Replacement of the HF symbol rate with a 2.8 kHz bandwidth for 160M through 10M, except 60M (which has no symbol rate limit), if adopted on Nov. 15 as proposed, is final action and will become effective 30 days after publication in the Federal Register. 

Deletion of the symbol rates for the other bands are in a Further Notice because they were not included in the ARRL’s 2013 petition nor the FCC’s 2016 Notice of Proposed Rulemaking. The FCC will fix comment and reply comment deadlines based on publication in the Federal Register.

73, Dave K3ZJ

David R. Siddall

Managing Partner

DS Law, PLLC

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

Unauthorized Disclosure Prohibited.  This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged.  If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments.  If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments.  Unintended transmission shall not constitute waiver of attorney-client or any other privilege.  Thank you. 

From: Fred Kemmerer <fkemmerer@anita-fred.net>
Date: Thursday, October 26, 2023 at 7:11 PM
To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>, "arrl-odv@reflector.arrl.org" <arrl-odv@arrl.org>
Subject: Re: [arrl-odv:35293] FCC Proposed Action on Symbol Rate Removal

Hello David,

Thank you very much for the explanation. Can you clarify if and to what extent these changes will be subject to a comment period before final implementation?

Best and 73,

Fred Kemmerer,  AB1OC

(603) 413-5400

Mail: ab1oc@arrl.org

ARRL New England Division Director

From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of David Siddall <david@davidsiddall-law.com>
Date: Thursday, October 26, 2023 at 11:53 AM
To: "arrl-odv@reflector.arrl.org" <arrl-odv@arrl.org>
Subject: [arrl-odv:35293] FCC Proposed Action on Symbol Rate Removal

All,

The FCC has released the proposed text of the item that it will consider on Nov. 15.   If adopted, the FCC would:

· Delete the HF symbol rate

· Adopt a 2.8 kHz bandwidth limit in place of the symbol rate

· Leave all other rules in place, including:

o prohibition of encrypted modes

o small subbands for unattended (automatic) digital modes with bandwidths greater than 500 Hz

· Initiate a new Further Notice of Proposed Rulemaking in which it:

o Proposes to eliminate the symbol rates for 6 meters and up

o Request comment on the signal bandwidth limits already applicable in those bands

o Request comment on eliminating the symbol rate limits applicable to the LF bands, and whether a bandwidth limit is necessary in those bands

Link to the proposed Commission item: https://docs.fcc.gov/public/attachments/DOC-397992A1.pdf.

· The proposed Report and Order, which relates to the HF symbol rate, is 100 percent consistent with ARRL positions and advocacy.

· The Further Notice makes proposals that also are consistent with ARRL’s recent advocacy on these issues.

As always, feel free to direct any questions to me.

73, Dave K3ZJ

David R. Siddall

Managing Partner

DS Law, PLLC

1629 K St. NW, Ste 300

Washington, DC 20006

direct: +1 202 559 4690

Unauthorized Disclosure Prohibited.  This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged.  If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments.  If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments.  Unintended transmission shall not constitute waiver of attorney-client or any other privilege.  Thank you.