[RTTY] ARLB030 ARRL Files "Symbol Rate" Petition with FCC

[Jim N7US]

73, Jim N7US


-----Original Message-----
From: ARRL Web site [mailto:memberlist at www.arrl.org] 
Sent: November 20, 2013 11:45
To: jim at n7us.net
Subject: ARLB030 ARRL Files "Symbol Rate" Petition with FCC

SB QST @ ARL $ARLB030
ARLB030 ARRL Files "Symbol Rate" Petition with FCC

ZCZC AG30
QST de W1AW
ARRL Bulletin 30  ARLB030
>From ARRL Headquarters
Newington CT  November 20, 2013
To all radio amateurs 

SB QST ARL ARLB030
ARLB030 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 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of outdated, 1980s-era restrictions that presently hamper or preclude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 argues, "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 League's petition on
public notice for comments, and there is no way to file comments until that
happens.
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/EX