Rules

December 5, 2018--Today the ARSFI board filed with the FCC a comprehensive response to the online and media campaign that Theodore Rappaport has been leading to get the FCC to dismiss the pending Notice of Proposed Rule Making (Docket No. 16-239). The proposal would eliminate the current 300 baud limit on HF digital transmissions. The original ARRL proposal would replace it with a 2.8 kHz bandwidth limitation. We're in favor of the NPRM plus the ARRL's bandwidth limit (for now, please read our paper) for many reasons, mostly because the advancement of the radio art is impeded without it, but for most Winlink stakeholders it will allow Pactor 4--finally--in the USA. New, faster and better protocols will be close behind.

Rappaport is spreading unrelated emotional fire, claiming that ARC protocols and similar wide-band connected digital modes and modes that are hard, expensive (or need proprietary hardware, firmware or software) to intercept communications on-the-air need to be removed from the amateur bands. He says these modes encourage crime, terrorism and are a threat to national security. His arguments would have the FCC remove Winlink, D*Star, Fusion, and all 'connected' modes not easily intercepted on-air by unskilled operators without a proprietary component in the monitoring equipment—before addressing the 300 symbols/second NPRM. He would set amateurs back 40 years or more with respect to the radio art and digital techniques. We don't have to say how devastating the consequences would be if Winlink and all others using similar modes disappeared from the ham bands.

You can download and read the letter we wrote to FCC Chairman Ajit Pai, our response paper, and Rappaport's two recent letters to the FCC. Make your own decision, but make it an informed decision!

If you have a stake in this, we urge you to please immediately file a comment on the ECFS. It's easy: Click here. Time is of the essence. You don't have to write a masterpiece. An 'express' comment that endorses the ARSFI filing is all that's needed.

Also, spread the word. Send a link to this page to all you know who care, especially those you know in leadership positions with emergency management or government agencies, the ARRL, and organizations and agencies that have a stake in Winlink. Let them know, and ask them to take a few moments to put their opinion on the record, or simply say you agree with us with a reference to our filing.

The ARSFI Board of Directors
Winlink Development Team

The FCC has proposed to revise the Amateur Service Part 97 rules in response to the ARRL's so-called "Symbol Rate" Petition for Rule Making (RM-11708), filed in late 2013, and it has invited comments on its recommended changes. The Notice of Proposed Rule Making (NPRM) in WT Docket 16-239, released on July 28, had been making the rounds at the FCC since May. ARRL had asked the FCC to change the Part 97 rules to delete the symbol rate limit in §97.307(f) and replace it with a maximum bandwidth for data emissions of 2.8 kHz on amateur frequencies below 29.7 MHz.

"We believe that the public interest may be served by revising the Amateur Service rules to eliminate the current baud rate limitations for data emissions, consistent with ARRL's Petition, to allow Amateur Service licensees to use modern digital emissions, thereby furthering the purposes of the Amateur Service and enhancing the usefulness of the service," the FCC said in its NPRM. "We do not, however, propose a bandwidth limitation for data emissions in the MF and HF bands to replace the baud rate limitations, because the rules' current approach for limiting bandwidth use by amateur stations using one of the specified digital codes to encode the signal being transmitted appears sufficient to ensure that general access to the band by licensees in the Amateur Service does not become unduly impaired."

The ARRL staff was still reviewing the NPRM at publication deadline, and we will report further on this proceeding.

Published with permission of the ARRL. Copyright 2016 Amateur Radio Relay League, Inc.

• Read the Notice of Proposed Rulemaking (PDF).
• You can file an express comment with the FCC (encouraged) here: https://www.fcc.gov/ecfs/filings/express (Insert "RM-11708" in the "Proceeding(s)" line.)