SB QST @ ARL $ARLB036   
   ARLB036 ARRL Files Comments on Its "Symbol Rate" Petition   
      
   ZCZC AG36   
   QST de W1AW   
   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.   
   NNNN   
   /EX   
      
      
      
   )\/(ark   
      
   Not only is the Universe stranger than we think, it is stranger than we can   
   think. - Werner Heisenberg   
      
   --- FMail/Win32 1.60   
    * Origin:  (1:3634/12.71)