FCC Opines on RM-11708 (Removal of Symbol Rate) and Solicits Additional Feedback

N1EN · Jul 28, 2016

The FCC has responded to the ARRL's petition to retire the 300 baud symbol rate restriction on HF.

The full document is available on the FCC ECFS.

The highlights:

FCC said:

We tentatively agree with ARRL that the baud rate limits should be eliminated, and propose to amend Part 97 accordingly. As ARRL notes, digital emissions were “in their early stages and experimentation with them was limited” at that time, and “the state of the art in HF digital communications has advanced substantially” since then. Indeed, the Commission observed in 1993 that “as technology progresses the rules may become unnecessarily restrictive, particularly with regard to the permissible baud rate.” [...]

Many commenters agree that the baud rate restriction should be eliminated, and we seek comment on the reasons supporting such a view. For example, one commenter states that “part of the purpose of the amateur radio service is the advancement of radio and communications technology. Denying the ability to research and implement higher symbol rates directly contradicts the very purpose for amateur radio.” Another commenter notes that “[t]he rest of the amateur radio operators in the world do not have this restrictive symbol rate requirement that is in the current Part 97” and eliminating this restriction will allow the Emergency Communications Community to “benefit by being better able to meet its mission.” Many commenters cite permitting PACTOR 4 at HF as a reason for changing the rule, particularly to facilitate more efficient transmission of emergency communications. Other commenters, however, are concerned that facilitating faster data throughput will actually increase congestion by encouraging the transmission of larger amounts of data and new types of content. [...]

We tentatively agree that a baud rate restriction has become unnecessary due to advances in modulation techniques, and no longer serves a useful purpose. Our rules do not impose a symbol rate limit on data emissions in any other amateur bands or in any other radio service. In addition, removing the baud rate restriction could encourage individuals to more fully utilize the amateur service in experimentation and could promote innovation, more efficient use of the radio spectrum currently allocated to the amateur service, and the ability of the amateur service to support public safety efforts in the event of an emergency. Facilitating the ability of the amateur service to transmit and experiment with technologies currently used in consumer and commercial products furthers this goal. Consequently, we propose to remove the baud rate limits in Section 97.307(f). We seek comment on this proposal. In particular, we seek comment on whether eliminating the baud rate limits would improve amateur communications, or would instead increase congestion. To the extent the elimination of the baud rate limits is likely to increase congestion, we seek comment on whether the costs of such an increase are outweighed by the benefits that are likely to flow from the elimination of the limits, and whether there are ways to mitigate these costs without losing the benefits of the proposed initiative. More generally, we seek comment on whether there are other costs and benefits to the proposal and, when weighing all the factors, whether the benefits of the proposal outweigh its costs. Commenters opposed to eliminating the baud rate limits should also explain whether their concerns relate to all of the bands at issue, or only certain spectrum.

We decline, however, to propose to add a 2.8 kilohertz bandwidth limitation for RTTY and data emissions in the MF/HF bands as requested by the ARRL Petition. ARRL concedes that the question of whether a bandwidth limitation is necessary is “reasonably debatable,” but proposes the limitation because it “may be necessary in order to ensure equitable and efficient sharing among Amateur licensees of very limited and heavily used Amateur Radio spectrum (especially at HF).” [...]

After reviewing the record, we tentatively conclude that a specific bandwidth limitation for RTTY and data emissions in the MF/HF bands is not necessary. We note that only the digital codes specified in Section 97.309(a) may be used for MF/HF data emissions, and our rules do not impose any specific bandwidth limitation on use of the specified digital codes in any frequency band other than the 60 meter band. [...]

We also observe that while a 2.8 kilohertz bandwidth limitation would accommodate HF data emissions that are in common use today, such a limitation could, at the same time, undermine the goal—fundamental to the amateur service—of encouraging advances in technology if amateur radio operators were thereby prevented from stepping beyond today’s radio science. Imposing a maximum bandwidth would result in a loss of flexibility to develop and improve technologies as licensees’ operating interests change and new technologies are developed. We seek comment on these tentative conclusions.[...]

While we tentatively conclude that a specific bandwidth limitation for RTTY and data emissions in the MF/HF bands is not necessary, we nonetheless request comment on whether we should establish emission bandwidth standards for amateur service MF/HF RTTY and data emissions. Commenters favoring such action should address what the maximum bandwidth should be, the basis for the particular limitation the commenter proposes, and whether the limit should apply across the bands or only in particular subbands. Commenters should explain the grounds for departing from the generally applicable standards.
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Comments can be made through the FCC's ECFS system, referencing RM-11708.

Remember, effective comments are polite, focused, and devoid of personal attacks or conspiracy theories.

KQ6XA · Jul 30, 2016

It is just a matter of whether Ham Radio
will help to lead this technological revolution,
keep up with it,
or be dragged kicking and screaming
into the RF techniques of the 21st century.

There is already the long-existing rule: 'hams must use the minimum bandwidth necessary' for communications.
That rule is still in effect and will not be changed by this FCC rulemaking.
Finite bandwidth limits such as 2.8 kHz or 3.0 kHz are counterproductive to technological innovation.

FCC RULE:
§97.307 Emission standards.
(a) No amateur station transmission shall occupy more bandwidth than necessary for the information rate and emission type being transmitted, in accordance with good amateur practice.

With the trend toward very fast communications that can contain a lot of message, with a short time spectrum footprint, it could lead to even better sharing than the antiquated frequency-based separation of the 20th century model.

The HF bands are not always crowded... for example: We are in the bottom of the solar cycle, and it is night here. I'm tuning around 15 meters right now and there's not a signal I can copy here. Would it bother anyone if I used the whole digi sub-band segment at 100 watts for 10 seconds to send an emcomm spreadsheet message on groundwave to a station 20 miles away? No.

Beginning in the 1980's, as a cellphone design engineer, I watched the evolution of cellular phone technology... we once used conventional FM for it. It evolved, and now we use various forms of Time-Division, Code-Division, and combinations of various time-interval modes. That innovation has vastly increased the number of signals that share the same spectrum.

The same revolution is happening in a similar way to HF, for commercial and governmental radio services outside the ham bands; and it will eventually happen to hams on HF.

FCC concluded that the antiquated symbol rate rule should be eliminated.

FCC also concluded there should be no new finite bandwidth limitations.

I fully agree with FCC's conclusions.

We need to support FCC's "no finite bandwidth limit" because it keeps Ham Radio open to development of new radio techniques and systems.

On the horizon, we can now see some of those new radio techniques which looked nearly impossible to implement 25 years ago.

NN4RH · Jul 30, 2016

N1EN said: ↑

Remember, effective comments are polite, focused, and devoid of personal attacks or conspiracy theories.
Click to expand...

Yes. Too many hams treat these comments on NPRMs as a "vote" for or against. That is not what the comments are for.

The FCC asked that commenters address five specific questions:

12. While we tentatively conclude that a specific bandwidth limitation for RTTY and data emissions in the MF/HF bands is not necessary, we nonetheless request comment on ...

* ... whether we should establish emission bandwidth standards for amateur service MF/HF RTTY and data emissions.
* ... Commenters favoring such action should address what the maximum bandwidth should be, ...
* ... the basis for the particular limitation the commenter proposes, ....
* .... and whether the limit should apply across the bands or only in particular subbands. ...
* ... Commenters should explain the grounds for departing from the generally applicable standards.

NN4RH · Jul 30, 2016

Sorry. Dupe.

FCC Opines on RM-11708 (Removal of Symbol Rate) and Solicits Additional Feedback

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