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. KX4Z

    KX4Z Ham Member QRZ Page

    OK, now for part II.

    Again, I'm NOT an expert, and this stuff is horribly confusing.

    There was a big deal about 4 years ago when all of a sudden, WINLINK began allowing software configurations that allowed automated relaying of messages ("radio-only") to deal with the potential scenario of complete overwhelming (denial of service?) or failure of the internet. I have been told this was requested by the Department of Homeland Security (for shares? for both? I don't know). That had me very nervous at first, but the FCC has specific bands where this is completely obviously many of us enabled that.

    Here is a statement out of the ARRL Extra Class license Manual for you to chew on (11th Edition) as I am:
    "There are special rules about the third-party messages and automatically controlled statos because of the power of message forwarding network. Third-party trafic is not limited to radiograms -- it can be e-mail, digital files or even keyboard to keyboard chat sessions if the content is transferred on behalf of someone who is not a licensed amateur. Automatically controlled stations may only relay third-party communications as RTTY or data emissions are never allowed to originate the messages [E1C05]"

    So jump to E1C05 question on page 13-9 of the same manual and look to see what the justifications are it lists:
    E1C05 When may an automatically controlled station originate third party communications. (A) Never. [Answer B, which they indicate is incorrect, says, "Only when transmitting RTTY or data emission."]

    I *think* they get that choice of correct answer 'A' ("never") from 97.115(b) where (1) shows the requirement for a human at the originating station:

    §97.115 Third party communications.
    (a) An amateur station may transmit messages for a third party to: [see the text for the rest, this is here for completeness]
    (b) The third party may participate in stating the message where:
    (1) The control operator is present at the control point and is continuously monitoring and supervising the third party's participation; and...

    Perhaps you see the problem? The same people who wrote this part, also wrote page 3-10 of Chapter 3 where it explained that a human using a radio to connect to an RMS to retrieve messages is using a REMOTELY controlled station --- so there is no automatically controlled station in use in that scenario and there is therefore no ORIGINATION of any email from a third party by an AUTOMATICALLY CONTROLLED station.

    Now lets' take the situation where the radio-only portion is being practiced, and a non-licensed Emergency Manager of an EOC gives a message to an amateur who puts it on the WINLINK system (local control) to connect to an RMS (remotely controlled by the amateur per the ARRL) and upload the message.

    The RMS stores the message and then AUTOMATICALLY computes a relay, and makes an AUTOMATIC connection to the next station in a relay chain to get the message to the message pickup station of the receiving amateur [by definition, the radio-only system cannot deliver to a gmail type address....] -- and is then an automatic relaying station of third party traffic. Where is this in the rules?

    it is in 97.115(c)

    (c) No station may transmit third party communications while being automatically controlled except a station transmitting a RTTY or data emission. " [emphasis added.]

    Oh my, this is all horribly complicated and makes my head spin. But if you take what the license manual least it all fits together.

    Of course, the folks who write the License Manual are not federal judges.... and there do not appear to be individual authorship specified. on page v, David Sumner, K1ZZ, invidts anyone with suggestions or corrections to send them to

    Whew....this stuff is horribly complicated. That's the best I can with it right at this moment.
  2. KX4Z

    KX4Z Ham Member QRZ Page

    Hi.... as you may see from the preceding very long explanations coming out of the ARRL License Manual Etra Class 11th Edition....I thought Ron was correct on this.....

    I had found the repeater answer and now I've lost it....I think he's right there [when I find it, I'll point it out, but I'm out of time right now with an appointment coming up]

    But on the ACDS -- well, the ARRL seems to explain that it isn't an ACDS.... it is a remotely controlled station. And that makes a huge difference -- you can read it on the last two sentences onpage 3-10 of Chapter 3.

    The reason that I have to keep my RMS within the ACDS (97.221(b)) space is because it can also be an automatically controlled station -- when operating within the radio-only network, and because I have allowed bandwidths greater than 500 Hz.

    Stations operating within the WINLINK system NOT as part of the radio-only system may be located within the slivers allowed for the wider bandwidth operation....or currently anywhere in the cw/rtty segments WITH A BANDWIDTH OF 500 or less. As i showed in earlier work, there aren't many of those [in the USA] ...and they use an almost negligible amount of time/bandwidth [from USA stations]

    i know this may be clear as mud, but it took me about 2 hours to try and figure it out.
    Again, thank you for your input.

    Gordon Kx4Z
  3. ND6M

    ND6M Ham Member QRZ Page

  4. N4QX

    N4QX Premium Subscriber QRZ Page

    Neck deep in paying work and may not be able to pay attention, but nothing would please me more than being able to eat my words.
  5. KL7AJ

    KL7AJ XML Subscriber QRZ Page

    This is probably a no-brainer, but when it comes to playing nicely on the ham bands, bandwidth is FAR more important than symbol rate. While there is a relationship, the bottom line is bandwidth. See W8JI's excellent treatise on the concept (a few years old now, but very valid).
    KX4O likes this.
  6. KX4Z

    KX4Z Ham Member QRZ Page

    I’m with you. This stuff is horribly complicated, and not of much interest to me at all. I don’t get my jollies from rules and regulations. But it was very important to Ron, and it was very important to N4QX that I acknowledge anything that was correct— which is an honorable way to be.

    But it’s so horribly complicated that I had to sit and get the time together to go through it all and see if I could figure it out. The fellow who is teaching that section of our extra class course in August, said he thought I had it correct. But he is just going on what the ARRL said just as I am. There is a consistency to it, whereas the actual FCC regulations seem to have an issue where they are not internally consistent. I think that probably happens often in complicated regulations.

    The upshot is that a third-party non-amateur cannot have an echo link account. You see that pretty clearly when you try to get your own echo link account, they go through a lot of work to make sure you are an amateur. When you key the repeater through EchoLink you are literally turning it on. When you send an email to the WINLINK network you are not at that point turning on any transmitter. The ARL’s position is consistent, the amateur who does turn on a transmitter and then cause another transmitter to respond, it is actually the one driving transmission.

    So then you download something and discover it is objectionable. Your remedy in this case could include taking that person off your ”whitelist”. But you really can’t do anything until you’ve read the email.
    You may be both the first amateur to look at it, and also the first amateur to cause it to be sent over airwaves.

  7. KX4Z

    KX4Z Ham Member QRZ Page

    I don’t know if this is the one that you’re mentioning but it is very useful. Makes good sense and explains why we should keep narrow stuff generally together.

    thank you for passing along
  8. KL7AJ

    KL7AJ XML Subscriber QRZ Page

    Yep, that's the one.
  9. K0IDT

    K0IDT Ham Member QRZ Page 18, 2019 Ex Parte Filing.pdf

    Here is the link to the FCC filing. Of the two attachments the critical one is the first one. This was presented
    by our side during the negotiations, and differs only in the amount of spectrum allowed in the proposed bandplan.

    The negotiations were broken down into two separate issues, interference and openness. Over the 4th of July
    weekend the interference issue we were tasked to resolve was completed but contingent on ARSFI producing
    something acceptable on openness, they did not.

    There's a third item to consider, the ARRL. Right now the board is meeting and deciding on how to proceed with
    16-239 and RM-11831. Several of the board members have already expressed in public that their minds were made
    up prior to the meeting, and any presentation of the negotiations, to push for enactment of 16-239 and reject RM11831.
    If the ARRL uses ANY of the negotiation material as a representation of what was agreed to, including any new bandplan,
    it further demonstrates the League was hardly a fair, honest mediator in the process. The negotiations became null and
    void when ARSFI failed to produce anything regarding open over the air communications. How the negotiations can be
    characterized as "winner take all" when one side provides generous compromises and the other side won't accept
    anything but the status quo on open amateur communications is beyond me.

    This is what was presented, minus some increased spectrum, in front of the ARRL and ARSFI. I would welcome ARSFI
    to post their slide deck, as presented, in this thread or any other public forum. I have it but as I said I'm not at liberty
    to provide a comment.

    The ECFS is having some problems right now and this may not show up under the various
    proceedings yet.
    Last edited: Jul 19, 2019
    KX4O likes this.
  10. KK5JY

    KK5JY Premium Subscriber QRZ Page

    If FCC is paying any attention to this issue after all the back-and-forth, they have to be saying to themselves that this is "CC&R, the sequel." If they decide anything, they're going to be flooded with petitions for reconsideration indefinitely, and since they don't do Part 97 enforcement anyway, rule changes are moot.

    If they say anything at all to close this, I suspect it will be to cite treaty obligations (or lack thereof) and say that they are doing what they are required to do (or not required to do).
    KX4O likes this.

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