Subj : ARRL Files Comments Responding to FCC Request for Input
To   : QST
From : ARRL de WD1CKS
Date : Mon Apr 14 2025 09:39 pm

04/14/2025

ARRL The National Association for Amateur Radio� filed comments [PDF][1] with
the Federal Communications Commission in response to its request for public
input on alleviating unnecessary regulatory burdens by deleting or modifying
rules, In the Matter of Delete, Delete, Delete[2]. Implementing ARRL's
suggestions would promote and protect the art, science, and enjoyment of
amateur radio, and enhance the development of the next generation of radio
amateurs.

In response to ARRL's request, over 200 members submitted suggestions that were
reviewed when considering what rules should be deleted or modified. ARRL will
continue to engage with members and advocate for the Amateur Radio Service.

In its filing, ARRL asked the FCC to delete or amend the following rules:

Delete the LF and VHF/UHF Symbol (Baud) Rate and Bandwidth Limitations.

ARRL supports the deletion of these restrictions as proposed by the Commission
in late 2023. Doing so would enhance Amateur experimentation with digital
technologies.

Update and Modernize Entry Level Technician Class License Privileges.

ARRL reiterated its earlier proposal for extending additional limited
privileges for Technician class operators. Adopting its proposal would provide
new licensees an introductory window to HF data and phone communications that
are at the core of the Amateur Radio experience and serve to incentivize the
next generation of technical leaders just as Novice CW HF privileges did for
earlier generations of operators.

Modernize 80/75 Meter Subband Divisions.

ARRL requested action on an earlier proposal that would make more efficient and
intense use of the 80/75 meter band. Changes in technology and modes since band
usage was last addressed have resulted in overcrowding in one band segment that
would be alleviated by adoption of ARRL's proposal.�

Delete and Replace Obsolete Digital Code Limitations.�

ARRL also asked the FCC remove provisions that refer to digital codes that
today are obsolete and permit Radio Amateurs to experiment freely with new
digital codes, so long as such codes are publicly documented and decodable over
the air.

Implement Changes to Third Party Rules Adopted Internationally at WRC-03.

Although the United States fully supported changes to the ITU Radio Regulations
in 2003 that removed a treaty requirement for third-party messages, there is no
record of this change having been considered and the FCC's rules were never
conformed to the new provision. Being the only nation known to continue to
require a formal treaty for such purposes has resulted in no new such treaties
for since the treaty changed more than two decades ago. Thus ARRL asked the FCC
to Implement rules that are consistent with those internationally agreed to
align with the rest of the world.

Delete Amplifier Drive Limitation.

ARRL requested that the Commission act favorably on a pending proposal to
remove limits HF amplifier gain that add to Amateur equipment cost and impede
use of new efficient amplifier technology.

Remove Non-current Personal Information in Amateur ULS records.

ARRL requested that the FCC complete a rule making in which it proposed that
only current licensee information to be visible in the public (ULS) database.
Right now, if an amateur changes their address to a Post Office Box to shield
their home address, the previous address remains visible. ARRL advocates for
protecting the privacy of radio amateurs.

Delete Obsolete Identification Requirement for Special Call Signs

Users of special event call signs are required to identify with the FCC-issued
responsible call sign at least once each hour.� This can be confusing,
especially on data and CW modes. ARRL proposed reliance on the web-based
database that clearly identifies each special event call sign and authorized
period of use.

Delete Obsolete Paper License Replacement Provision

The FCC no longer mails physical copies of amateur radio licenses, so ARRL
suggested deleting the rule that provides for sending paper replacements as
obsolete.

The FCC notice[3] [PDF] generated a lot of interest among radio amateurs, with
hundreds of Amateurs submitting comments directly to the FCC as well as
responding to ARRL's request for suggestions.

The FCC deadline for filing reply comments is April 28, 2025.

It is hoped that the Commission will incorporate worthy suggestions in a future
Notice of Proposed Rulemaking (NPRM) later this year. At that time there will
be a new opportunity for public comment on the specific rules that the
Commission proposes to delete or modify.


[1] https://www.arrl.org/files/file/Advocacy/ARRL%2025-133%20Comments%2004_11_2025.pdf
[2] https://www.arrl.org/news/fcc-initiates-broad-inquiry-on-rules-to-delete-or-amend
[3] https://docs.fcc.gov/public/attachments/DA-25-219A1.pdf

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