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FCC Action Anticipated on ARRL’s “Symbol Rate” Petition for Rule Making


The FCC has put “on circulation” its decision on the ARRL’s Petition for Rule Making (RM-11708), seeking to change the Amateur Service Part 97 rules to delete the symbol rate limit in §97.307(f) and replace it with a maximum bandwidth for data emissions of 2.8 kHz on amateur frequencies below 29.7 MHz. Proceedings on circulation are pending action by the full Commission, although there is a current backlog, and FCC action is not likely in the near future. ARRL General Counsel Chris Imlay, W3KD, said the League has remained patient.

“While we had hoped for more responsive handling, it is understood that the large number of comments from radio amateurs on the Petition took some time to sort out,” he said. “It was good to note that the Wireless Telecommunications Bureau has circulated a draft of what we presume to be a Notice of Proposed Rule Making responsive to our Petition to the Commissioners for their consideration. We hope to see the proposal released soon.”

In its petition, the League asserted that the changes proposed would “relieve the Amateur Service of outdated, 1980s-era restrictions that presently hamper or preclude Amateur Radio experimentation with modern high frequency (HF) and other data transmission protocols” and would “permit greater flexibility in the choice of data emissions.”

Symbol rate represents the number of times per second that a change of state occurs, not to be confused with data (or bit) rate. Current FCC rules limit digital data emissions below 28 MHz to 300 baud, and between 28.0 and 28.3 MHz to 1200 baud. “Transmission protocols are available and in active use in other radio services in which the symbol rate exceeds the present limitations set forth in §97.307(f) of the Commission’s Rules, but the necessary bandwidths of those protocols are within the bandwidth of a typical HF single sideband channel (3 kHz),” the ARRL pointed out in its 2013 petition. At one point, the League’s petition topped the FCC’s list of “Most Active Proceedings,” attracting hundreds of comments.

Meanwhile, the Amateur Radio community continues to await action on ET Dockets 12-338 and 15-99 that would spell out service rules for the new 2200 and 630 meter Amateur Radio bands. The FCC was expected to issue a Report and Order last fall. That subsequently got moved back to the first quarter of 2016, which also has slipped.

Regulatory provisions under consideration have included a possible notification requirement by some radio amateurs to utilities that operate PLC systems in that region of the spectrum, prior to their starting operation on either new band. Utilities use unlicensed PLC systems to control parts of the electrical power grid.

Earlier this year, the ARRL has asked the Commission not to adopt overly broad requirements to notify utilities in advance of intended Amateur Radio operation on the pending bands. The Amateur Service would gain access to 135.7-137.8 kHz (2200 meters) and 472-479 kHz (630 meters). Both bands have been used by numerous Experimental (Part 5) licensees, and the ARRL’s WD2XSH 600 Meter Experiment continues.



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