At present, there exists some ambiguity in Part 97 that has led to uncertainty and disagreement among frequency coordinations nationwide as coordination pertains to digital voice repeaters.  Specifically, the major issue in question is how "repeater" is defined in 47 CFR 97.3(a).  The definition of "repeater is "An amateur station that simultaneously retransmits the transmission of another amateur station on a different channel or channels." Some have argued that the definition should not apply to digital voice repeaters due to their inherent delay in repeating the digital audio, thereby disqualify them by virtue of the repeating not being done "simultaneously".  The majority of coordinators, including ARCC, believe that any duplex repeater, analog or digital, is transmitting and receiving simultaneously, even if there is a delay as is often the case of even analog repeaters, many of which have intentional audio delay built in to eliminate squelch tails.  At the very least, every repeater has propagation delays both in the RF path and audio circuitry; there is no such thing as a "zero delay" repeater.

In order to attempt to come to a conclusion on this issue, the National Frequency Coordinators' Council (NFCC) has requested the FCC provide clarification as well as revise the definition of "repeater" to eliminate this point of contention.  To date, the FCC has not responded.  Until the matter is resolved, ARCC will continue to accept applications for new digital voice repeaters subject to the policies outlined above, and will hold them in a first-come first-served queue until the matter is resolved.