Roger,

I will let Bonnie respond, but let me add my 2 cents.  Paragraphs 15 
through 19 address the rule changes which allow image 
emissions.  Paragraph 19 has most of us confused because while it 
says "we will revise our rules to clarify that the 500 Hz limitation 
applies only to the emission types we are adding to the definition of 
data"; J2D was already in the definition of data before this 
revision.  They also say "the 500 bandwidth limitation will not apply 
to other data emission types or amateur service bands in which a 
higher symbol rate or bandwidth currently is permitted.  There is a 
footnote to that sentence that references 97.305(c), 
97.307(f)(3)-(8), (13).  This would indicate that the intention of 
the revision to the definition is to add image emissions that have a 
maximum occupied bandwidth of 500 Hz.  I am not sure why J2D was 
moved into the less than 500Hz area.  I would only be guessing if I 
gave my hypothesis.

73,

Mark N5RFX


>Actually, it is mostly Greek to me. I admit it. Are you saying that
>the above quote, beginning with the numeral "19" came out **after** the
>ARRL interpreted the regs as prohibiting Pactor 3? Or are you simply
>disagreeing with ARRL on the interpretation of the FCC regs?
>
>And how does this affect Olivia and MT-63? Since these modes were
>presumably included in the original definition of "Data" are they
>unaffected as well--i.e. 1Khz Olivia and MT-63 would be permitted below
>30 Mhz?
>
>de Roger W6VZV


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