While the FCC has authorized international data stations experimentally, those were “never conceived to engage in revenue operations indefinitely as an alternative to regular spectrum allocations and transparent, public license assignment procedures.”

In a separate email to Radio World, Kobb noted recent news coverage of shortwave applications for private data communication services such as instant stock trading; examples are here and here. Kobb emphasized that the objectors have no reason to think Parable is associated with those particular projects.

But regardless of audio programs that Parable may transmit, the three told the FCC that licensing a point-to-point message facility this way would be “an impermissible excursion around formalizing an international private data service or updating existing rules to accommodate it.” So they say the commission FCC should require Parable to certify that “no nonpublic, non-broadcast, nondisclosed, encrypted, confidential or clandestine data messages shall be sent over the proposed station.”

They added that the FCC needs to update its “hoary Part 73F rules, some dating from the 1930s and now without any articulable public interest basis.” These include “excessive” minimum required power level and a prohibition on domestic service. “Rule changes might embrace data communications under an expanded scope of service.” //

Parable’s facility would operate on the 5.9–15.8 MHz international shortwave bands with 15 kW power. Two 10 kW Amplifier Systems transmitters (main and standby) would feed 550 feet of 5-inch Comscope pressurized coax to a “super high gain” TCI log-periodic antenna system. The latter would consist of three towers, including two at 184 feet, with antenna power gain of 18.0 dBi, which the application notes is “a multiplier of 63.1.”