The ARRL has filed comments with the FCC on its own Petition for Rule Making RM-11708 (plus Erratum) — the so-called “symbol rate” petition. Although the League rarely files formal comments on its own petitions, ARRL General Counsel Chris Imlay, W3KD, citing the high level of interest in the proceeding, said, “[T]his is clearly an exceptional circumstance.” RM-11708 proposes to drop the symbol rate limit in §97.307(f) of the FCC Amateur Service rules, substituting a maximum occupied bandwidth of 2.8 kHz for HF data emissions.

“More than 700 comments have been filed thus far, which is a large number indicating that the issue of data communications is an important one in the Amateur Radio Service,” the ARRL commented. “It is also gratifying that the majority of the filed comments are supportive of the proposals in the Petition.” Imlay said the League also would file reply comments — ie, comments on filed comments — on its petition by the January 7, 2014, deadline, “dealing specifically with the arguments of substance contained in opposing comments.”

The ARRL’s comments to the FCC echo the points it made in a briefing memorandum made public in mid-December. The memo attempted to clarify just what it is — and is not — asking the FCC to do. The League said some comments filed in opposition to its petition “are premised on certain recurring misconceptions or errors” that, the ARRL allowed, were “understandable” given that the rules governing Amateur Radio MF and HF emissions “are not entirely straightforward or intuitive.”

In general, the ARRL said, the petition would have no effect on HF subbands where phone and image emissions are now allowed. “The petition would not permit digital voice transmissions in the data and RTTY subbands, because digital voice is defined in the Commission’s rules as voice (ie, phone), not data,” the ARRL stressed in its comments. The petition would have no effect on CW operation in the HF bands either, and restrictions on automatically controlled digital stations would remain unchanged as well.

“It is hoped that those who have filed comments in this proceeding or who anticipate doing so will review the above summary of what the Petition in this proceeding does and does not propose, and that they will find it helpful in evaluating the proposal for themselves, unhindered by any misconceptions about the existing rules or the proposed changes,” the ARRL said in its comments.

The ARRL comments also took pains to address the proposed 2.8 kHz maximum bandwidth for HF data emissions. “Some comments say that bandwidths greater than 2.8 kilohertz for data emissions should be permitted in order to permit a wider array of data emissions now and in the future,” the ARRL said. “Others argue that 2.8 kHz is too wide, potentially allowing usurpation of the band to the detriment of CW and other narrow-bandwidth emissions.”

The recommended 2.8 kHz maximum, the ARRL said, was an attempt to balance two competing objectives — facilitating the use of current and future data emissions and protecting against a situation where a few data stations take over a band.

“Some bandwidth limit is necessary, if the outdated symbol rate limit is eliminated, as it should be,” the League argued, adding that it would be “undesirable” to permit an environment where “a few data stations using large swaths of spectrum could operate to the detriment of other modes in the very narrow HF amateur allocations.” Nor would it be possible, the League said, to drop the maximum HF data emission bandwidth much below 2.8 kHz without prohibiting permitted data modes already in use.

The League’s petition now tops the FCC’s “Most Active Proceedings” list. As of the December 23 comment deadline, more than 850 comments had been filed.