01/11/2024

ARRL  The National Association for Amateur Radio¿[1] responded to the Federal
Communications Commission's (FCC) request for comments on removing the symbol
(baud) rate restrictions that apply to data communications on the LF bands and
the VHF and UHF bands below 450 MHz. The FCC also requested comments on the
bandwidth limits applicable to those bands.

The FCC's action follows their 2023 decision to remove the symbol (baud) rate
limits on the 160- to 10-meter amateur bands.[2] Those limits were replaced
with a 2.8 kHz bandwidth limit, a move ARRL had long advocated for.

The FCC's Further Notice of Proposed Rulemaking sought comments on updating the
other amateur bands on which its symbol (baud) rate limits continue to throttle
faster data rates. The subject bands are the LF bands (2200 and 630 meters) and
the VHF and UHF bands below 450 MHz. In its comments, ARRL strongly agreed with
the FCC's proposal to remove the symbol (baud) rate limits on the remaining
bands.

ARRL's comments also noted that CW operation is protected in the lower 100 kHz
of the 6- and 2-meter bands and will continue to be so protected, but
otherwise, all modes are permitted in the remainder of the subject VHF and UHF
bands with only the data modes subject to bandwidth restrictions below 450 MHz
that vary by band. The bandwidth restrictions uniquely applicable to data modes
have resulted in the other modes being permitted to use many times the
bandwidth of data modes in an intermixed fashion determined by those using the
bands. For the data modes, however, the limits have limited experimentation
with techniques already in use in other countries on amateur VHF and UHF bands.

ARRL concluded that the FCC should also remove the bandwidth limits that apply
uniquely to the data modes on the subject bands, and instead, amateurs rely on
voluntary band plans and local agreements, as they already do with regard to
the mix of the other modes ranging from Morse code (CW) signals of 50 Hz or so
(depending upon speed) to amateur television that employs signals of 6 or more
MHz. ARRL also noted that the limited propagation range on the subject bands
enables local cooperation that is not possible on the HF bands where
propagation is such that signals can cover the globe.

The bands addressed in this rulemaking are: 

o 135.7 - 137.8 kHz (2200-meter) and 472 - 479 kHz (630-meter) bands.
o 50.1 - 54 MHz (6-meter) and 144.1 - 148 MHz (2-meter) bands.
o 219 - 220 MHz (1.25-meter digital) bands.
o 222 - 225 MHz (1.25-meter) and 420 - 450 MHz (70-centimeter) bands.

The public period for reply comments remains open until January 22, 2024. An
ARRL guide to filing comments is available at
https://www.arrl.org/arrl-guide-to-filing-comments-with-fcc[3].

[1] https://www.arrl.org
[2] https://www.arrl.org/news/bandwidth-limits-replace-symbol-rates-on-the-hf-bands-other-bands-open-for-comment
[3] https://www.arrl.org/arrl-guide-to-filing-comments-with-fcc

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