Chris, I understand your point but I think the Board addressed that concern separately in Minute 47 with its charge to the HF Band Planning Committee. Raising it in the context of the rulemaking proceeding would perpetuate the misconception that it is related to Part 97, which it is not.

Rick Roderick isn’t letting any grass grow under his feet; the HF Band Planning Committee is holding its first teleconference next week.

Dave K1ZZ

From: Imlay, Chris, W3KD
Sent: Thursday, February 06, 2014 4:38 PM
To: Sumner, Dave, K1ZZ; arrl-odv
Subject: Re: [arrl-odv:22418] Symbol rate FAQ

Dave, having just seen this, it strikes me that it might benefit from the addition of a point that addresses the fundamental objection that we hear over and over: which is the assumption that the Committee didn't consider the cumulative effect on CW, RTTY and narrow bandwidth data emissions from a plethora of new, 2.8 kilohertz data stations. I realize that a response to that objection calls for speculation on both sides of the argument, but to my mind there is not much benefit in a FAQ that doesn't get to what the vocal minority of objectors are actually concerned about. We might note that any future crowding of the RTTY/data subbands is handled by voluntary band planning.

There is the corollary suggestion that is also heard repeatedly from objectors that such wider bandwidth data emissions should be relegated to the phone/image subbands; The response to which is that such a fundamental reconfiguration of the HF bands WOULD constitute a broad-based endorsement of regulation by bandwidth, a subject with far more ramifications than are contained within the much more limited RM-11708.

73, Chris W3KD

Christopher D. Imlay
Booth, Freret, Imlay & Tepper. P.C.
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
W3KD@ARRL.ORG

-----Original Message-----
From: Sumner, Dave, K1ZZ, K1ZZ <dsumner@arrl.org>
To: arrl-odv <arrl-odv@arrl.org>
Sent: Thu, Feb 6, 2014 2:23 pm
Subject: [arrl-odv:22418] Symbol rate FAQ

Here is the symbol rate FAQ that I propose to post in accordance with Minute 51 of the January Board Meeting. Suggestions for additions and clarifications are welcome.

I want to acknowledge Brennan Price’s considerable contribution to the FAQ, without which it would not yet be ready for your perusal. Both of us had to overcome our usual inclination to go into great detail when just a simple explanation is called for.

73,

Dave Sumner, K1ZZ

Frequently Asked Questions about the ARRL “Symbol Rate” petition, RM-11708

Q: Why did the ARRL think the petition to eliminate regulation by symbol rate was needed?

A: HF data emissions are now limited to symbol rates that are based on the long-obsolete technology of the early telephone modems. Regulation by symbol rate is not appropriate for present and future generations of digital data modes; it prohibits the use of some new, efficient modes while not preventing the introduction of digital data modes with much wider bandwidths than are now in use.

Q: The petition proposes to substitute a bandwidth limit of 2.8 kHz for the symbol rate limits – why 2.8 kHz and not some other figure?

A: It accommodates the digital data modes that are now in widespread use while limiting future development to the bandwidth of an SSB transceiver.

Q: Would the proposed revision have any effect on phone or image operation?

A: No.  There is no proposal to revise any rule applicable to the phone and image subbands.

Q: Would the proposed revision have any effect on digital voice operation?

A: No.  The FCC rules define digital voice as phone.

Q: Does the proposed revision permit wider use of automatically controlled digital stations?

A: No.  Section 97.221 would remain unchanged.

Q: Does the proposal expand the frequencies on which unspecified digital codes may be used?

A: No, although an error in the original ARRL filing suggested otherwise. As soon as it was discovered, this was corrected through the filing of an erratum.

Q: Is the proposal a precursor to large-scale regulation by bandwidth?

A: No. The proposal is to regulate the bandwidth of a single type of emission (data) in order to narrowly and surgically eliminate an outdated limitation in the FCC rules which precludes radio amateurs from experimenting and contributing to the radio art as fully as they should.

Posted February xx, 2014

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