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FORMULATING A COHERENT RESPONSE TO ARRL RM 11708 / FCC DOCKET 16-239 NPRM

FORMULATING A COHERENT RESPONSE TO ARRL RM 11708 / FCC DOCKET 16-239 NPRM

Background on ARRL Petition RM 11708 / FCC Docket 16-239 NPRM

In November, 2013, the ARRL filed a Symbol Rate Petition with the FCC, requesting that a maximum bandwidth of 2.8 kHz be established for all data emissions below 29.7 MHz.  The FCC assigned RM (Rulemaking) number 11708 to this petition and subsequently requested comments from the public.  From March 2014 to present (Sep 2016), 80% of the amateur radio operators who have sent comments to the FCC on this RM have expressed opposition to RM 11708.  You can view comments that have been posted to the FCC regarding the ARRL’s petition RM 11708 here.  

The FCC issued Docket 16-239 NPRM (July, 2016) in response to ARRL’s RM 11708.  NPRM stands for Notice of Proposed Rulemaking.  The FCC is currently requesting comments on its soon-to-be-enacted Docket 16-239 NPRM , but anyone interested in filing a comment on RM 11708 / Docket 16-239 NPRM must do so prior to the Oct 11, 2016 filing deadline.  Of the approximately 100 comments that have been filed with the FCC to date, 89% of those responding  have expressed opposition to Docket 16-239 NPRM.  The majority of amateur radio operators who responded to this NPRM cited the need for a bandwidth limit in the RTTY/data subbands in order to protect the narrow band modes from unlimited bandwidth  transmissions.   You can view comments that have been posted to the FCC regarding Docket  16-239 NPRM here.

The Issues

In RM 11708 / Docket 16-239 NPRM, the FCC is requesting comments on two issues relating to data communications:

  1. Should the 300 baud limit be eliminated, thereby removing all limitations on baud rate?
  2. Should there be any bandwidth limit for RTTY and data emissions in the MF and HF bands?

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