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?