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No Consensus Reached for FCC on “Symbol Rate” Issues


ARRL-initiated efforts for rival parties to reach consensus on some of the issues they raised in the so-called “Symbol Rate” proceeding have ended. In April, the FCC granted ARRL’s request for a 90-day hold in the proceeding, FCC Docket WT 16-239, to provide an opportunity for ARRL to lead an effort to determine whether consensus could be reached on some or all of the issues that commenters have raised in the FCC’s proceeding. The FCC already has issued a Notice of Proposed Rulemaking in WT 16-239, which stemmed from ARRL’s rulemaking petition RM-11708. Discussions were since widened to include issues raised in another Petition for Rule Making, RM-11831, filed by Ron Kolarik, K0IDT, that seeks, in the words of his petition, “to ensure Amateur Radio digital modes remain openly decodable and available for monitoring” by the FCC and by other third parties, including other radio amateurs. His petition also aims to limit Automated Controlled Digital Stations (ACDS) to identified HF sub-bands, to reduce interference. Last month, ARRL filed an interim report with the FCC summarizing its efforts to bring all sides to the table, and on June 28, ARRL requested an additional 60-day pause to pursue promising talks.

“In seeking the delay, it was the ARRL’s intent to facilitate discussions between the opposing parties in an effort to explore the possibility of an agreed resolution that would better protect users of the Amateur Radio spectrum from interference and would permit all members of the Amateur Radio service to continue to contribute to the advancement of the radio art,” ARRL Washington Counsel David Siddall, K3ZJ, said, summarizing the situation in a July 15 letter to the FCC. “The end purpose, if a binding agreement between the opposing parties could not be reached, was to provide the strongest possible basis for the ARRL to file its recommendations on a fair and equitable resolution of the issues.”

Siddall said that despite difficulties “partially attributable to the passions of the respective parties,” ARRL was able to schedule meetings with both sides and, eventually, joint discussions among the respective parties.

“When this process began, we expressed our intention to reach a common understanding of issues and to agree on their resolution insofar as possible,” Siddall said in his letter. “At the beginning of our meetings there emerged consensus on the issues to be discussed. By the end, the parties had reached consensus on some of the issues, but not all. Despite our best efforts, some of the parties did not agree to submit to the Commission any of the recommendations on which there had been an apparent consensus, having negotiated with an “all or nothing” approach.”

Despite the disappointing conclusion, Siddall expressed confidence that a better understanding of issues and positions of the various interests exists among all of the parties who participated in the in-person meetings and teleconferences, and that this will have an overall positive effect upon the outcome of the proceeding.

Siddall said ARRL remains committed to providing the FCC with its best recommendations on a fair and equitable resolution of the issues, after it has had an opportunity for discussion and deliberation.

“The ARRL membership is composed of radio amateurs with a broad array of interests in technical and experimental domains that range from creating and using satellite technologies to long-haul emergency message handling,” Siddall concluded. “The ARRL is committed to promoting and protecting the interests of all Amateur Radio operators as it continues to address amateur interests and concerns.”




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