ARRL Executive Committee Okays Filing Symbol Rate Rule Modernization Petition
The ARRL Executive Committee has authorized ARRL General Counsel Chris Imlay, W3KD, to file a Petition for Rule Making on the League’s behalf calling for the deletion of symbol rate references for data emissions in the HF bands. The League will be unable to file its Petition, however, until the partial federal government shutdown ends, and the FCC reopens. The EC met October 5 in Aurora, Colorado.
The League’s Petition, still in the final stages of preparation, would substitute an authorized bandwidth of 2.8 kHz for all data emissions in the bands below 30 MHz. Current FCC rules limit data emissions to a symbol rate of 300 baud below 28 MHz and to 1200 baud on 10 meters. The current limits date to 1980, when US amateurs first were authorized to use ASCII, reflecting the state of the art back then, which, the League points out, has been overtaken by technology. After discussing alternatives to the 2.8 kHz limit, the EC okayed filing the petition as drafted, subject to any final editorial changes.
At its July meeting, the ARRL Board of Directors, on the recommendation of the Ad Hoc Symbol Rate Rule Modernization Committee, directed Imlay to draft a Petition for Rule Making with the FCC seeking to modify §97.307(f) of the Amateur Service rules to delete all references to symbol rate. The Petition would ask the FCC “to apply to all amateur data emissions below 29.7 MHz the existing bandwidth limit, per §97.303(h), of 2.8 kHz.” In digital systems “symbol rate” refers to the number of times per second that a change of state occurs. The ARRL chose the 2.8 kHz bandwidth, since the FCC already has applied it to emissions on the channelized 60 meter band and because it’s slightly wider than the data mode bandwidths currently in use by amateurs on HF.
The Ad Hoc Committee had determined that the current symbol rate restrictions in §97.307(f) “no longer reflect the state of the art of digital telecommunications technology,” and that the proposed rule change would “encourage both flexibility and efficiency in the employment of digital emissions by amateur stations.” ARRL Chief Executive Officer David Sumner, K1ZZ, discussed the symbol rate issue in detail in his September 2013 QST “It Seems to Us” editorial. “The guiding principle for our use of the spectrum allocations to the Amateur Radio Service is cooperation in the sharing of access to a limited resource,” Sumner wrote.
On another FCC-related matter, Imlay noted that while reply comments in ET Docket 13-84, the FCC’s reexamination of its RF exposure rules, are due November 1, the League will not be able to complete its review of filed comments until the FCC reopens. Once the review has been completed the League will determine whether any of the comments require an ARRL response.
Imlay further noted that the FCC has yet to take action in ET Docket 12-338 to formally reflect the Final Acts of the 2007 World Radiocommunication Conference in its rules. Comment deadlines were more than 6 months ago. The Commission also has taken no action on the ARRL’s November 2012 petition to implement a 472-479 kHz allocation, which stemmed from WRC 2012. Imlay said the subject may be considered in a Further Notice of Proposed Rule Making in the proceeding.
Imlay told the EC that FCC action is expected soon on WT Docket 12-283 and WT Docket 90-209, which contain several proposals to amend rules governing the administration of Amateur Radio examinations. The League has argued against a proposal to reduce the number of volunteer examiners required at an exam session from three to two.
The EC reviewed a draft FCC filing prepared by ARRL Chief Technology Officer Brennan Price, N4QX, that supports recommendations approved last month by the FCC Advisory Committee for World Radiocommunication Conference 2015. The EC authorized Price to file the comments, subject to any final editorial changes.