ARRL report - No Consensus Reached for FCC on “Symbol Rate” Issues

Discussion in 'Ham Radio Discussions' started by W0PV, Jul 17, 2019.

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  1. K0IDT

    K0IDT Ham Member QRZ Page

    You're not going to post the link are you? Nice, you claim to have a page of stuff of where you say I'm wrong but won't post it for review by everyone.

    C'ya Gordon
  2. WZ7U

    WZ7U Ham Member QRZ Page

    This thread devolved into a pissing match, just like all the others have. I'm not sure we're going to have ham radio in the future if we as hams present this sort of front to the regulatory officials on a regular basis.

    Smoke em while you got em.
  3. KB9MWR

    KB9MWR Ham Member QRZ Page

    This is why it would be better if the FCC would weigh in and just make a decision based on logic rather than this whole thing being ruled by emotion.
    K0IDT and KX4O like this.
  4. W0PV

    W0PV Ham Member QRZ Page

    Repeated from the OP,

    As a result of the meeting, what issues formed a consensus?

    NDA be damned, it is unreasonable that constructive info is not publicized.
    NL7W likes this.
  5. N8OHU

    N8OHU Ham Member QRZ Page

    I think what Ron is waiting for is an apparently agreed upon time period where they would not discuss it to end.
  6. K0IDT

    K0IDT Ham Member QRZ Page

    Matthew, what I'm waiting for is the information to post on the ECFS so I can link to it. The same information has already been sent to all the ARRL directors, and a few others at the league. The posting to the FCC site was this morning.
    The material needs to be in the public domain before it gets linked here. Now, by agreement, I am unable to even comment on what the other side put forth in the meeting, it's up to ARSFI to do that if they so choose. All I can do is apologize for the delay at this point.
    AB2RA, KX4O and NL7W like this.
  7. AK4XL

    AK4XL Ham Member QRZ Page

    I've been following this (these?) controversy off and on. I recall when I first got my license in 2012 hearing about D*STAR radios using a proprietary chip to compress and send digitized voice (the tech info was NOT available), thus making it effectively the "e' word. That seemed pretty clear cut to me, and I don't know how it wasn't banned on the amateur bands.

    But this is a weak argument against digital modes in general:
    The message this is responding to made it clear that it's about receiving the transmitted signal strong enough to successfully decode the message. This has always been a challenge of amateur radio.

    The FCC NEVER COULD listen to and understand every amateur communication or transmission, even presuming they could hire enough people to listen 24/7. If the only two hams in a small town communicate CW QRP at 30 words per minute, there's most likely no one else around to pick up the signal. Actually, the FCC rules REQUIRE that one use the MINIMUM amount of power to communicate, so presuming they follow that rule, the only person who could possibly hear their transmissions is a SWL listener in that same town. Is the listener going to have a Morse code decoder, or be able to copy 30 wpm? I think he's going to keep turning the dial.
    KX4Z and KX4O like this.
  8. W6EM

    W6EM Ham Member QRZ Page

    Ron- I scanned the ECFS register for all filings posted today. Only 6 were. And, all were internal, FCC Bureau filings. No proceedings comments at all. Very strange. Maybe a people or equipment problem. Tomorrow should see it.

    I can't wait for the "Winlink Email Server Control Operator" to get what he deserves for all the entertaining 3rd party emails he allowed to be transmitted.... :=)
    AB2RA likes this.
  9. KX4Z

    KX4Z Ham Member QRZ Page

    And that is honorable. Good job.
    AB2RA likes this.
  10. KX4Z

    KX4Z Ham Member QRZ Page

    A good night's sleep. I'm still not an expert, but I've tried to review the information you helpfully provided as well as some other information. Some of it is pretty clear (and you were correct); some of it is still cloudy. I initiated an email on one point to some others to ask for some clarification.

    Way way back there, Ron stated,
    " the control operator of the automatic station is the license holder for that station. A client activating an RMS has absolutely NO CONTROL of the actual operation"

    And I responded that [at that point] I thought he was correct on the first part, and not on the second. There were a lot of questions after that, and I got tired and confused. I'm still somewhat confused, but here is what I found:

    97.7 indicates that in the FCC view, there is always a control operator:
    "§97.7 Control operator required.
    When transmitting, each amateur station must have a control operator. The control operator must be a person:
    (a) For whom an amateur operator/primary station license grant appears on the ULS consolidated licensee database, or (b) Who is authorized for alien reciprocal operation by §97.107 of this part."

    I had found something which I thought confirmed Ron's first part ("the control operator of the automatic station is the license holder for that station" [and I think he means the station license.] ) but now I'm having problems remembering what it was.

    The FCC defines "Control Operator": " (13) Control operator. An amateur operator designated by the licensee of a station to be responsible for the transmissions from that station to assure compliance with the FCC Rules."

    and also defines:
    "(32) Message forwarding system. A group of amateur stations participating in a voluntary, cooperative, interactive arrangement where communications are sent from the control operator of an originating station to the control operator of one or more destination stations by one or more forwarding stations."

    and also defines:
    "(47) Third party communications. A message from the control operator (first party) of an amateur station to another amateur station control operator (second party) on behalf of another person (third party)."

    So gee, if you have an automatically controlled station being interrogated by a locally controlled station, one would think that based on the way they handle repeater stations that the control operator of the automatically controlled station would be the station license holder, right? And I can't remember, but I suspect that is where I thought Ron was correct! But now there is a flaw in the ointment, because when reviewing this stuff in the ARRL Extra Class License Manual [see later for a place where i think they got something WRONG, so don't take these people as authoritative, remember my earlier statement that the law is what a judge says it is....]

    ARRL. Chapter 3, page 3-10, 11th Edition:
    "Another common example of remotely-controlled stations are the digital Winlink RMS PACTOR stations ( that wait for a station to call them before responding. The RMS station is considered to be remotely controlled by the calling operator."

    Huh? So in the ARRL's view, it isn't an automatically controlled station in that view -- it is REMOTELY controlled, and the control operator is....the calling operator?? Look back at the definition (32) Message forwarding system -- and it appears they are saying that the two control operators in this case are the same person -- the control operator of the locally controlled [calling] station.

    Wierd, huh?
    So maybe some of you folks are brighter than me and you can set me straight if the ARRL is wrong here.

    Look at 97.221(c) and you'll see that there appears to be an inconsistency--
    "(c) Except for channels specified in §97.303(h), a station may be automatically controlled while transmitting a RTTY or data emission on any other frequency authorized for such emission types provided that:
    (1) The station is responding to interrogation by a station under local or remote control;...."

    Because there the rules imply that the station interrogating [the caller?] has the human operator, and the station answering is being automatically controlled.

    Here are some other things that apply to message forwrding systems:
    §97.219 Message forwarding system.
    (a) Any amateur station may participate in a message forwarding system, subject to the privileges of the class of operator license held.
    (b) For stations participating in a message forwarding system, the control operator of the station originating a message is primarily accountable for any violation of the rules in this part contained in the message.
    (c) Except as noted in (d) of this section, for stations participating in a message forwarding system, the control operators of forwarding stations that retransmit inadvertently communications that violate the rules in this part are not accountable for the violative communications. They are, however, responsible for discontinuing such communications once they become aware of their presence

    So if a human operator (local control) calls up an RMS and retrieves a message....the RMS is originating the message, and by 97.219(b) the control operator of that RMS (and originating) station is responsible --- and it is the OPERATOR OF THE CALLING STATION according to the ARRL because the RMS is not an automatically controlled station; it is a remotely controlled station.....

    I'll follow with another issue in this same area where the ARRL may have gotten it wrong. But again....I'm NOT an expert here. There may be case law that explains or corrects some of what is confusing here.

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