[KCDXC] Link for FCC Filing RM-11708 REJECT Sample

[bfrahm at st-tel.net]

On Sat, 30 Nov 2013 03:08:19 +0000, Jeff Blaine <Jeff.Blaine at epak.com>
wrote:
........
> This situation would have been completely hopeless if the original
> proposal verbiage (unspecified codes) was not amended and pulled.  But

**That was a regrettable oversight in drafting the rulemaking request.
Apparently came about by maintaining some VHF-area language that didn't
belong.

> don’t we have the similar situation with this device in that it's not a
> specified com method - meaning either you have to buy a similar unit
(best
> case) or you can't read the link at all (worst case)?

**We could go back to the old days when RTTY sent a CW ID every 10
minutes, but I think nowadays it'll be sufficient to 'get in touch with an
OO or capable monitor' if a problem-causing signal is busting the agreed-on
limits.
 
> I am not sure why we would want to bet the future of the non-phone
> band-space on effective self-policing - if we can't monitor the com
link? 

**The monitoring can come from equipped observers as above - conceptually
not different from nowadays where lots of stakeholders are incapable of
demodulating numerous modes.

And if for reasons which I can't fathom, wideband data operators start
running roughshod over the bottom 65 and can't be persuaded to behave, the
rules could always revert to less bandwidth than 2.8 (or whatever is
ultimately decided with this NPRM).  The risk of this (to me) unlikely
scenario is offset by the reward of experimentation with and use of fast
data.  I will be surprised if droves of ops use such modes regularly.

Regardless of your concerns over the entire NPRM, I suspect you agree that
eliminating the 300 baud/no bandwidth restriction rule as a speed limit,
and going to a more 21st century limit is a good move.  And then..... 
we're just kicking the can down the road until the awkward nature of
fitting digital voice and other modes into the rules becomes so nightmarish
that something really different will need to be done.  And that something
in my estimation should be Regulation by Bandwidth (or no {federal}
regulation at all like most of the rest of the world).  But as was learned
a few years ago it's going to take some more time for US hams to get used
to that idea, live with ever more contorted FCC language and the glacial
speed with which that language usually gets modified, and come around to
embracing the adaptability of such a spectrum usage paradigm where the
stakeholders call the shots. 

I appreciate your interest in this Jeff, and I sure want my cw hangouts
available !

73  Bruce