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ARRL Files Erratum to “Symbol Rate” Petition for Rule Making

12/02/2013

The ARRL has filed an Erratum with the FCC to correct an error in its “symbol rate” Petition for Rule Making (PRM), filed November 15 with the FCC and put on public notice for comment as RM-11708 a few days later. The League’s petition asks the FCC to delete the symbol rate limit in §97.307(f) of its Amateur Service rules and replace it with a maximum bandwidth for data emissions of 2.8 kHz on amateur frequencies below 29.7 MHz. The Erratum, filed November 26, removes an erroneous reference in the appendix at §97.307(f)(3) to “unspecified digital codes” and includes a corrected appendix.

“In one respect the criticism being voiced about our RM-11708 petition has some merit,” said ARRL CEO David Sumner, K1ZZ. “This is with regard to the addition of ‘unspecified digital codes’ language to §97.307(f)(3). This change is not discussed at all in the body of the petition and was not intended to be included in the proposal.” The Erratum “relates only to the Appendix as originally filed, and only with respect to the proposed revised text of §97.307(f)(3),” The League said. “The remainder of the Petition was correct as filed.”

The revised proposed §97.307(f)(3) will read: “Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The authorized bandwidth is 2.8 kHz.” Sumner pointed out that in 1995 the FCC clarified that “specified digital code” is any digital code that has its technical characteristics publicly documented.

“All of us who reviewed the draft and missed this are deeply sorry for the confusion thus caused,” Sumner said.

In its petition, the ARRL said that the changes it is proposing “would, in the aggregate, relieve the Amateur Service of outdated, 1980s-era restrictions that presently hamper or preclude Amateur Radio experimentation with modern high frequency (HF) and other data transmission protocols.”

 



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