SB QST @ ARL $ARLB037
ARLB037 Current Rules Holding Hams Back from Adopting State-of-the-Art
Technology, ARRL Says

ZCZC AG37
QST de W1AW
ARRL Bulletin 37  ARLB037
> From ARRL Headquarters
Newington CT  October 12, 2016
To all radio amateurs

SB QST ARL ARLB037
ARLB037 Current Rules Holding Hams Back from Adopting State-of-the-Art
Technology, ARRL Says

In comments filed on October 12 with the FCC, ARRL reiterated its case that the
FCC should impose a 2.8 kHz limit on symbol rate for digital modes, arguing
that its approach is both balanced and necessary. ARRL had asked the FCC to
change the Part 97 rules to delete the symbol rate limits in Part 97.307(f) and
replace them with a maximum bandwidth for data emissions of 2.8 kHz on amateur
frequencies below 29.7 MHz. In a July Notice of Proposed Rule Making (NPRM) in
WT Docket 16-239, the FCC proposed to eliminate the current baud rate
limitations for data emissions, consistent with
ARRL's Petition, but it declined to propose a bandwidth limitation for data
emissions in the MF and HF bands to replace the baud rate limitations.

ARRL's comments can be found on in PDF format on the web at,
https://ecfsapi.fcc.gov/file/1011120327463/Comments%20of%20ARRL%20on%20NPRM%201
0112016%20FINAL.pdf .

ARRL told the FCC in its comments that the current HF symbol rate "speed limit"
reflects 1980s technology and has no place in an experimental radio service in
which modern protocols could be efficiently deployed in crowded RTTY/data
subbands.

"The symbol rate limit was created in order to maximize the efficient use and
reuse of that crowded, shared spectrum, but the assumptions made at the time
are no longer valid," ARRL said, "and the rules now prohibit radio amateurs
from utilizing state-of-the-art technology, thus precluding or substantially
inhibiting any meaningful contribution to the advancement of the radio art in
this area." ARRL said earlier assumptions are no longer valid mainly because
there is no correlation between the data rate and the occupied bandwidth in the
rules now.

The League said present rules in the HF data subbands promote inefficiency,
allowing data transmissions of unlimited bandwidth as long as the symbol rate
is sufficiently low, and it stressed that
there must be some limit on occupied bandwidth for HF data emissions.

"Eliminating the symbol rate limitations for data emissions and substituting a
maximum authorized bandwidth would permit the utilization of all HF data
transmission protocols presently legal in the Amateur Radio Service, as well as
state-of-the-art protocols that fall within the authorized bandwidth," the
League said.

ARRL said that it could be "fairly debated" whether or not 2.8 kHz is the
proper maximum bandwidth for data emissions. "Greater bandwidth for data
emissions would permit a wider array of data emissions now and in the future,"
the League said in its comments. "However, even 2.8 kHz could arguably permit
usurpation of the subbands to the detriment of CW and other narrow-bandwidth
emissions. ARRL views the 2.8 kHz maximum bandwidth proposal for data emissions
at HF to be a necessary component of the FCC's proposal, and it fairly balances
the objectives of facilitating use of new and future data emissions and
protecting against usurpation of the band by a few data stations.

ARRL said it would be impossible to reduce the permitted maximum bandwidth for
data emissions at HF much below 2.8 kHz without prohibiting data modes that are
now legal. "At the same time, it would not be desirable to have a few data
stations using large swaths of spectrum to the detriment of other modes," the
League said.

The deadline to file reply comments in the proceeding - ie, comments on
comments already filed - is November 10.

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/EX

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