ARRL Executive Committee to Consider Numerous Regulatory Issues
The ARRL Executive Committee (EC) will face an agenda heavy on FCC and regulatory issues when it meets Saturday, October 5 in the Denver, Colorado, area.
Among action items, the EC is expected to consider the filing of a Petition for Rule Making, now in draft, seeking to delete restrictions on symbol rates for data communication and to establish a 2.8 kHz maximum authorized bandwidth for HF digital data emissions. At its July meeting, the ARRL Board of Directors directed ARRL General Counsel Chris Imlay, W3KD, to prepare a Petition for Rule Making with the FCC seeking to modify §97.307(f) 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.”
The Board 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 CEO David Sumner, K1ZZ, explained the Board’s action on symbol rate regulation in his September 2013 QST “It Seems to Us” editorial.
The EC also will consider authorizing comments on an FCC Public Notice on recommendations approved by the WRC-15 Advisory Committee. The Committee will consider approving the filing of comments with the FCC that express concerns about expanding proposed radiolocation use of the 77.5 to 78 GHz band beyond on-vehicle applications to, for example, fixed roadside applications. The comment deadline is October 11, although the FCC shutdown may change that date.
The EC also will continue to evaluate strategies to improve the FCC’s Amateur Radio enforcement program and consider filing reply comments on FCC ET Docket 13-84, regarding a reexamination of RF exposure regulations (reply comments are due November 11, subject to the FCC shutdown). While the FCC proposals do not alter existing RF exposure limits, they do call for the elimination of existing special evaluation exemptions spelled out in §97.13(c) of the Commission’s rules. Minor rules changes adopted in the Report and Order section of the document took effect August 5.
In addition the EC will discuss a manufacturer’s proposal to delete §97.317(a)(2), requiring that amplifiers operating below 144 MHz “not be capable of amplifying the input RF power (driving signal) by more than 15 dB gain.” The Committee will consider whether to propose the rules change described.
The EC will hear status updates on other regulatory matters, including the ARRL’s Petition for Rule Making filed last November to create a new MF allocation for the Amateur Service at 472-479 kHz. The FCC’s ET Docket 13-101 regarding receiver performance standards also will come up for discussion, as will pending amendments of the Amateur Service rules governing qualifying exam systems, Amateur Radio use of TDMA equipment, and remote proctoring of exam sessions.
Other topics on the EC agenda for review include the FCC’s proposed revision of Part 15 rules to permit unlicensed National Information Infrastructure (U-NII) devices in the 5 GHz band, the effects of communications towers on migratory birds, and amendments to the FCC’s CORES system. There has been no recent FCC action on these items.
The EC also will hear a report on the status of the effort to have the “Emergency Communications Enhancement Act of 2013” introduced in the 113th Congress. The objective of the League’s draft bill is an instruction from Congress to the FCC to extend the existing limited preemption of state and local regulation of Amateur Radio station antenna structures to private land-use regulations.