About a week ago, the FCC announced that it is accepting comments on a Petition for Rule Making (RM-11831) that seeks to change the rules to require that all digital transmissions use techniques “whose technical characteristics have been documented publicly.” Filed by Ron Kolarik, K0IDT, the petition expresses concerns that some currently used digital modes are not readily and freely able to be decoded, and it asks the FCC to require all digital codes to use protocols that “can be monitored in [their] entirety by third parties with freely available, open-source software,” per §97.113(a)(4).
I was informed of this petition by Janis Carson, AB2RA. She supports the petition and says:
- RM-11831 ensures the ability to identify and monitor the radio transmissions of any data signal using readily available over-the-air interception methods by third parties, as required by Part 97.113(a)(4) and 97.119(a).
- Without open, over-the-air interception capability for all transmissions in the amateur radio spectrum, there is no way to determine if there is commercial, or other prohibited inappropriate content in ongoing communications over the amateur radio spectrum. FCC DA 13-1918 ¶ 6
- RM-11831 assures that the amateur radio service will not be used to bypass commercial internet or email services or be used for commercial use as required by Part 97.1, 97.3(4), 97.113(a)(5)
- Eliminating Part 97.221(c) as RM-11831 proposes would solve long standing interference issues suffered by radio amateurs wishing to use the HF RTTY/Data sub bands for other mainstream and emerging digital modes rather than ACDS purposes.
Dan White, W5DNT, also contacted me about this proposal. He notes, “RM-11831, is a very well thought out, and actually quite elegant, solution. It’s quite simple. ACDS would be confined to the Part 97 Sec 221(b) “data sub bands” plus 6M and above.” He also urges:
Please consider at least a simple “express filing” in strong support of RM-11831. Filing instructions are shown below and the process will only take a few minutes of your time.
http://www.wirelessgirl.net/HowToFile11831Express.html
The filing deadline is April 28, 2019.
Please help spread the word to your friends and together let’s ensure the viability of our CW, RTTY, FT-8, JT-65, PSK HF spectrum, while still allowing ACDS ample HF space, along with VHF and up, to operate on an unencrypted basis, as is the spirit and requirement for the amateur radio service.
Personally, I’m not sure how I feel about this. I’ve personally not encountered any interference from an automatically-controlled digital station, but I can see where there’s a good possibility that this could happen if the rules changed proposed by RM-11708 and WT 16-239 were to be adopted. Those that seem to know more about this than I do seem sufficiently behind the petition, so I’m inclined to be as well.
What are your thoughts?
Interesting idea and I always support open source software.
But this would mean you could no longer use DMR and therefore I think not many people will sign it. The AMBE encoder / decoder is not open source. The same applies for D-Star and System Fusion and all other digital speech modes, as far as I know. FreeDV being the only exception I am aware of.
This is not needed at all. It reads like some old timers don’t want to keep up with the times/modes so they want to punish the rest of us. I view this more as a attack on digital modes then a help. So this means new modes are out and if we aren’t careful modes like DMR and Dstar will be gone too. I also find the wording presumptuous, I have not once in almost 10 years heard one person complain about digital mode interference outside of RTTY contests. To name FT8 and FT8Call(JS8CALL) just tells me this is again a personal attack by some disgruntled old timers. The modes that are “named” take up such a small sliver and are documented if you are willing to look. A google search of the frequency often yields all the info you need to start decoding. I hope this does NOT pass.
Well said…. The petitioner is a OLD TIMER for sure
You really need to read the petition carefully before jumping to conclusions.
None of the digital voice modes are affected. It only applies to HF and it only clarifies existing rules in one case. It’s actually very simple, any new mode must have the technical details published and means to decode the mode by 3rd parties made available.
David, please learn some manners, “some old timers” and “presumptuous” don’t help.
Try reading the links in the footnotes of the petition and see how many of your fellow hams have been interfered with by the <500Hz ACDS stations.
K0IDT
I did read it and it does read like a grumpy om not liking a few modes so he is going to ruin it for all. The fact he names ft8 and js8call claims it’s not discernible by ear is rubish. The modes he complains about are very easily decoded and documemted. I also find his tone about “hams” all complain about these modes is not true at all, just because a few are loud and make posts on petitions. If me calling it like it is means I have no manners you should read up on what manners are. My manners have nothing to do with my reply.
I do find it funny it’s ok for the guy who wrote the petition to make presumptions but heaven forbid anyone refutes them.
Well Said…
What I get from this is it is a reinforcement of the rule that no amateur radio communications should be encrypted. Why the controversy? This has been the rule nearly since the dawn of licensed amateur radio operation. This measure just attempts to include digital modes in the rule that has been at the heart of amateur radio for as long as it has been going on. No big mystery here, no danger, no problems. This is a basic principle of amateur radio so it should be no surprise that the latest modes and methods should be included in the rules. I for one have no problem in supporting this.
None are being encrypted NOW… The Rules do not need changed.
David,
“The fact he names ft8 and js8call claims it’s not discernible by ear is rubish.”
The exact quote is “The ever growing number of digital modes, most recently FT8 and FT8call1, present some unique problems for anyone attempting to monitor them, for instance: is the protocol easily identified by sound or appearance in a video waterfall.”
That seems pretty clear to most people, is it easily identified by ear or waterfall. Never said it wasn’t discernible, and there seems to be a rash of people cherry picking the petition without supplying full quotes or sufficient reading comprehension.
Here’s another take on this topic: https://www.theregister.co.uk/2019/04/05/amateur_radio_spectrum/
I do believe that all protocols should be published. Otherwise they are too close to codes which obscure the meaning. Until recently, as far as I know they have.
Perhaps sometimes equipment has been expensive (early RTTY for example), but it’s still been open.
Now you have PACTOR which has proprietary modes which are not published. I’d like to see a ruling on this one way or the other.
The other thing is unnatended HF operations. Too much of that will cause issues. Perhaps they should only be allowed by Extra class hams?
ALL Current Protocols are Published, not is encrypted all Compression Schemes are Published.
I guess some do not understand Part 97 …
“Personally, I’m not sure how I feel about this. I’ve personally not encountered any interference from an automatically-controlled digital station, but I can see where there’s a good possibility that this could happen if the rules changed proposed by RM-11708 and WT 16-239 were to be adopted.”
Still balderdash, still batsqueeze, and still rot. Allowed symbol rate has zilch to do with the frequencies on which automatic wide bandwidth digital stations are permitted under 97.211.
You presumably write about this rule in your study guides, Dan. You do not live up to the “No Nonsense” appellation by buying into the noise that is utterly irrelevant to the issue at hand in the symbol rate proceeding.
I seem to remember when Winlink had its ARRL backing in 2004 a lot of us felt that the interference would abound. It never has… When we expressed concern we were told we had to tolerate the interference. But there has been very little to none. Fact remains the Rules do not need changed.. in 2004 I ran HF at 300 baud AX25 Packet.. Never seen the first instance of interference by WINLINK..
RTTY on the other and .. By god the rudest group of HAMS I have ever met. You ask them to not squash your QSO and they call you every name in the book.. (Not on air) but via email.. If you bother to email them…. I say through this Bogus bunch of Crap out the window. 73