[I submitted the following comments.]
I oppose this proposal:
1) It places undo restrictions on experimental digital systems.
2) Technology is moving too rapidly to regulate by modulation
designators, regulation should be by bandwidth/emission mask, with
varying bandwidth for each band and segments for automatic vs. manual
transmissions.
3) Deal with automated transmission by limiting permitted segments
for automatic stations (as is done now). Set expectation for
non-automatic stations in those segments, that automated stations
may not recognize their presence.
More clearly define intentional vs. incidental interference for both
automated and non-automated stations, especially in light of the
vagaries of propagation on HF. Remind operators that incidental
interference is to be expected, intentional interference is not.
4) Remove the artificial limits between data, image, and voice for
digital transmissions. (e.g. voice can now be sent in 1100 hz via
FDMDV -- there should be allowances for up to 8 kHz. in the
traditionally 'voice' portions of the bands below 29 mHz., more
bandwidth above 29 mHz.) Digital transmissions are all 'data'
regardless of the content, whether voice, image, or text/data.
5) 160 meter band does not have the same regulatory segregation as
other bands and the amateurs have worked out a workable bandplan.
6) Clarify encoding vs. encryptions. Especially as relates to
authentication and control vs. obscuring the meaning of the
message(s) in the transmission.
Sincerely,
John D. Hays, K7VE
