[AMRadio] ARLB020 ARRL Renews Request for FCC to Replace Symbol Rate with Bandwidth Limit

Thu Sep 19 18:46:01 EDT 2019

 From a "Lifer" since 1962 :   ARRL, quit meddling with our hobby. You  
have been trying to kill AM since the 70s ….  Stop it !
Don W4DNR

Quoting Mark <lexnonscripta at usa.com>:

> Hey, if people stop sending money, they'll go out of business. Kind of
> like taxes. If you want the boot off the back of your neck, stop paying
> them to do it!
>
> Mark
>
> KD9CXH
>
> On 9/19/2019 1:41 PM, Rob Atkinson wrote:
>> The ARRL is back to trying to get FCC to have a rule with a strict
>> numerical bandwidth limit.  The question is whether or not this is the
>> beginning of numerical bandwidth limits for everything.
>> The FCC was willing to cooperate with ARRL on everything but the 2.8
>> kc bandwidth limit.  ARRL is back wanting that strict limit written
>> into the rules.  This seems disturbing.
>>
>> 73
>>
>> Rob
>> K5UJ
>>
>>
>>
>> SB QST ARL ARLB020
>> ARLB020 ARRL Renews Request for FCC to Replace Symbol Rate with
>> Bandwidth Limit
>>
>> In ex parte comments filed on September 17 in WT Docket 16-239, ARRL
>> renewed its request that the FCC delete symbol-rate limits for data
>> transmissions in the Amateur Service rules. As it did in its initial
>> filing, ARRL asked the FCC to couple the removal of the symbol rate
>> limits with the adoption of a 2.8 kHz bandwidth limit. In response
>> to a 2013 ARRL Petition for Rulemaking (RM-11708), the FCC proposed
>> deleting the symbol-rate limits but declined to replace them with
>> the 2.8 kHz bandwidth that ARRL wanted.
>>
>> The 2013 ARRL Petition for Rulemaking (RM-11708) can be found online
>> in PDF format at, https://ecfsapi.fcc.gov/file/7520958815.pdf .
>>
>> "This proceeding addresses an update to the Commission's rules that
>> is needed because a limitation in the rules unintentionally is
>> inhibiting US amateurs from employing the latest improvements to
>> some of the digital modes," ARRL said in its remarks. "Data signals
>> commonly used for daily communications as well as in disaster
>> situations have bandwidths in the range of 2.5 kHz and must co-exist
>> with other modes that use bandwidths as narrow as 50 Hz."
>>
>> ARRL said the 1980s-era symbol-rate limits now inhibit the use of
>> some efficient data modes. "The symbol rate limit uniquely prevents
>> radio Amateurs in the United States from experimenting and
>> innovating with a class of modern digital communication techniques
>> that already are widely used in other countries," ARRL told the FCC.
>> "The limit also impairs the ability of Amateurs to improve support
>> that they offer in times of disaster."
>>
>> Repealing the symbol-rate limit would "allow shortened transmission
>> times for the same amount of data without increasing the bandwidth
>> occupied by the signal," ARRL contended. "Other Amateurs would
>> benefit by the resulting reduction in potential interference."
>>
>> ARRL's remarks also addressed issues raised by other parties.
>> "Discussion by commenters in this proceeding delve into subjects
>> well beyond its scope," ARRL said, noting that it had attempted to
>> broker consensus among "some of the most active commenters" with an
>> eye toward exploring possible areas of agreement for the FCC's
>> consideration. ARRL noted that the parties to the ARRL-arranged
>> talks declined to forward to the FCC "joint recommendations on which
>> conditional agreement had been reached."
>>
>> "The issues discussed with the parties are outside the scope of this
>> Docket and would require a further Notice of Proposed Rulemaking
>> before final consideration," ARRL observed. "Some of the same issues
>> also are raised in petitions for rulemaking on which the Commission
>> has sought comment. Given the policy as well as factual
>> disagreements evidenced in the record, we understand that the
>> Commission may decide to consider some of these issues."
>>
>> One of those issues involves automatically controlled digital
>> stations (ACDS). Commenters' concerns focused on interference that
>> could occur with a move away from symbol-rate criteria. ACDS with
>> signals wider than 500 Hz and below 29.7 MHz are confined to
>> specific subbands. ARRL recommended that the FCC consider rule
>> changes that would have all ACDS stations and digital stations with
>> bandwidths greater than 500 Hz share identified subbands.
>>
>> ARRL said if additional signals are added to the ACDS subbands, as
>> recommended, that it would strongly support expanding the HF ACDS
>> subbands. But, ARRL added, "changing the subband boundaries requires
>> study and careful consideration of trade-offs, because any changes
>> will affect multiple user interests." ARRL referred subband
>> reformulation issues to its HF Band Planning Committee for study and
>> recommendations.
>>
>> Some commenters also raised the issue of obscure and encrypted
>> messages. ARRL pointed out in its ex parte remarks that it remains
>> opposed to encryption in the amateur bands, but disagreed "with
>> commenters who argue that the digital modes being used by radio
>> amateurs around the world are per se 'obscured' or 'encrypted.'"
>>
>> ARRL noted that FCC rules permit the use of "new and innovative
>> digital modes" without prior approval, if specified conditions are
>> met. Digital techniques must use approved codes with publicly
>> documented technical characteristics, and their purpose must be to
>> facilitate communication and not to obscure content.
>>
>> "Some commenters allege that specific messages violate the
>> Commission's rules governing encryption, third-party messages,
>> pecuniary interests, objectionable language, or commercial
>> carriage," ARRL noted, and they have called for open-source decoding
>> software to aid in enforcing the applicable rules. "We observe that
>> recently there have been laudable efforts at self-policing," ARRL
>> said. "Unresolved complaints are appropriately handled as
>> enforcement matters rather than as rulemaking matters."
>>
>> ARRL concluded, "It is vital that the rules governing the Amateur
>> Radio Service facilitate continuation of its experimental traditions
>> and purposes. Using the Amateur spectrum 'sandbox' for innovation
>> and development of new ideas and technologies is of significant
>> public benefit."
>> ______________________________________________________________
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>
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