ARRL

ARRL General Bulletin ARLB036 (2013)

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ARLB036 ARRL Files Comments on Its "Symbol Rate" Petition

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ARRL Bulletin 36  ARLB036
From ARRL Headquarters  
Newington CT  December 24, 2013
To all radio amateurs 

SB QST ARL ARLB036
ARLB036 ARRL Files Comments on Its "Symbol Rate" Petition

The ARRL has filed comments with the FCC on its own Petition for
Rule Making RM-11708 (plus Erratum) - the so-called "symbol rate"
petition. Although the League rarely files formal comments on its
own petitions, ARRL General Counsel Chris Imlay, W3KD, citing the
high level of interest in the proceeding, said, "[T]his is clearly
an exceptional circumstance." RM-11708 proposes to drop the symbol
rate limit in §97.307(f) of the FCC Amateur Service rules,
substituting a maximum occupied bandwidth of 2.8 kHz for HF data
emissions.

The comments may be found on the web at, 
http://apps.fcc.gov/ecfs/document/view?id=7521063715 .

"More than 700 comments have been filed thus far, which is a large
number indicating that the issue of data communications is an
important one in the Amateur Radio Service," the ARRL commented. "It
is also gratifying that the majority of the filed comments are
supportive of the proposals in the Petition." Imlay said the League
also would file reply comments - ie, comments on filed comments - on
its petition by the January 7, 2014, deadline, "dealing specifically
with the arguments of substance contained in opposing comments."

The ARRL's comments to the FCC echo the points it made in a briefing
memorandum made public in mid-December. The memo attempted to
clarify just what it is - and is not - asking the FCC to do. The
League said some comments filed in opposition to its petition "are
premised on certain recurring misconceptions or errors" that, the
ARRL allowed, were "understandable" given that the rules governing
Amateur Radio MF and HF emissions "are not entirely straightforward
or intuitive."

In general, the ARRL said, the petition would have no effect on HF
subbands where phone and image emissions are now allowed. "The
petition would not permit digital voice transmissions in the data
and RTTY subbands, because digital voice is defined in the
Commission's rules as voice (ie, phone), not data," the ARRL
stressed in its comments. The petition would have no effect on CW
operation in the HF bands either, and restrictions on automatically
controlled digital stations would remain unchanged as well.

"It is hoped that those who have filed comments in this proceeding
or who anticipate doing so will review the above summary of what the
Petition in this proceeding does and does not propose, and that they
will find it helpful in evaluating the proposal for themselves,
unhindered by any misconceptions about the existing rules or the
proposed changes," the ARRL said in its comments.

The ARRL comments also took pains to address the proposed 2.8 kHz
maximum bandwidth for HF data emissions. "Some comments say that
bandwidths greater than 2.8 kilohertz for data emissions should be
permitted in order to permit a wider array of data emissions now and
in the future," the ARRL said. "Others argue that 2.8 kHz is too
wide, potentially allowing usurpation of the band to the detriment
of CW and other narrow-bandwidth emissions."

The recommended 2.8 kHz maximum, the ARRL said, was an attempt to
balance two competing objectives - facilitating the use of current
and future data emissions and protecting against a situation where a
few data stations take over a band.

"Some bandwidth limit is necessary, if the outdated symbol rate
limit is eliminated, as it should be," the League argued, adding
that it would be "undesirable" to permit an environment where "a few
data stations using large swaths of spectrum could operate to the
detriment of other modes in the very narrow HF amateur allocations."
Nor would it be possible, the League said, to drop the maximum HF
data emission bandwidth much below 2.8 kHz without prohibiting
permitted data modes already in use.

The League's petition now tops the FCC's "Most Active Proceedings"
list. As of the December 23 comment deadline, more than 850 comments
had been filed.
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