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ARRL Reply Comments Cite 'Fundamental Misunderstanding' of 'Symbol Rate':

from The ARRL Letter on January 9, 2014
Website: http://www.arrl.org/
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ARRL Reply Comments Cite 'Fundamental Misunderstanding' of 'Symbol Rate' Petition:

In reply comments http://apps.fcc.gov/ecfs/document/view?id=7521064769 filed on its "symbol rate" Petition for Rule Making (RM-11708 http://apps.fcc.gov/ecfs/comment/view?id=6017477458), the ARRL said comments opposed to its initiative reflect a "fundamental misunderstanding" of the petition's intent. The League's petition now tops the FCC's list of "Most Active Proceedings http://www.fcc.gov/rulemaking/most-active-proceedings." More than 800 comments were filed as of January 7, some of them posted after the December 23 cut-off date and most favoring the ARRL's proposal. The ARRL earlier filed comments http://apps.fcc.gov/ecfs/document/view?id=7521063715 with the FCC on its own Petition (plus Erratum http://apps.fcc.gov/ecfs/document/view?id=7520959653). 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 ARRL said those opposing the Petition do not, in general, challenge the removal of the symbol rate limit for data emissions in band segments where RTTY and data emissions are now permitted.

"Rather, they tend to view the proposal to establish a maximum occupied bandwidth of 2.8 kHz for data emissions in the medium-frequency (MF) and high-frequency (HF) bands where data emissions are permitted now as an enabling provision," the ARRL said. Instead, the League said, its Petition is intended to impose "a limitation on the maximum bandwidth of data emissions where none exists now." Given state-of-the-art data technologies, the League said, there is no necessary correlation between the symbol rate and the bandwidth of a data emission. The current symbol rate "acts only as a limit on the efficiency of data emissions in the HF bands as a practical matter, and as an artificial and arbitrary filter on the types of emissions that can be utilized by radio amateurs."

The ARRL said its suggested 2.8 kHz maximum bandwidth reflects a balanced approach that will permit all currently used data emissions, encourage experimentation with data emissions that the current symbol rate restriction prohibits, and preclude the use of wider-bandwidth data emissions that could usurp the limited RTTY/data subbands. Petition opponents, the ARRL went on to say, "offer no evidence" that the rule changes it proposes will lead to a situation where data transmissions overwhelm the subband and preclude narrow bandwidth emission communications.

"The Commission has properly chastised the Amateur Service for resisting deregulatory proposals that are designed to enable amateur experimenters to refine and adapt technologies," the League said in its reply comments. "ARRL is of the view that outdated Commission regulations that needlessly preclude experimentation with data technologies should not be preserved. Outdated regulations are not a viable alternative to cooperative sharing arrangements in the HF bands through voluntary band plans."

Some of those opposing its petition, the ARRL went on to say, expressed the belief that the proposed rule change would impose wider-bandwidth data emissions in spectrum where narrow-bandwidth modes such as CW and PSK31 now operate, to the detriment of the narrow-bandwidth modes. Other opponents contended that the Petition will benefit a few operators at the expense of the many now operating narrowband data, RTTY, and CW on the HF bands.

"It is illogical to argue on the one hand that the Petition is intended to benefit 'the few' who are data emission experimenters and users, and on the other hand to predict that the relief requested in the Petition would create a flood of 'wide-bandwidth' data emissions, swamping the band segments used for CW, RTTY, and narrow-bandwidth data emissions," the League pointed out. "If the concern is that the rule changes will encourage more radio amateurs to experiment with data emissions, that would be a positive outcome." The ARRL further asserted that the fear of interference from automatically controlled stations "is not a valid one."

Its Petition, the ARRL concluded, "is not a referendum on the value of MF or HF data emissions or data experimentation in those bands," but intended to encourage experimentation now restricted artificially by outdated rules. "It is instead a proposal to delete outdated limitations on Amateur Radio experimentation, which Commission policy supports, and which the basis and purpose of the Amateur Radio Service necessitates."

Source:

The ARRL Letter

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