ARRL

ARRL General Bulletin ARLB032 (2013)

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ARLB032 ARRL Files Erratum to "Symbol Rate" Petition for Rule Making

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ARRL Bulletin 32  ARLB032
From ARRL Headquarters  
Newington CT  December 2, 2013
To all radio amateurs 

SB QST ARL ARLB032
ARLB032 ARRL Files Erratum to "Symbol Rate" Petition for Rule Making

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"would, in the aggregate, relieve the Amateur Service of outdated,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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