NYU Files Petition for Declaratory Ruling to Clarify 97.113(a)4 of the Commission's Rules

Discussion in 'Ham Radio Discussions' started by W6EM, Oct 25, 2019.

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  1. W6EM

    W6EM Ham Member QRZ Page

    The enemy of my enemy is my friend. :)
    If the FCC understands that P4 and VARA utilize SS techniques, then only limited storm ports left for safe harbor........
    Winlink routinely airs 3rd party authored email coming from the Internet without sender permission....... 18USC2702 et. seq.
  2. W3WN

    W3WN Premium Subscriber QRZ Page

    I have no dog in this fight. I'm just trying to figure out what is going on.

    There is so much contradictory information out there, to say nothing of some of the deliberate... let's say misdirection, or at best, very one-sided statements of potentially questionable accuracy... and on top of that, some of the egos involved and the clear determination by some that they will prevail (right or wrong), damn the torpedoes, full speed ahead...

    Trying to take the best, unbiased course of action may not be possible.

    And if WE (as a whole) can't figure out this mess, can we REALLY expect the FCC to do what's best for us, and not what's easiest for them?
  3. KX4O

    KX4O Ham Member QRZ Page

    I can shed some light on this. They are focused on the Pactor aspect that is clearly a part of the brouhaha. Here are a few points in no particular order that might add clarity.
    • The aren't really opposed to over the air copy of their digital signals since Pactor can be coped with a modem (not cheap, but certainly legal for now at least).
    • As most of you have already figured out, RRI is the result of revolution against the ARRL's lackluster support of NTS as any sort of solution to moving messages from point A to B. I write about it here.
    • They use Pactor variants for their digital relay operations in their new DTN system... as was done in the previous NTSd for decades. Really not much changed except the name and management.
    • There are several ways NTS messages move between computing systems: BPQ32, Airmail and probably some others.
    • BPQ32 does sometimes use the 20+ year old LZHUF compression when relaying between two BPQ32 systems.
    • I don't know if the Airmail client system uses this compression because typically client to BPQ32 interactions are entirely uncompressed.
    • As I observed when monitoring for Pactor/Winlink transmissions most of the sessions were Pactor/NTS. Unlike Winlink's silly notion to ensure the Pactor modem always operate without modem level compression, NTS makes no such requirement leaving the Pactor modem free to decide what's best for the transfer of that particular frame (something many of us agree with). As Pactor to Pactor is always transparent, this makes sense giving NTS the edge in logical use of a modems... IMO.
    • Being so small, NTS messages are always fairly thrifty in size (unlink some of the emails we see in Winlink) therefore placing a modest "load" on the airwaves.
    • The digital version of RRI/NTS seems to be a bit more prevalent in the ACDS than Winlink... as far as I can see anyway, but I admit my data set is small since I only bothered listening long enough to successfully prove monitorablity of Pactor/Winlink.
    • RRI and NTS support the use of Winlink in some way, but they don't seem to place all their marbles in that basket.
    This may seem weird, but I admire what was done to create RRI. It takes some guts to actually solve a perceived problem rather than just cry about it. It's for these reasons and others I do lend my support to RRI. That said, other than the logical defense of Pactor, I'm not sure I would have worded their ECFS the way they did. NYU has done a pretty magnificent job of shooting themselves in the foot a few times now leaving little reason to interfere, but I guess there is a place for some blowback.
  4. N1FM

    N1FM Premium Subscriber QRZ Page

    I don't really find this Petition to be unreasonable. I understand SCS makes money selling modems with proprietary compression schemes, and normally I come down on the side of free enterprise and fewer regulations, but there is a self-enforcement function involved in amateur radio. Although it has been demonstrated there's an ability to decode under controlled conditions, it's not easy. I also think email via amateur radio comes with a host of problems, but the Kolarik petition doesn't seek to eliminate any mode. It comes down to the FCC to make a decision -- Status Quo, or a change. I just hope they don't split the baby down the middle where nobody will be happy.

    What the petition will do.
    A. Only two simple changes requested.
    B. Moves all 97.221(c) operation into the ACDS segments with other unattended stations.
    C. Requires a decoder be provided for OTA decoding of current and future digital modes.

    https://ecfsapi.fcc.gov/file/10428309711643/Reply to comments.pdf
  5. KX4O

    KX4O Ham Member QRZ Page

    I'm all for this and RRI/NTS probably wouldn't be affected IMO. It would be nice to have the ACDS a touch larger on 40m, but as Ron says, they (the WL supporters at the various or maybe one negotiation) wanted more than that. Oh well.
    Monitoring Pactor has always been possible, but at a price... sometimes a hefty one if one likes new gear (me sadly). I guess price is a major concern to many. Of course modem money is rounding error magnitudes for institutions and gubment negating this ridiculous notion...

    “In my personal conversations with FBI and FCC officials, they admit they also are unable to readily decode these types of transmissions,”​

    Don't personally know about the FCC, but the FBI, of course, can readily decode if they want to. He asked the wrong people I guess.
  6. KX4O

    KX4O Ham Member QRZ Page

    This ^^^^
    If it isn't obvious yet, the FCC doesn't want to over regulate us unless forced. If forced... we all might be dumbfounded at the result.
  7. K0IDT

    K0IDT Ham Member QRZ Page

    Related to the current topic, is this the replacement for ham emcomm, "Network Radios"? Some of the faithful should be afraid, very afraid.
    WE4B likes this.
  8. K0IDT

    K0IDT Ham Member QRZ Page

    IARU Region 2 bandplan says 6kHz is adequate. There really isn't much need for more than that if WL learned how, or even wanted, to actually manage their network. Their clients need to learn some manners and dicipline too.

    I'm still bound by agreement not to disclose any positions taken during the July negotiations, but there is nothing preventing me from disclosing what wasn't put on the table. Let's just say if you want more spectrum a proposed bandplan
    is always a good item to have at the start, ours can be found on the ECFS.

    Waiting for the ARRL bandplan, got the pitchfork and torch ready. If I had to guess, with the backdoor games the EC played on the 16-239 ex parte, by going against the Board passed resolution, I'm going to have lots of company storming HQ, lots of it.
    KX4O likes this.
  9. KX4O

    KX4O Ham Member QRZ Page

    I say the more the merrier. Gotta love maverick efforts. Most fail, some more fail, some bear fruit. Amateur radio might even have a real role in this as part of some specific task that suits it. Not sure what this means yet, but small amounts of data that fits into available bandwidths might make sense. Believe it or not NTS (RRI) fits in perhaps. Small, tidy, functional, yes old, but practical... maybe.
  10. N1FM

    N1FM Premium Subscriber QRZ Page

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