Here are more self-serving lies from the ARRL Letter concerning
the "symbol rate" petition. Note particularly the assumption that
2.8 KHz is an appropriate bandwidth in the narrow data allocations
and the promotion of PACTOR 4 as much more efficient (and desirable)
than PACTOR 3 as well as the assertion without evidence that the
present symbol rates were "created to suit digital modes that are no
longer in favor" (since when is RTTY no longer in favor?), and that
present rules "actually encourage spectrum inefficiency."
==> YOUR LEAGUE: ARRL FILES "SYMBOL RATE" PETITION WITH FCC
The ARRL has asked the FCC to delete the symbol rate limit in
§97.307(f) of its Amateur Service rules, replacing it with a maximum
bandwidth for data emissions of 2.8 kHz on amateur frequencies below
29.7 MHz. The ARRL Board of Directors adopted the policy underlying the
petition initiative at its July 2013 meeting. The petition
<http://www.arrl.org/admin/attachments/view/News/72517> was filed
November 15.
"The changes proposed would, in the aggregate, 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Service of outdated, 1980s-era restrictions that presently hamper or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," the League's petition asserted.
"The proposed rule changes would also 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's petition pointed out.
The League said that while bandwidth limitations are reasonable, the
symbol rate "speed limit" reflective of 1980s technology, prohibits
radio amateurs today from utilizing state-of-the-art technology.
Present symbol rate limits on HF "actually encourage spectrum
inefficiency," the League argued, "in that they allow data
transmissions of unlimited bandwidth as long as the symbol rate is
sufficiently slow." The League said eliminating symbol rate limits on
data emissions and substituting a "reasonable maximum authorized
bandwidth" would permit hams to use all HF data-transmission protocols
now legal in the Amateur Service as well as other currently available
protocols that fall within the authorized bandwidth but are off limits
to amateurs.
The League said it's been more than three decades -- when the
Commission okayed the use of ASCII on HF -- since the FCC has evaluated
symbol rate restrictions on radio amateurs as a regulatory matter. "The
symbol rate restrictions were created to suit digital modes that are no
longer in favor," the ARRL noted in its petition. Modern digital
emissions "are capable of much more accurate and reliable transmissions
at greater speeds with much less bandwidth than in 1980."
As an example, the League pointed to PACTOR 3, which is permitted under
current rules, and PACTOR 4, which is not. Despite PACTOR 4's greater
throughput, both protocols can operate within the bandwidth of a
typical SSB transmission.
"If the symbol rate is allowed to increase as technology develops and
the Amateur Service utilizes new data emission types, the efficiency of
amateur data communications will increase," the ARRL concluded.
ARRL General Counsel Chris Imlay, W3KD, has emphasized that there is no
broader plan on the League's part to seek regulation by bandwidth. The
FCC has not yet assigned an RM number and put the petition on public
notice for comments, and there is no way to file comments until that
happens.
Since there is no way to file comments until the Commission assigns an
RM number ... I recommend others file additional "Petitions for Rule
Making" that asks that the maximum bandwidth in the current MF and HF
"RTTY, Data" allocations be set at 500 Hz - "consistent with historical
use of traditional radioteleprinter bandwidths" and other modern data
modes such as PSK31, JT65A, JT9, etc, and that wider bandwidth digital
modes such as PACTOR 3, PACTOR 4, M110A/B/C, ALE, etc. be grouped with
phone and image transmission due to their 2.8 KHz compatible bandwidth.
73,
... Joe, W4TV
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