Hi Ria (and all on the cc),
Timing is driven by procedural requirements. The FCC issued a Notice in 2016 addressing the 300 baud limit and the related 2.8 kHz bandwidth limit, then accepted public
comment thereon. The symbol rate / bandwidth issue is positioned for final action by the Commission whenever they decide to move on it, as soon as later tis fall. The other issues are not within the 2016 Notice, and therefore cannot be resolved before the
Commission issues a notice and receives public comment. The FCC will determine whether to do so, and if so, when. I would expect it to be with the baud rate decision, or within a short time of it.
Our reiteration of support on the symbol rate issue increases the chances for favorable action to delete the symbol rate with inclusion of a 2.8 kHz limit, even though the
FCC’s initial cut was that no bandwidth limit is needed. Such a decision (1) would resolve the 300 baud limit problem that nearly everyone recognizes should be deleted, while
(2) the 2.8 kHz limit would have the effect of preserving the status quo with regard to potential interference and other related concerns with digital signals. As a practical matter, nothing is likely to change insofar as data usage band occupancy
and such so long as the 2.8 kHz limit is included in the FCC’s actions. That bandwidth limit is roughly equivalent to the original bandwidth limit intended by adoption of 300 baud rate limit.
The other issues have not been subject to the required FCC Notice and public comment. The FCC has not agreed even to consider any of the other issues. But I do expect that
the steps in the ARRL Board resolution will go forward to be considered in an FCC proceeding along with other suggestions that have been made, such as in the Kolarik petition (RM-11831). Under this scenario no one is worse off than before deletion of the
baud rate, and the prospects for the FCC moving on the related suggestions in a timely fashion are improved because there are fewer issues and conflicting claims with which to deal.
The state of play right now is that I have hopes for (1) a decision on the symbol rate / bandwidth issue this fall, no later than early winter. (The decision must go to
all five Commissioners for voting, it is not a staff-level item, so timing is difficult to predict.) (2) The other issues, such as ACDS band changes, require the FCC to issue a Notice and accept public comment. This could be done as a completely new proceeding,
or it could be in the form of a “Further Notice” issued with the baud rate / bandwidth limit decision.
FCC consideration of things like whether to put all ACDS stations within ACDS bands – and whether and how those bands should be changed to accommodate additional signals
– is not “tomorrow” but not years in the future either. In the meantime, it seems to me that nothing changes except the baud rate limit goes away. There should be no change except maybe that repeal of 300 baud limit, which has across-the-board support, no
longer could be held hostage to try to force through other changes. Those changes will have to be considered on their own merits.
Hope this is clear. If not, please try again.
73, Dave K3ZJ
From: "rjairam@gmail.com" <rjairam@gmail.com>
Date: Thursday, September 19, 2019 at 10:08 AM
To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>
Cc: arrl-odv <arrl-odv-bounces@reflector.arrl.org>
Subject: Re: [arrl-odv:28789] ARRL Filing re Board Resolution
Hi David,
One thing is unclear to me. What happens now? From this filing it appears as though we are recommending to immediately remove the 300 baud limit, institute a 2.8kHz bandwidth limit, and then possibly consider the rest of stuff (all automatic
in ACDS segments, and all wideband automatic or not in ACDS segments) for an undetermined future filing? When? 5, 10 years down the road?
That doesn’t seem correct to me.
Thanks
Ria
N2RJ
On Tue, Sep 17, 2019 at 11:03 PM david
davidsiddall-law.com <david@davidsiddall-law.com> wrote:
Attached is the ARRL filing submitted to the FCC pursuant to the July Board Resolution concerning the symbol rate, digital/ACDS/encryption, WInlink, etc. issue(s). It will be cross-filed in the other dockets that the commenters have been copying – amateur technician class, 80 meter band reformulation, etc. Pursuant to item (6) of the resolution, a letter is being drafted to the Enforcement Bureau Chief. Given that a software release this weekend from SCS is reported to enable monitoring Winlink messages OTA in plain language, maybe this issue will calm down, who knows?
73,
Dave K3ZJ
David R. Siddall
Managing Partner
DS Law, PLLC
direct: +1 202 559 4690
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