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#FCC #DigitalModes: New Petition for Rule Making RM-11831 #fcc

M5AKA
 

FCC asking for comments on new Petition for Rule Making RM-11831 which calls for "Amateur Digital Mode Transparency".

Would require all digital codes to use protocols that “can be monitored in [there] entirety by third parties with freely available, open-source software,” per §97.113(a)(4).
Petition for Rule Making Calls for “Amateur Digital Mode Transparency”


73 Trevor M5AKA

Andrew OBrien
 

It makes no sense to do this retroactively .  This would impact  Pactor, Dstar, Fusion, DMR, and possible ALE. 
Andy K3UK 

ALE
 


There would be no impact to MIL-STD 2G ALE or AQC-ALE which are already FCC legal on all of MF/HF as long as Link Protection is not used as plenty of tools are freely available to monitor both.

3G ALE which is legal on 60 meters is another matter as to free tools being available, however all the details of 3G ALE as per MIL-STD-188-141D and STANAG 4538 permit the creation of such free tools. There are plenty of sound card software tools available that can be bought to monitor 3G ALE.

/s/ Steve, N2CKH


At 08:12 PM 4/2/2019, you wrote:
It makes no sense to do this retroactively .  This would impact  Pactor, Dstar, Fusion, DMR, and possible ALE.
Andy K3UK 

Graham
 

Kolarik contended in his petition that FCC action stemming from ARRL’s 2013 “symbol rate” Petition for Rule Making could increase congestion (i.e., interference) problems. In July 2016, the FCC in WT Docket 16-239 proposed to revise the Part 97 rules to eliminate current baud rate limitations for data 

For  a  'technical person'  its difficult to  assimilate  the  position's taken in the petition , appears to be based on
obsolete concepts ?.

Take the  300  baud max rate ,  technology  has advanced to the  point , this this is no longer relevant,  OFDM has now  rendered  high speed  serial carrier systems to be  obsolete ,  In a series of tests ,  carried  out , comparing the  VARA modem against other systems ,  VARA  HF  provided  higher  data  transfer , at lower power  levels than  Pactor 4 , in either direct or nivs path.. 

The on-air  carrier rate  for  vara  is round  37 Baud , maintaining compatibility , with  'all' propagation  modes

: link to  the  published  article :VARA review in HBradio

Channel  congestion / interference 

Making no reference to the  benefits of  2G , in terms of  bandwidth efficiency/access , although , apparently  well  versed in the  subject's , would of expected some  solution to the  issues , again , seeking to  diminish, rather than  innovate ?

73-Graham
g0nbd

ALE
 


Grahm I take exception to that OFDM vs. serial tone modems comment.

The U.S. Military as well as NATO and even SCS long ago determined that serial tone modems out perform OFDM.

U.S. MIL-STD and STANAG data modems and 3G/4G ALE from 3kHz through 48kHz bandwidths are all 2400 baud symbol rate serial tone modem based. The burst waveform 3G ALE and above provide even better performance than do the continuous waveform data modems due to short bursts prevailing over changes in channel conditions. This too is something SCS implemented with their serial tone based P4 modems.

If only the FCC would drop that darn 300 baud symbol rate limitation the U.S. ARS would find this out as well.

Sincerely,

/s/ Steve, N2CKH


At 10:38 AM 4/3/2019, you wrote:
Kolarik contended in his petition that FCC action stemming from ARRLs 2013 symbol rate Petition for Rule Making could increase congestion (i.e., interference) problems. In July 2016, the FCC in WT Docket 16-239 proposed to revise the Part 97 rules to eliminate current baud rate limitations for data

For  a  'technical person'  its difficult to  assimilate  the  position's taken in the petition , appears to be based on
obsolete concepts ?.

Take the  300  baud max rate ,  technology  has advanced to the  point , this this is no longer relevant,  OFDM has now  rendered  high speed  serial carrier systems to be  obsolete ,  In a series of tests ,  carried  out , comparing the  VARA modem against other systems ,  VARA  HF  provided  higher  data  transfer , at lower power  levels than  Pactor 4 , in either direct or nivs path..

The on-air  carrier rate  for  vara  is round  37 Baud , maintaining compatibility , with  'all' propagation  modes

: link to  the  published  article : VARA review in HBradio

Channel  congestion / interference

Making no reference to the  benefits of  2G , in terms of  bandwidth efficiency/access , although , apparently  well  versed in the  subject's , would of expected some  solution to the  issues , again , seeking to  diminish, rather than  innovate ?

73-Graham
g0nbd

Graham
 

Steve, 

Point taken, 

The test  shows  transfer   P4  at  19,600  2 min 46 sec   VARA  at  24,700 2 min flat in 2.2 kHz b/w 
30% speed increase, with a lower power budget ,  

This meet the  only real test ,  data transferred / power expended 

The main issue  is the  impending  petition , that seeks to  degrade accesses , 
my observation, is it it appears to be  narrow in its thrust 

73-Graham 

 

My comments (sorry about the typo in the downloaded file name, it is not easily fixed, but the link will bring it up) -- Comments RM-11831.docx 



John D. Hays
Edmonds, WA
K7VE

   

Graham
 

Something has just occurred to me,  the  contents of this  are  very similar  to another  exchange  with the  FCC 

https://www.rrmediagroup.com/News/NewsDetails/NewsID/17667

one and the  same ?

73-Graham 

ALE
 


Well it has been a long standing requirement on the FCC side that waveforms used on the Amateur Radio Service be sufficiently detailed in public that one could implement a decoder. For example when WINMOR came along the following was published:

http://www.arrl.org/files/file/WINMOR.pdf

The FCC does not and in my opinion should not, require that decoding software be provided.

However, it is my opinion if a waveform is not detailed sufficiently, as illustrated above, it has no place in being used on the ARS bands and the FCC agrees with that.

The MIL-STD and STANAG serial tone waveforms that I am focused on are so documented. However they are shut out from use do to their symbol rate on all but 60 meters below 6 meters when implemented without modification.

/s/ Steve


At 11:38 AM 4/3/2019, you wrote:
Steve,

Point taken,

The test  shows  transfer   P4  at  19,600  2 min 46 sec   VARA  at  24,700 2 min flat in 2.2 kHz b/w
30% speed increase, with a lower power budget , 

This meet the  only real test ,  data transferred / power expended

The main issue  is the  impending  petition , that seeks to  degrade accesses ,
my observation, is it it appears to be  narrow in its thrust

73-Graham 

 

But they have not precluded proprietary (eg. patented) methods to be used, even if it required obtaining a technology license to decode.  Remember, SSB and FM were patented "waveforms" at one time.  There is a difference between encoding and encryption.

On Wed, Apr 3, 2019 at 11:45 AM ALE <n2ckh@...> wrote:

Well it has been a long standing requirement on the FCC side that waveforms used on the Amateur Radio Service be sufficiently detailed in public that one could implement a decoder. For example when WINMOR came along the following was published:

http://www.arrl.org/files/file/WINMOR.pdf

The FCC does not and in my opinion should not, require that decoding software be provided.

However, it is my opinion if a waveform is not detailed sufficiently, as illustrated above, it has no place in being used on the ARS bands and the FCC agrees with that.

The MIL-STD and STANAG serial tone waveforms that I am focused on are so documented. However they are shut out from use do to their symbol rate on all but 60 meters below 6 meters when implemented without modification.

/s/ Steve

At 11:38 AM 4/3/2019, you wrote:
Steve,

Point taken,

The test  shows  transfer   P4  at  19,600  2 min 46 sec   VARA  at  24,700 2 min flat in 2.2 kHz b/w
30% speed increase, with a lower power budget , 

This meet the  only real test ,  data transferred / power expended

The main issue  is the  impending  petition , that seeks to  degrade accesses ,
my observation, is it it appears to be  narrow in its thrust

73-Graham 



--


John D. Hays
Edmonds, WA
K7VE

   

ALE
 


Hi Jim,

There is a difference between published and proprietary data encryption schemes as well, public and private keys for that matter too.

I actually can't see good cause on the part of the FCC to not allow ALE Link Protection levels 1 and 2 if the keys being used are provided to the FCC and or ARRL OO program and rules are implemented as to when its appropriate to make use of Link Protection. But that's another subject for debate.

/s/ Steve, N2CKH


At 03:02 PM 4/3/2019, you wrote:
But they have not precluded proprietary (eg. patented) methods to be used, even if it required obtaining a technology license to decode.  Remember, SSB and FM were patented "waveforms" at one time.  There is a difference between encoding and encryption.

On Wed, Apr 3, 2019 at 11:45 AM ALE <n2ckh@...> wrote:

Well it has been a long standing requirement on the FCC side that waveforms used on the Amateur Radio Service be sufficiently detailed in public that one could implement a decoder. For example when WINMOR came along the following was published:

http://www.arrl.org/files/file/WINMOR.pdf

The FCC does not and in my opinion should not, require that decoding software be provided.

However, it is my opinion if a waveform is not detailed sufficiently, as illustrated above, it has no place in being used on the ARS bands and the FCC agrees with that.

The MIL-STD and STANAG serial tone waveforms that I am focused on are so documented. However they are shut out from use do to their symbol rate on all but 60 meters below 6 meters when implemented without modification.

/s/ Steve

At 11:38 AM 4/3/2019, you wrote:
Steve,

Point taken,

The test  shows  transfer   P4  at  19,600  2 min 46 sec   VARA  at  24,700 2 min flat in 2.2 kHz b/w
30% speed increase, with a lower power budget , 

This meet the  only real test ,  data transferred / power expended

The main issue  is the  impending  petition , that seeks to  degrade accesses ,
my observation, is it it appears to be  narrow in its thrust

73-Graham 



--


John D. Hays
Edmonds, WA
K7VE

[]Â [] Â []Â []

Bonnie KQ6XA
 

That is *yet another* awful petition to FCC.

The petitioner, Ron Kolarik K0IDT, wants a pony. 

He wants a free station that is capable of decoding any mode. 

There are just too many awful digital modes that he just can't copy. 

People talking in a way that he can't understand! :)

He thinks FCC should put them all in a cramped cell (tiny sub-band) in a technology jail. 

-KQ6XA

 

Read the petition:

https://ecfsapi.fcc.gov/file/100918881206/PETITION%20FOR%20RULEMAKING.pdf

 

Read Comments:

https://www.fcc.gov/ecfs/search/filings?limit=100&proceedings_name=RM-11831&submissiontype_description=COMMENT&sort=date_received,DESC

 

Make a comment: Proceeding: RM-11831

https://www.fcc.gov/ecfs/filings/express

 

Bonnie KQ6XA
 

There is so little activity on the HF bands these days, that we should encourage all the "congestion" that we can.

The only "interference" we see on the HF bands these days are primarily due to contesting, and the activity is often welcomed by some operators. 

Contesting and pile-ups are literally the definition of "intentional harmful interference", since the objective is to shout over everyone else so that they don't win :) 

That activity is sponsored by and encouraged by ARRL and other IARU organizations.

-Bonnie KQ6XA


On Wed, Apr 3, 2019 at 07:38 AM, Graham wrote:
For  a  'technical person'  its difficult to  assimilate  the  position's taken in the petition , appears to be based on
obsolete concepts ?.

Take the  300  baud max rate ,  technology  has advanced to the  point , this this is no longer relevant,  OFDM has now  rendered  high speed  serial carrier systems to be  obsolete ,  In a series of tests ,  carried  out , comparing the  VARA modem against other systems ,  VARA  HF  provided  higher  data  transfer , at lower power  levels than  Pactor 4 , in either direct or nivs path.. 

The on-air  carrier rate  for  vara  is round  37 Baud , maintaining compatibility , with  'all' propagation  modes

: link to  the  published  article :VARA review in HBradio

Channel  congestion / interference 

dualraoul
 

On Wed, Apr 3, 2019 at 12:07 PM, Graham wrote:
one and the  same ?
NO

Ron K0IDT

dualraoul
 

On Wed, Apr 3, 2019 at 09:13 PM, Bonnie KQ6XA wrote:
The petitioner, Ron Kolarik K0IDT, wants a pony. 
Nice. There's no pony in the petition.

Ron K0IDT

dualraoul
 

On Wed, Apr 3, 2019 at 09:22 PM, Bonnie KQ6XA wrote:
That activity is sponsored by and encouraged by ARRL and other IARU organizations.
What, yet another anti-contest rant? File a complaint or something.

Ron K0IDT

Bonnie KQ6XA
 

On Wed, Apr 3, 2019 at 11:15 PM, dualraoul wrote:
What, yet another anti-contest rant? File a complaint or something.

Ron K0IDT
Ron, anyone can file a petition... and probably get a bunch of curmudgeons to support it under an "anti" banner... as demonstrated. 

50 years ago, as a ham radio novice, I learned about the true spirit of amateur radio.  
Advancement of the radio art is the real "traditional values" of amateur radio. 
It needs no petition.

Bonnie KQ6XA
 

On Wed, Apr 3, 2019 at 11:12 PM, dualraoul wrote:
Nice. There's no pony in the petition.

Ron K0IDT
I count several unicorns in the petition :)