Subj : Other Ham Radio News
To : All
From : Daryl Stout
Date : Tue Apr 02 2019 10:44 am
Petition for Rule Making Calls for "Amateur Digital Mode Transparency"
04/02/2019
The FCC is accepting comments on a Petition for Rule Making (RM-11831)
seeking to amend FCC Part 97 rules that require all ham radio digital
transmissions to use techniques "whose technical characteristics have
been documented publicly."
The Petition, filed by Ron Kolarik, K0IDT, of Lincoln, Nebraska, 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).
Kolarik said his petition also aims to reduce levels of amateur-to-amateur
interference from Automated Controlled Digital Stations (ACDS) on HF
operating under �97.221(d)(2). Kolarik wants the FCC to delete �97.221(c),
which permits automatic control of digital emissions provided the station
"is responding to interrogation by a station under local or remote control,
and [n]o transmission from the automatically controlled station occupies
a bandwidth of more than 500 Hz."
In his Petition, Kolarik maintains that interference from ACDS continues
to be "a major problem on the amateur bands." He suggested that an absence
of formal complaints may be due to the fact that such stations are
"difficult to identify."
The Petition also proposes to amend �97.309(a)(4) to ease monitoring of
certain digital transmissions. "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" Kolarik's Petition
asserts. He said problems arise when "protocols and devices used in
commercial, government, and marine services, are used in the Amateur
Service with no adequate means to fully decode transmissions," thwarting
any efforts at self-policing of such transmissions. He said simplifying
the language "would remove ambiguity about what constitutes ''publicly
documented technical characteristics'' by requiring any protocol to be
freely decodable," and lead to "amateur digital mode transparency, present
and future."
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 emissions, consistent with ARRL's Petition, but
declined to propose a bandwidth limitation for MF and HF digital to
replace current baud rate limitations. ARRL had asked the FCC to delete
the symbol rate limits in �97.307(f) and replace them with a maximum
bandwidth for data emissions of 2.8 kHz on amateur frequencies below
29.7 MHz.
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