As the Monday, December 23, deadline nears to comment on the ARRL’s “Symbol Rate” Petition for Rule Making (PRM), the petition has climbed into second place on the FCC’s “Most Active Proceedings” page. Since the FCC put the ARRL Petition on public notice for comment as RM-11708, it has attracted 638 comments and counting. The petition asks the FCC to delete the symbol rate limit in §97.307(f) of its Amateur Service rules and to replace it with a maximum data emission bandwidth of 2.8 kHz on frequencies below 29.7 MHz. In a briefing memorandum released this week, the League took steps to clarify just what it is — and is not — asking the FCC to do. ARRL General Counsel Chris Imlay, W3KD, said that while a significant majority of commenters support the petition, some appear not to understand the petition’s intent. The League reiterated that its filing would not “initiate any large scale plan to convert to regulation of emissions by bandwidth” and would not affect any emissions other than data.

“The Petition proposes no changes that would affect in any way the existing rules governing Morse telegraphy, phone, and image emissions,” the ARRL stressed in its talking points. “The state of the art in digital communications now allows transmission protocols in which the symbol rate exceeds the present limitations of §97.307(f) of the FCC rules, but the necessary bandwidth of the protocol is within the bandwidth of a typical HF single sideband channel (3 kHz).” The League contends that eliminating symbol rate limitations for data emissions and substituting a maximum authorized bandwidth “would permit the utilization of all HF data transmission protocols presently legal in the Amateur Radio Service, as well as state-of-the-art protocols that fall within the authorized bandwidth.”

The briefing memo stresses that the petition would not

• affect HF subbands where phone and image emissions are now permitted nor affect HF CW operation
•  permit digital voice transmissions in data and RTTY subbands nor add rules affecting digital voice
• change restrictions on automatically controlled digital stations
• permit data emissions to use occupied bandwidths in excess of what is now allowed.

Further the petition does not call on the FCC to expand the frequencies on which “unspecified digital codes” may be used. The original petition, as filed, included an error that the ARRL corrected in an Erratum deleting the erroneous reference to unspecified digital codes at HF. “It was never our intention to permit unspecified digital codes at HF,” the League said.

All told, the ARRL talking points state, the proposal represents a balanced approach. “ARRL attempted, in adopting the 2.8 kHz maximum bandwidth proposal for data emissions at HF to balance the two objectives of facilitating use of new and future data emissions and protecting against usurpation of the band by a few data stations,” it said. “Some bandwidth limit is necessary if the outdated symbol rate limit is eliminated, as it should be.”

Reply comments — ie, comments on filed comments — on the ARRL’s petition are due by January 7, 2014.