In comments filed on October 12 with the FCC, ARRL reiterated its case that the FCC should impose a 2.8 kHz limit on symbol rate for digital modes, arguing that its approach is both balanced and necessary. ARRL had asked the FCC to change the Part 97 rules to delete the symbol rate limits in §97.307(f) and replace them with a maximum bandwidth for data emissions of 2.8 kHz on amateur frequencies below 29.7 MHz. In a July Notice of Proposed Rule Making (NPRM) in WT Docket 16-239, the FCC proposed to eliminate the current baud rate limitations for data emissions, consistent with ARRL’s Petition, but it declined to propose a bandwidth limitation for data emissions in the MF and HF bands to replace the baud rate limitations.
ARRL told the FCC in its comments that the current HF symbol rate “speed limit” reflects 1980s technology and has no place in an experimental radio service in which modern protocols could be efficiently deployed in crowded RTTY/data subbands.
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