[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
