael Adams]

Fred:

Re factoid 4: Are you certain that comments seeking a bandwidth restriction on part of the CW/data subband would be ignored?

In the discussion accompanying the NPRM, the FCC rather explicitly invited comments as to whether a limitation is appropriate for a portion of the bands, specific frequencies meriting protection, etc. provided that such were supported by some technical reasoning

Given that a specific question was asked, I'd think that direct responses to the specific question would be considered as relevant.

While I'm not schooled in the provisions of the APA, I don't think American regulatory bureaucracy has yet deteriorated to the point where a federal agency is required to ignore responses to questions they asked in the development of regulation.

--
Michael Adams | mda at n1en.org

________________________________
From: Fred Jensen <k6dgw at foothill.net>
Sent: Aug 21, 2016 4:13 PM
To: Richard Thorne; Elecraft Reflector
Subject: Re: [Elecraft] RM-11708: CW and RTTY users please read


<factoid#4>Actions by the FCC are governed by the Administrative
Procedures Act [APA] which requires a somewhat slow process that
includes multiple opportunities for public input</factoid#4>

The matter at hand in NPRM-11708 contains exactly two questions:  1)
Should the symbol rate limit of 300/sec at 97.309(f) be eliminated?; and
2) Should a specified limit of 2.8 KHz occupied bandwidth in the RDS be
imposed?

Those are the ONLY two issues that can be decided in this proceeding.
Any comment/request outside those two issues will be ignored.  Folks,
read that again.  If you want to be heard, you must speak to those two
issues.  Anything else is irrelevant to the proceeding at hand.