[arrl-odv:22081] Symbol Rate Limit Petition for Rule Making Filed 11-15-2013
Greetings. Per the order of the Executive Committee, and following the receipt of helpful edits to the draft Petition reviewed by the EC earlier, attached please find the as-filed Petition for Rulemaking proposing the deletion of the symbol rate limit in Section 97.307 of the FCC Rules, and the imposition of a maximum bandwidth for data emissions below 29.7 MHz of 2.8 kilohertz. The policy underlying the Petition was adopted by the Board in July. Almost all FCC rulemaking documents are permitted to be filed electronically in the ECFS. This is not true, however (yet) of petitions for rulemaking that would initiate a proceeding. Therefore, we filed this Petition by courier in order to obtain a stamp-and-return copy, thus to ensure that the FCC doesn't lose this, as they are wont to do, or if they do, that we can establish that it was in fact filed. You may hear about this issue from constituents, as has been the case in the Pacific Division already, based on news stories that we have circulated about the Board's action. Some may think this signals a resurgence of our prior filing on regulation by bandwidth (which it is not); some may think that the 2.8 kilohertz maximum bandwidth is too wide or too narrow; or some may there need be no bandwidth limit for data emissions at HF, as is the case now. It is hoped that our argument is explained in full in this filing and that you will have no trouble addressing the details of this with constituents. CTO Price and I will be happy to provide any clarifications necessary to help you with this. FCC staff has indicated that they have no problem deleting the symbol rate limit at HF, but they did express concern that the proposed maximum bandwidth was too wide. That concern, however, was based on a mistake of fact that we have tried to debunk in this filing. Let me know any questions you have. 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
Chris. On page 9 of the document, there is written: [image: Inline image 1] I believe that should be cited as STANAG 4406, which applies to messaging standards and architecture. STANAG refers to many *NATO standard agreements* covering various items and protocols. Bob Vallio, W6RGG On Mon, Nov 18, 2013 at 5:48 AM, Chris Imlay <w3kd@aol.com> wrote:
Greetings. Per the order of the Executive Committee, and following the receipt of helpful edits to the draft Petition reviewed by the EC earlier, attached please find the as-filed Petition for Rulemaking proposing the deletion of the symbol rate limit in Section 97.307 of the FCC Rules, and the imposition of a maximum bandwidth for data emissions below 29.7 MHz of 2.8 kilohertz. The policy underlying the Petition was adopted by the Board in July.
Almost all FCC rulemaking documents are permitted to be filed electronically in the ECFS. This is not true, however (yet) of petitions for rulemaking that would initiate a proceeding. Therefore, we filed this Petition by courier in order to obtain a stamp-and-return copy, thus to ensure that the FCC doesn't lose this, as they are wont to do, or if they do, that we can establish that it was in fact filed.
You may hear about this issue from constituents, as has been the case in the Pacific Division already, based on news stories that we have circulated about the Board's action. Some may think this signals a resurgence of our prior filing on regulation by bandwidth (which it is not); some may think that the 2.8 kilohertz maximum bandwidth is too wide or too narrow; or some may there need be no bandwidth limit for data emissions at HF, as is the case now. It is hoped that our argument is explained in full in this filing and that you will have no trouble addressing the details of this with constituents. CTO Price and I will be happy to provide any clarifications necessary to help you with this.
FCC staff has indicated that they have no problem deleting the symbol rate limit at HF, but they did express concern that the proposed maximum bandwidth was too wide. That concern, however, was based on a mistake of fact that we have tried to debunk in this filing.
Let me know any questions you have.
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
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participants (2)
-
Bob Vallio -
Chris Imlay