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.pl 99 .po 0 .op ARRL votes to squelch automatic HF Digital Operations Tom Clark, W3IWI W3IWI@W3IWI.MD (packet) w3iwi@amsat.org (Internet) The month of July saw an incredible amount of activity pertaining to the continuation of the ARRL-sponsored STA (Special Temporary Authorization) which permitted automatic, unattended digital operation on HF bands. By way of review, when the FCC adopted NPRM 85-105 it permitted unattended digital operation, which gave us the opportunity to build VHF/UHF packet networks. However this permission was not extended below 30 MHz. To extend the line-of-sight links to provide trans- and inter-continental extensions of the packet networks, in 1987 the ARRL requested an STA from the FCC to allow a selected list of amateurs the same priviledges on HF. Thus was born SKIPNET. The initial STA was for for a period of 180 days, and in 1988 the ARRL was granted an extension based on this letter: January 5, 1988 Mr. Ralph A. Haller, Chief Private Radio Bureau Federal Communications Commission Washington, DC 20554 Drar Mr. Haller: In re: STA for HF Automatic Packet Operation The American Radio Relay League respectfully requests a one- year extension of special temporary authority granted in your letter 7230-J (Attachment A), dated July 7, 1987. The STA expired 180 days after the grant, or January 3, 1988. The purpose of the extension is to allow the HF packet-radio automatic message-forwarding net to continue for the balance of 1988 while revised packet rules are under consideration. The technical parameters of the STA remain as outlined in my letter of June 2, 1987 Attachment B). Stations presently covered under the STA are listed Attachment C. During the 180-day STA period, we were successful in col- lecting enough data and operating experience to show persuasively that, with suitable safeguards, automatic operation of packet- radio stations below 30 MHz is feasible and in the public inter- est. Answers to specific questions are now being received from individual stations, and the League will prepare a report docu- menting the experiment. The conclusions are that the operation has gone almost without incident and that those few instances of introduction of improper traffic were dealt with effectively. Several senior PRB personnel have, on several occasions, stressed the need for changes to Part 97 of the Commission's rules to cover packet-radio operation. The League's Executive Committee on December 4 requested the ARRL Ad Hoc Committee on Amateur Radio Digital Communication to draft new proposed lan- guage to correct problems in the current rules. Also, the Digi- tal Committee will consider wording appropriate to permit auto- matic operation of packet-radio stations below 30 MHz. It is our intent to petition for such rule changes during 1988 and as soon as coordination is completed and approvals are obtained. It is requested that the above-mentioned STA be extended until the end of 1988 under the same conditions. Sincerely, David Sumner, K1ZZ Executive Vice President In the early years of the STA, the ARRL took heat from established users of the HF spectrum because the packet operations had usurped portions of the already crowded HF bands. This criticism came from domestic sources (particularly the RTTY community) and from IARU member societies. Well, the situation continued in limbo, with the STA being renewed annual ly. To gather facts to assist the ARRL in proposing rules changes, the STA community conducted an in-depth survey of activity and forwarded it on to the ARRL. In advance of the 1990 STA renewal, the ARRL sent this letter to the STA participants: December 22, 1989 SKIPNET STATIONS Gentlemen: By now, you have heard that the League has filed a petition for rule making with the FCC seeking permanent provisions for automatic RTTY and packet operation within certain HF segments. Meanwhile, ARRL Counsel Imlay, N3AKD, will request the FCC to extend the SKIPNET special temporary authority for a year or until permanent rules are adopted. Perhaps it would facilitate understanding and discussion of the issues if you have some of the background leading up to the decisions represented by this petition. I know I'm preaching to the faithful by saying that we need automatic packet operation in the HF bands. Nevertheless, the two and a half years that the SKIPNET STA has been in effect has shown that (a) such operation is technically feasible, (b) the network operations can be orderly without commercial encroachment, (c) the spectrum can accommodate it without undue displacement of other operations, and (d) HF automatic packet operation performs a vital public service that has proven itself in day-to-day and disaster communications. It's clear that virtually all amateurs have come to the same general conclusions, albiet reluctantly in a few cases, and have enjoyed the message- handling service provided by the packet network. It is evident that the FCC thinks amateur packet radio is a good thing, including automatic operation on HF, by virtue of their granting the STAs. Also, the FCC has made repeated requests for the amateur community to propose some permanent packet rules with adequate safeguards against prohibited transmissions. For nearly two years, the ARRL committee on Amateur Radio Digital Communication has been considering proposals for permanent RTTY and data communications rules. These deliberations were not done in a vacuum but in close coordination with two other committees of the Board of Directors. While they did not work on the RTTY and data sections specifically, the Board's Ad Hoc Part 97 Rewrite committee handled everything else in a way that would permit the RTTY and data sections to drop right in. The Board's membership Services Committee (MSC) played a pivotal role in the Rtty and data peitiion consideration,. One of MSC's missions is band planning. While the Board has other committees advocating certain types of operation (i.e., DX, contests, repeaters, VHF-microwaves and digital), it is the job of the MSC to try to strike a reasonable balance in their spectrum needs. Having weighed the competing bandwidth demands of the different users, the recommendations of the MSC still need either full Board or Executive Committee approval prior to filing a petition with the FCC. This petition was presented at the Executive Committee's October 21 meeting (but not voted on at that meeting in orfer to give the members more time to give it careful consideration) and subsequently approved by correspondence. Now that we've reviewed the process, let's talk about the merits. o We started with a yes/no decision: Is automatic operation on HF packet a good thing? Yes--you demonstrated that. o Having decided that, should automatic operation be permitted within the entire parts of the HF bands where RTTY and data are allowed or just in certain segments? Certain segments-- to calm fears of other CW and RTTY operators both here and abroad of unwarranted and uncontrolled proliferation of automatic operation. o Should the petition for automatic operation include RTTY (Baudot and AMTOR)? Yes--we struggled with this but were persuaded that there have been successful RTTY mailboxes longer than packet, and there was an STA that demonstrated automatic AMTOR operation. Also, as you know, AMTOR has some special robust qualities and serves as links in some parts of the worldwide (mostly) packet network. o Now for the tough part: What specific frequency segments? The ranges chosen in most bands are probably self- evident. Let's just talk about the difficult ones--20 and 40 meters. Occasionally, it helps to state the obvious to update any Van Winkles who have been asleep for 20 years... There is no virgin spectrum in these two bands. Every kilohertz is used by someone, sometime. In many respects, specific frequencies are more emotionally held than ancestral hunting grounds. (Remember: It's only a hobby?) It's hard enough to find some frequencies that won't conflict with other users within the United States. The specific frequencies used by SKIPNET stations have shown that it's possible to shoehorn in with other U.S. users. But, we live in a larger world, and we've received complaints from societies in other countries about HF packet frequencies, particularly in the 20- and 40-meter bands. - On 20 meters, nearly every other country operates phone in the 14.100-14.150 MHz range, and packet operations in the lower part of that range have been a continual cause of concern to them. This has been the case in all ITU/IARU Regions including Region II-the Americas. The fact that some of their own packet operators use frequencies above 14.100 has not convinced the societies in other countries that this is a good place for packet. The worldwide consensus (with some reluctance on our part) is that packet should operate below 14.100. Of course, that puts pressure on the Baudot RTTYers and AMTOR RTTYers just below them in frequency andultimately on the CW operations. If this can be done, however, maybe we can put one problem behind us. - On 40 meters, most countries have a narrower band--only 7.0 to 7.1 MHz--into which they must squeeze CW, RTTY, packet, phone and image communications. Around 7.040, or even as low as 7.030, is where their phone band starts. So, you can understand why there might be contention over packet and RTTY around 7.090. The frequency segments for each band were chosen after careful review of domestic and international implications. While we knew to begin with that there was no such thing as a "perfect fit", we nevertheless had to try for a "best fit" solution. I believe that others will come to the same conclusion after deliberate, unemotional stufy of domestic and international needs. Pleease bear in mind that we now have a viable packet network that is worldwide in scope. As such, we need to use frequencies that are compatible with the rest of the world. Even with the frequency segments chosen, there may still be the need for future adjustments, both by us and in other countries to finally arrive at common segments for automatic operation. The League's petition is not a fait accompli. There are three points in the FCC's proceedings where individual inputs are possible. We anticipate that individuals may wish to suggest some changes in the frequency segments proposed by the League. We believe such inputs to be helpful in cases where commenters take the time to consider the domestic and international implications of their proposals. I thought you would like to have the above background. We'll let you know as soon as possible about renewal of the STA. Meanwhile, we wish you happy holidays and best wishes for the new year. Sincerely, David Sumner, K1ZZ Executive Vice Presicent Well, the proposed rules changes were unacceptable to the RTTY/AMTOR community who saw the STA as a sham. The ARRL continued to take heat from the other IARU member societies. Unable to form a consensus, the situa tion has been in limbo ever since. As a result, the STA continued with annual renewals; the current STA extension expires the end 1992. Also in early 1991, the FCC caused additional heartburn for the packet radio network by citing a dozen east-coast stations (including W3IWI) for automatically forwarding an Anti-war bulletin (I still call this the 900- GATE affair). In that action, the community was informed that EACH packet network station was responsible for the content of EACH message that automatically passed thru his station. Clearly the FCC has a problem understanding automatic operation within a network! At the summer, 1991 ARRL Board meeting, the Directors made a decision to split the functions of the old Digital Committee into two -- a Digital Committee to look after the operational needs of the entire digital commu nity, and an Advanced Techniques Committee to help design future systems. To my knowledge, the ARRL never publicized the membership of either of the new committees. Early in 1992, the ARRL announced a survey of the needs of the entire digital HF world. The STA group was told that they would be surveyed separately for detailed comments on STA operations. Dale Sinner, W6IWO through his publication RTTY Journal called on all the RTTY and AMTOR users to respond en masse. Imagine our surprise when, in early July the following ARRL Bulletin appeared: SB QST @ ARRL $ARLB058 ARLB058 Digital news ZCZC AG80 QST de W1AW ARRL Bulletin 58 ARLB058 >From ARRL Headquarters Newington CT June 25, 1992 To all radio amateurs SB QST ARL ARLB058 ARLB058 Digital news The ARRL Committee on Amateur Radio Digital Communication has reviewed the results of the January 1992 QST survey on automatic unattended HF operation of digital stations, and has submitted recommendations for ARRL Board consideration at its July 17 meeting. A clear majority of survey respondents opposed fully automatic, unattended operation on HF. However, by a ratio of two to one, respondents endorsed semi-automatic operation, where there is a control operator present at one end of the circuit. The Digital Committee recommendations are consistent with the survey results. The Committee is recommending that FCC rules be proposed to permit semi-automatic digital operation below 30 MHz, but not to permit fully-automatic operation. Neither type of operation is presently permitted, except under a special temporary authorization granted to ARRL that will expire next January. The recommendation includes language to protect other amateur operations from interference in the event of a malfunction of the unattended station. The Committee also recommends that the use of unspecified digital codes on HF be allowed, with bandwidth limited to 500 Hz below 28 MHz and to 2 kHz between 28.0 and 28.3 MHz, to encourage experimentation with more spectrum efficient systems. Finally, the Committee recommends greater efforts by the League to educate amateurs interested in HF digital operations, and to develop technical standards or guidelines for spectrum- efficient digital communications equipment. ARRL Directors are now studying the recommendations of the Digital Committee, in preparation for their formal consideration July 17. At that time, the Board will have the opportunity either to adopt the recommendations, decline to adopt them, adopt them in modified form, or postpone consideration. NNNN A number of SKIPNET members said "Huh??? What the **** is happening here?". Calls to our local directors indicated that none of them had seen the committee report. Most directors did not know who was on the Digital Committee, or who had appointed the Committee members. One Director thought that I was on the Committee and called me for information. Well, we finally got a copy of the full report -- here is what it says, verbatum: --------------------- Minutes of the ARRL Committee on Amateur Radio Digital Communications June 13, 1992 The ARRL Committee on Amateur Radio Digital Communications met at 8:30 CDT on June 13, 1992 at the DFW Marriott Hotel, Dallas, TX. Ed Juge, W5TOO, Chairman presided and Vic Poor, W5SMM acted as recording secretary. In addition the following members were present: Tom Comstock, N5TC, Craig McCartney, WA8DRZ, Paul Newland, AD7I, and Dale Sinner, W6IWO. Bob Poirier, KODJ, was unable to attend. Comstock reviewed the role of digital communications in past emergencies including the Mexico City earthquake and hurricane Hugo. Poor reviewed the current state of the art of current and soon to be introduced digital modes and their impact on h.f. spectrum utilization. The Committee as a whole reviewed the responses from the Digital Survey conducted by QST and RTTY Journal. A lengthy discussion followed on all the issues raised in connection with the operation of unattended amateur h.f. digital stations. The recording secretary was directed to summarize these discussions and the unanimously approved recommendations to the ARRL Board in a separate report which is attached as a part of these minutes. Ed Juge, Chairman Vic Poor, Recording Secretary Report and Recommendation to the ARRL Board of Directors by the ARRL Committee on Amateur Radio Digital Communications June 13, 1992 The ARRL Digital Committee has been asked by the ARRL Board of study the issues related to use of automatic unattended control of amateur stations operating digital modes in the h.f. spectrum and to recommend what action the Board should take toward establishing permanent rules for such operation, if any. The Committee has carefully studied as many of the facts and opinions as were available within the Committee's resources. Data bearing on the question included: The results of the ARRL Digit Survey; Frequency usage and allocations in the U.S. and in other countries; The current state of the art for amateur h.f. digital modes; Potential abuse of unattended operation such as illegal third party traffic; The various competing interests for h.f. spectrum, particularly between existing digital modes; and Amateur operating practices and traditions. The ARRL Digital Survey The members of the Committee carefully studied the tallies of answers to the questions in the survey and read every written comment submitted by the respondents. The survey data showed that majority of respondents favored permanent authorization of unattended semi-automatic operation but limiting semi-automatic operation to sub-bands, and a substantial majority did not approve of unattended fully-automatic operation. A wide range of opinions and proposals were made in the comments attached to the survey, all of which were discussed and weighed by the Committee. The important issues raised are discussed below. Frequency Usage and Allocations in the U.S. and other Countries It is no secret that available space is very limited in the h.f. spectrum. Nowhere is that more evident than in the very popular 20 and 40 meter bands. The two oldest modes of operation, voice and c.w., have the lion's share of the spectrum in those bands since they were in heavy use before there were any digital modes. The digital modes have simply "squeezed in the crocks" between already established modes of operation. Since the digital modes have become established they have expanded gradually, a little at a time, primarily into space occupied by c.w. operation. Frequencies near the edges of digital mode operation continue to be shared by both digital and non-digital modes. Outside of the U.S., depending on the ITU region and the rules adopted by various administrations, digital operation for any given mode may not align with practice in this country and it does not seem possible to establish a sub-band plan that could be universally acceptable. It is simply inevitable that any band segment in the h.f. spectrum is going to be shared among differing modes of operation. This is not a new condition on the h.f. bands and has been accommodated for decades. Available Spectrum Space in the H. F. Bands Since all current h.f. band space is actively occupied by one or another mode of operation and since no current class of user is willing to give up space for another, the Committee is operating under the assumption that whatever rules are proposed there will not be a sudden significant change in the way the bands are currently used (at least this Committee is not prepared to make any such recommendation!). The Committee believes that gradual changes will continue to occur but that these changes will be due to natural migration as a larger percentage of amateurs shift to digital from other modes of operation and from one digital mode to another. The respondents to the survey strongly opposed the allocation of sub-bands by rule. The Committee also believes that any attempt to specify by rule sub-bands for a class of digital operation would soon grow obsolete as patterns of operation change, more digital modes are introduced, and more users shift to digital modes. Instead, the Committee believes that the amateur community will need to adjust itself to continued sharing of the spectrum by various modes and that such sharing should be facilitated through the publication by the ARRL of recommended sub-bands for the various modes and that such recommendations should be revised from time to time as operating patterns change. The Committee, as a subsequent action, will propose a revised band plan for consideration by the ARRL. In any case, the h.f. spectrum is severely limited, especially for digital mode operation, and modes of operation that improve spectral efficiency must be strongly encouraged. The Committee will undertake a study proposing, in a subsequent action, voluntary technical standards which can be promoted among amateurs and vendors to significantly improve our current frequency usage. The State of the Art for Amateur HF Digital Operation While the current rules allow considerable latitude in what digital modes the amateur community uses, the actual practice is somewhat limited. Current practice includes "RTTY", a non-error-protected simplex mode, usually using the baudot code; "AMTOR", a partially error-protected half-duplex mode using the baudot code; "packet", an error-protected half-duplex mode using ascii code; and "PACTOR", an error-protected half-duplex mode using ascii code. In addition, a new DSP-based system has been demonstrated but is not yet generally available called "Clover" that is an error-protected full -duplex highly spectrum efficient mode. As currently used all of the above modes require approximately 500 to 1000 Hz. of bandwidth per channel except packet which requires 2000 Hz. per channel. Effective use of that bandwidth is terms of character throughput varies considerably as a function of the protocol used and the channel conditions. Partly because of the requirement for 2000 Hz. of space per channel and partly because of the nature of the AX.25 protocol, the performance figures for packet are the poorest per unit of bandwidth of any of the currently used modes. RTTY and AMTOR are better, and PACTOR is better still. Clover promises to exceed the throughput per unit of bandwidth of any of the above modes. Tolerance to poor channel conditions also varies among the modes with packet having the poorest performance, RTTY next, AMTOR and PACTOR being very much better. Digital techniques for h.f. operation are improving and newer technologies such as PACTOR and Clover promise significant near- term improvements in spectrum utilization, throughput, and performance under difficult h.f. radio conditions. The current rules do not appear to have contemplated these new modes in the h.f. portion of the spectrum and the Committee believes the rules require a modest change to encourage these and other new more effective digital modes and to promote operation in the narrowest possible bandwidth. Potential Abuse of Unattended Operation A few respondents to the Survey expressed opposition to any form of unattended operation because of possible illegal use of amateur bands for unauthorized third-party traffic, commercial purposes, or the support of illegal activities such as drug smuggling. The Committee is not aware of any pattern of such abuse nor does the Committee see any reason why illegal operation is not just as likely to occur directly between two attended stations as any other. The Committee did not consider this factor in making its recommendations. Competing Interests for HF Spectrum Space The most difficult issue the Committee has had to deal with is the demand for spectrum space from the many different classes of users. Many of these users are sharing (somewhat unwillingly) the same space and each would like the others to vacate to other locations. The most critical frequency bands (at the moment!) are 20 and 40 meters. On 20 meters the frequencies above 14,100 kHz. have been traditionally used for DX voice and below 14,100 KHz. for c.w. and data. With the advent of packet, and the STA authorizing unattended packet operation, packet operations began above 14,100 Hz. and has gradually occupied the region of 14,100 to 14,125 Hz. Due in large part to the fact that data is not allowed in this sub- band in some countries, packet operation has also extended downward into the band immediately below 14,100 attracting US operation in this sub-band as well. Non-US voice operators have taken exception to the use of the 14,100-14,125 space and RTTY operators have taken exception to the use of the space below 14,100. On the 40 meters packet operation began in the 7080-7100 Hz. region where traditionally RTTY and AMTOR operators had been active. This has forced the RTTY and AMTOR operations further down into the dismay of c.w. operators. This picture is further complicated by the fact that outside of region 2 data operation must be confined below 7050 kHz. The situation on other bands, especially below 21 mHz., though not as critical as on 20 and 40 meters, have similar conflicts. The informal 'sub-bands' used by the various modes are also somewhat fluid as propagation conditions change and usage shifts from one mode to another. The Committee does not believe that any subdivision of the bands by rule will best serve the amateur community in the long run. It also seems unlikely that any subdivision of the band by mode will work on a world wide basis because of the differences in the rules between regions and between individual administrations. Any subdivision of amateur bands by rule also imposes an unnecessary potential enforcement burden on the FCC. Amateur Operating Practices and Traditions Except in a very few special situations it has long been the tradition (and rule) that one amateur station must not willingly or knowingly interfere with a contract already in progress regardless of the mode of operation or the perceived importance of the communications in progress. It has also been a long standing tradition that no station or group of stations 'own' a frequency. (Frequency 'ownership' has admittedly become a practice on certain v.h.f. frequencies, but this practice has never been established on the h.f. bands and the Committee strongly rejects the concept of doing so now.) On h.f. the use of sub-bands with various classes of operation gravitating to specific locations is largely self regulating simply by virtue of the fact that a station occupying a frequency is not driven off the frequency by deliberate interference by a station operating another mode. (There are always isolated exceptions to this but it is not condoned in the rules or by the vast majority of amateur operators.) As greater numbers of amateurs use a particular mode that part of the band becomes recognized informally as a mode-specific sub-band. There is always a significant overlap in the sub-bands between modes - packet sharing with RTTY, RTTY sharing with AMTOR, AMTOR sharing with c.w., and so on. The greatest conflicts come where the overlapping modes have significantly different bandwidth, i.e., AM vrs. ssb, packet vrs. RTTY. Types of Automatic Operation Two types of automatic digital operation are under consideration for use on the amateur h.f. bands. One is fully-automatic operation where messages are passed between amateur stations without any operator intervention and no operator may need be present at either station. The other is semi-automatic operation where messages are passed between amateur stations with an operator initiating the contact from one of the two stations. Both fully- and semi-automatic operation is permissible today under the rules provided there is a control operator present at both stations. (Stations authorized under the STA may operate unattended.) Digital operation with one station functioning in a semi-automatic mode has long been a practice dating back to the '60s. Fully-Automatic Unattended Operation The proposal to authorize fully-automatic unattended operation represents distinct departure from past practices. A clear majority of the respondents to the survey opposed any fully- automatic operation on the amateur h.f. bands. To authorize fully-automatic operation without restriction, as some of the respondents to the survey advocate, would seriously undermine the fiber of mutual cooperation that h.f. operation requires. The Committee rejects such operation as undesirable on its face. It was also proposed to authorize fully-automatic operation with restrictions, either to the frequencies allowed, to a few privileged stations, or both. The committee saw no purpose in limiting the frequency bands alone since the number of stations that would attempt unattended operation would make the mode and allocated frequency useless to everyone. Limiting the number of participating stations was also rejected by the committee because there was no conceivable way to equitably allocate the privilege to specific stations nor was the committee willing to set aside any portion of the band to stations with special privileges. Fully-automatic operation, by it's very nature is mode-specific and must 'own' the frequency it operates on an cannot be effectively shared by other modes of operation. To authorize fully-automatic operation on the necessary mode- specific sub-bands raises serious problems. There are no likely sub-bands that can be used on a world-wide basis or that will not cause interference to other users under some circumstances. The only mode of operation that is currently a prospect for fully- automatic authorization is packet, based on the AX.25 protocol, using 2 kHz. channel spacing. This mode delivers the poorest performance with respect to spectrum utilization or survivability under adverse propagation conditions of any the digital modes currently in use. j The Committee does not believe that, if a protected mode-specific sub-band is to be authorized, that it should be a mode that is as inefficient in its resource utilization as current packet practice represents. Such an authorization will discourage the development and use of a more suitable mode. Further, the Committee does not believe that these is any service being provided by fully-automatic operation that is not also available by other means without the associated problems of fully- automatic operation. Nor does the Committee know of any reason why packet operation cannot also be operated in semi-automatic mode, thereby eliminating the need for a rule-mandated sub-band. Semi-Automatic Unattended Operation There are many reasons, however, why some form of automatic digital operation is desirable. It permits amateurs to exchange communications when there is a time difference between the operating times available to the two amateurs, and it permits the quick exchange of messages rather than taking air time with long calls and keyboard-to-keyboard operation. (This not a suggestion by the Committee that keyboard-to-keyboard is undesirable but simply that there are many cases where moving messages at machine speeds is more spectrum efficient and makes more frequency time available to direct keyboard operation.) It is very evident that some form of automatic operation is highly desirable when handling NTS and personal messages between amateurs through intermediate stations. This capability forms the very heart of the amateur community's preparedness for emergency service. Respondents to the survey favored semi-automatic unattended operation over those opposed by a two-to-one ratio. The Committee does recognize that there is some potential for interference using a semi-automatic unattended mode even as there is such potential in purely manual modes. However, so long as there is a control operator present at one end of the link, monitoring the progress of an exchange, such interference can be held to a minimum. The benefits of semi-automatic operation outweigh the risk of inadvertent interference. The Committee believes that in view of the long successful history of semi-automatic operation that authorizing unattended semi- automatic operation is in the best interests of the amateur community. RECOMMENDATIONS I. Unattended fully-automatic operation of amateur digital stations should not be authorized below 30 mHz. II. The FCC rules should be amended to allow unattended semi- automatic operation of digital stations on any frequency on which digital modes are authorized. Unattended semi-automatic stations may not initiate a contact, either with another station or via an undirected broadcast. An operator initiating a contact with an unattended station must first ascertain that no interference will be caused to existing communications, and must monitor the progress of communications. If it becomes evident that the communications with an unattended semi-automatic station is interfering with other amateur communications then the link with the semi- automatic station must be discontinued. An unattended semi- automatic station must be equipped with a time-out timer to insure that no signal is transmitted longer than five minutes in the event of the malfunction of control equipment or the loss of contact with the initiating station. Suggested wording for such an amendment is included in the appendix. III. The FCC rules should be amended to allow the use of modem- dependent codes for the purpose of efficient data compression and error control on h.f. radio channels. The bandwidth of such signals should be restricted to 500 Hz, below 28 mHz, and 2000 Hz. between 28.0 and 28.3 mHz The appendix to this report suggests specific wording for the recommended rule change. A station using a modem-dependent code must still comply with 96.119 Station Identification. IV. The League should publish a comprehensive tutorial-style operator's guide for h.f. digital operations clearly defining acceptable operating practices. Such a manual would delineate currently used informal sub-bands for the various modes and styles of operation, and the good operating practices that are required for effective mutual cooperation and coexistence. This Committee will make specific recommendations for the content of this guide. V. The League should publish technical standards or guidelines for the characteristics of signals generated by digital mode stations for the purpose of achieving the best possible use of the h.f. spectrum. QST should be used as a forum to educate that amateur community on the benefits and means of achieving acceptable signal quality and should review the technical characteristics of digital mode products with respect to published standards. This Committee will make specific recommendations for these technical standards. APPENDIX A The following is suggested wording for an addition to Part 97 authorizing unattended semi-automatic digital mode operation. 97.3 Definitions ( ) Unattended Digital Station - A station in the amateur service using an RTTY or data emission that is operated without a control operator present. 97.216 Unattended Digital Station (a) Any amateur station licensed to a holder of a General, Advanced or Amateur Extra Class operation license may be an unattended digital station. (b) An unattended digital station may operate on any frequency below 30 mHz. that is authorized for RTTY or data emission for the class of operator license held. (c) An unattended digital station may only use those RTTY or data emissions authorized by 97.305 and 97.307. (d) No unattended digital station may initiate a contact with another station or may broadcast any undirected signal. (e) The transmitter of an unattended digital station must be equipped with a time-out timer that will insure that no signal is transmitted for longer than five minutes in the event of the malfunction of control equipment or loss of contact with the initiating station. (f) Any amateur operator initiating contact with an unattended digital station must first ascertain that no interference will be caused to existing communications, must be present for the duration of the contact, and must discontinue the contact if it becomes evident that communications with the unattended digital station is interfering with other amateur communications. APPENDIX B To encourage improvements in digital mode communications and especially to improved spectrum utilization on amateur h.f. bands Part 97, 97.307 (f) (3) and 97.307 (f) (4), should read as follows: (3) A RTTY or data emission using a specified code listed in 97.309 (a) of this Part may be transmitted. The symbol rate must not exceed 300 baud, and for frequency-shift keying, the frequency shift between mark and space must not exceed 300 Hz. A RTTY or data emission using an unspecified digital code under the limitations listed in 97.309 (b) of the Part also may be transmitted. If an unspecified digital code is transmitted the authorized bandwidth is 500 Hz. (4) A RTTY or data emission using a specified code listed in 97.309 (a) of this Part may be transmitted. The symbol rate must not exceed 1200 baud, and for frequency-shift keying, the frequency shift between mark and space must not exceed 1 kHz. A RTTY or date emission using an unspecified digital code under the limitations listed in 97.309 (b) of the Part also may be transmitted. If an unspecified digital code is transmitted the authorized bandwidth is 2 kHz. --------------------- After this appeared, telephones started ringing and the packet and Usenet channels became very busy, trying to find out what was happening and trying to influence the ARRL Board in advance of their July 17th meeting. Here are some samples: Luck Hurder, KY1T at ARRL HQ said, in defense of questions about the Committee acting in secrecy: The truth is that the list of unattended digital STA folks has been available for the asking since day one. All a person need do was ask. And it's still available to the public on the ARRL BBS as a downloadable file. Also untrue is the notion that we've not spouted forth with regard to what we've learned from the STA. In fact we put out an ARRL/W1AW bulletin about it just this past week. We even went so far as to ask the STA participants (and all other interested amateurs) for their opinions on how we should proceed with our request to the FCC for rulemaking. Over 500 people responded. Not what you'd call a 'secret' guys! Here's the result of the digital committee's efforts on this matter: To which Hank, W0RLI responded: And we responded to the earlier poll ... the response from the STA participants was to allow fully automatic operation, since there had been near zero problems with it. Many of us have not YET responded to the recent "popularity contest" poll that appeared in a recent QST - in my case, since I've not yet had a chance to READ that QST. Hank then commented on the ARRL Bulletin #058 which said: "A clear majority of survey respondents opposed fully automatic, unattended operation on HF. However, by a ratio of two to one, respondents endorsed semi-automatic operation, where there is a control operator present at one end of the circuit." Who responded? What is the breakdown of people with actual serious HF packet operation? What did they cite as reasons for not allowing automatic unattended operation? Have the incidents cited (if any) been independently verified? Bulletin 58 continues by saying: "The Digital Committee recommendations are consistent with the survey results. The Committee is recommending that FCC rules be proposed to permit semi-automatic digital operation below 30 MHz, but not to permit fully-automatic operation. Neither type of operation is presently permitted, except under a special temporary authorization granted to ARRL that will expire next January. The recommendation includes language to protect other amateur operations from interference in the event of a malfunction of the unattended station." But what do the survey results mean? We have no information that indicates the survey did indeed sample the information it was expected to sample. The digital committee did not poll the STA holders. Since the STA holders are the only hams with experience in automatic unattended HF operation, this seems a VERY serious oversight. Note that this recommendation, if implemented, will shut down HF forwarding, and will shut down HF gateways. The original intent of the STA was to discover if it was feasible to have automatic unattended HF operation. The results of the operations under the STA have shown that it is feasible. The previous survey OF THE PARTICIPANTS OF THE STA showed that there were no problems. I strongly recommend that the digital committee do it's homework. A survey in a single ham magazine is not likely to produce the information the committee needs to make a good decision. And let's publish some actual information: Who's part of the STA? Are they on air? Have they been on air for the duration of the STA? What have their experiences been while operatin under the STA? The "secrecy" that folks are concerned about revolves around the fact that the information on WHO is in the STA, and WHAT has happened with the STA has not yet been made widely available. For example, it might make sense to publish the list of stations involved in the STA in QST. There WAS one packet BBS bulletin listing the original stations (sent around by W2JUP). There has been NO information about the results of the operation of the HF STA stations. With respect to that operation: I know of only ONE incident that might have caused unexpected QRM, etc. Cannot remember exactly when it occured (perhaps 1985?). Hardware failure caused one of the STA stations to go key down. The operator was notified within one hour (at his place of work), and he corrected the problem. He lost his L4 linear though ... Is there other evidence that unattended automatic operation has caused problems? Don't bother to respond with "It *COULD* do ....". The STA has been in existance for a long time now, anything that "could" happen has had it's chance to happen, and didn't. 73, Hank W0RLI And Carl, WA0CQG said Jay, WS7I said, quote "The ARRL Digital Committee has done a great job and put forth a recommendation that deserves wide support. It has done the study that the STA never did and the conclusion that it reached should be supportable by the Amateur Community." Whether it deserves widespread support is dependent on what it says. We'll know that when we see it, won't we? Whereis it available? I haven't seen it on packet nor here. The only request that the STA participant have had to provide info to ARRL that I am aware of was in November 1987 when Paul Rinaldo, W4RI, sent a letter requesting specific details as to amounts, types of traf fic handled and general operational questions. Those details were in cluded in a letter on January 5, 1989 from Mr. Dave Sumner, K1ZZ, to Mr. Ralph Haller, Chief, Private Radio Bureau, FCC, requesting a further extension of the STA term. It stated that the lessons learned are: "a. The system works, moves traffic and, with careful frequency selection, can provide a public service without undue interference to other amateur activities. b. Network management and control are necessary. c. Accountability for traffic must be with the station introducing it into the network; accountability at relay points is not practical. d. Packet is not compatible with other modes and needs separate fre quencies; carrier sense is not adequate to protect against interfer ing with other modes on HF owing to transmission impairments, hidden station effects, etc. e. Frequency stability needs to be on the order of 10 Hz. f. Protocols need improvement, and new capabilities are needed. g. Modems need improvement. h. Watchdog timer (to disable the transmitter automatically in the event of a malfunction) are essential. i. Stations need to change frequenciesin accordance with propagation conditions to improve efficiency, reduce retries, and free up frequencies for other users. j. While a 200-watt power output has proven adequate for many domestic paths, there is no justification for a blanket 200-watt limitation." So, thats the kind of stuff learned during the STA, as reported to FCC by ARRL. Stuff learned from real life experiences. WA0CQG continues his response to WS7I who had said: "... The survey of the ARRL membership and the various input was a terrific idea. Many have already called their ARRL director and urged support. More should do so." A terrific idea if you want to form government regulatory policies from public opinion. I always understood that the League's role was to further technical excellence. Sometimes that is in contrary to the first blush of public opinion. What the FCC is asking for is, based on our actual STA experience can we operate the service without interfering with each other? They didn't ask our opinion! This assumes you have been fortunate enough to find a copy to read. I think time is too short before the BOD meeting to get wide-spread distribution of the document and understand it. Therefore, I have urged our local Director, Howard Mark (W0OZC) to either vote to table it or refer it back to the committee for inclusion of inputs from the STA participants. 73, Carl WA0CQG Quoting from comments by NO8M: The prohibition of automatic HF forwarding will result in a drastic and damaging affect on the amateur radio networks that now exist. This is exactly what the ARRL Digital Committee is proposing. The text of their recommendation is circulating on other networks and on many PBBSs as a separate message. It is also available on the Cleveland Hamnet BBS, 216-942-6382. There is little doubt that the HF network as we now know it will col lapse. Few, if any HF Sysops now operating will participate after the banning of automatic forwarding. (Ask one.) Hence, the same network that now relays the far majority of health and welfare, NTS and personal mail will close. At this same time, the possibility of future enhancements and experimen tation with a data network on all but the local scale will become so limited that the potential for advancement will be all but lost. Years of a highly successful STA operation are being ignored. Advancements that have come from this experimentation such as Clover and Pactor are being ignored. Massive amounts of traffic handled during emergencies is being ignored. Instead, we are treated to page after page of suggestions based not on these many successes but on speculation and suspicion of problems that do not exist. Situations that have not occurred. Pages after page of pretend that mocks the reality so easily shown by the networks that are real, that exist, that prove that it works. For years upon years, the staff of Newington has chosen to ignore and belittle the advances that have been made. Caught once in this activi ty, the prior Digital Committee was abandoned as an embarrassment. In its place were put tokens designed to meet a demand. The FCC, weary of waiting, publicly scorned the ARRL with the announcement that they best get off their derrieres and move to propose rules for the termination of the STA. To this end they begin their fight to build a case able to ignore the fantastic dedication and labor easily shown by today's net works. Should this event occur it will be years before the damage can be un done. This trend will only end and reverse if the Directors see the folly this Committee (and the staff at Newington who chose them) is perpetrating. Please, contact your Division Director and request that the recommenda tions of the Digital Committee be abandoned. In mid-July they will have a meeting in order to take action on this matter. Your Director's information is available inside the cover of QST. Also please contact your Section Manager. Your Section Manager has an ear to your area and a voice in Newington. 73, Steve, NO8M @ NO8M.#NEOH.OH.USA.NA And I circulated this long diatribe on July 11th: The ARRL Digital Committee has filed a report to be voted on by the ARRL Directors in their meeting 7/17 concerning the STA which permits automatic, unattended HF digital operations. This STA has been hanging around for a number of years as an un-reconciled thorn in everyone's side. This represents some of my personal comments on the proposal by the ARRL Committee on Amateur Radio Digital Communications date June 13th. I find the Committee's report to be interesting. I agree with part of it. I find parts of it suffering from technical errors. I find a number of places where assertive "god's truth" statements are made based on what I consider to be inadequate/incomplete/questionable evidence and/or circular logic. The report conveys an aura which is in essence "let's flog packet" which I think is unfortunate and tends to put some of the community immediately on the defensive. My personal belief is that the desirable systems for the future are different from any of the current techniques, and will draw on the good/bad experience of each. Regarding new techniques, I am pleased to see Clover and Pactor represented; too bad several of the other new/proposed techniques were ignored. I find each of the techniques to be discussed as a "black-box" based on perceived performance, with lots of apples vs. oranges comparisons. By way of example, the strengths/deficiencies of a particular class of modem technology are not separated from issues of error correction, link-level data protocols, high-level messaging/networking protocols or number of people sharing a given frequency. From the packet standpoint, it is unclear whether any distinction is made between "open" operation (BBSs open to all users) and "closed" (regulated, limited membership) dedicated networks. The survey "vote" seems to have been based on counts of individual responses. This may give an incomplete picture. By this scheme, the "closed" dedicated HF networks (both packet and amtor) get only one "vote" per station when in point of fact, they handle messages from many people. I also note that, because of the way in which the survey was announced and advertised (heavily promoted in the RTTY Journal, but with no specific requests to the HF Net Managers to submit statistics), many of the sysops of the "closed" network stations didn't respond with enough information. Let me note my personal credentials to comment on these various points. First, I have been an active member of the present STA since the begin ning. I operate two "dedicated" "closed" HF Packet ports (14109 and 21097). My HF + VHF/UHF system acts only as a network mail forwarding node and has no direct users. The W3IWI mail switch handles 8000-12000 messages per month. Although NTS activity has decreased recently, my system has "made BPL" more than 20 times. My two HF ports typically handle 25-100,000 bytes of user- generated packet mail each day. I have been active in designing and building the amateur digital satellites to provide additional channel capacity to the world-wide network. I have been involved in the development and design of several of the pieces of hardware in common usage including the TNC1, TNC2 and 1200 baud PSK modem. I have been involved in developing DSP-based techniques for improving link- level performance. I have done research in quantifying the effects of multi- path on HF digital links and in developing the digital protocols. Now to some specific points concerning the committee report: 1. The meeting was held June 13th. It was July 8th before I was able to get a copy for comment, and it is only a week to get comments to the ARRL BoD. I wonder why the document was kept "secret" until it is (almost) to late to lobby the Directors? My local Director (W3ABC) had also not seen a copy and phoned me today asking what I knew about it. Along similar lines, I wonder who in the community the committee discussed the issues with? Among the folks I know operating HF packet systems under the current STA, and among the folks who are currently writing code to make improvements to the present system, and among the folks who are trying to improve modem technology, no one was contacted. I think some grievous errors and misconceptions could have been corrected if only people had asked! 2. Spectrum usage: In the report the committee states > In any case, the h.f. spectrum is severely limited, especially for > digital mode operation, and modes of operation that improve > spectral efficiency must be strongly encouraged. The Committee > will undertake a study proposing, in a subsequent action, voluntary > technical standards which can be promoted among amateurs and > vendors to significantly improve our current frequency usage. Good, I'm glad to see that philosophical statement. Actually efficiency needs to also be measured in a second domain -- time. Any network needs to be judged on the basis of objective criteria like bits/day/kHz, not just occupied kHz. The committee then goes on to state: > The State of the Art for Amateur HF Digital Operation > > While the current rules allow considerable latitude in what digital > modes the amateur community uses, the actual practice is somewhat > limited. Current practice includes "RTTY", a non-error-protected > simplex mode, usually using the baudot code; "AMTOR", a partially > error-protected half-duplex mode using the baudot code; "packet", > an error-protected half-duplex mode using ascii code; and "PACTOR", > an error-protected half-duplex mode using ascii code. In addition, > a new DSP-based system has been demonstrated but is not yet > generally available called "Clover" that is an error-protected full > -duplex highly spectrum efficient mode. I wish to note that "CLOVER" is not the only "DSP-Based" technology currently being developed. I also note that Clover is the only "mode" listed (but not the only one under development) where new modem technology is being developed. The other techniques cited use nearly identical FSK implementations. > As currently used all of the above modes require approximately 500 > to 1000 Hz. of bandwidth per channel except packet which requires ^^^^^^^^ > 2000 Hz. per channel. Effective use of that bandwidth is terms of > character throughput varies considerably as a function of the > protocol used and the channel conditions. Partly because of the > requirement for 2000 Hz. of space per channel and partly because of ^^^^^^^^^^^ > the nature of the AX.25 protocol, the performance figures for > packet are the poorest per unit of bandwidth of any of the > currently used modes. I wonder what kind of strange weed the authors were smoking when they decided that packet REQUIRES 2000 Hz of bandwidth. The currently used channels on HF happen to be spaced 2000 Hz, but that was simply done for convenience. With 300 baud data superimposed on a 200 kHz shift, the REQUIRED bandwidth is about 500 Hz. Even given mortal receiver and modem filters, 1 kHz channel spacing would be adequate. With high performance receivers and a DSP modem (TS950, DSP2232) running the current BELL 103A standards, I have demonstrated that 750 Hz spacing is more than adequate. [In point of fact, the reason that packet uses 103A standards today is that back circa 1982 Bob Bruninga (WB4APR) picked up some surplus 103A modem boards at the Gaithersburg hamfest, and then N7CL+WA7GXD+W3IWI figured out how to tweak the XR2211 chip in the TNC1/2 to work compatibly.] 3. Channel Throughput. The Committee chose to use make this statement: > .... RTTY and AMTOR are better, and PACTOR is > better still. Clover promises to exceed the throughput per unit of > bandwidth of any of the above modes. I would like to see the factual justification for justifying the statement about packet. One major difference between the techniques that must be normalized to make such definitive claims is that the packet channels have several users on a frequency at a given time. Is the claim that ONE STATION's throughput is poorest, or is that the total channel throughput, considering frequency re-use is poorest? In the case of packet, are they referring to the "free-for-all" packet channels wherein the BBSs operate "open" or to the "closed" networks which limit membership in an attempt to minimize congestion, or to both? This set of sweeping statements, made to sound authoritative but lacking factual support are PRECISELY the type of apples vs. oranges rhetoric that some people have used to try to incite packet vs. rtty vs. amtor "wars". These rhetorical statements sweep under the rug that the performance differences arise because of several factors. The committee report then states: > Tolerance to poor channel conditions also varies among the modes > with packet having the poorest performance, RTTY next, AMTOR and > PACTOR being very much better. Again, the committee did not state the opinion on which these "facts" are based! 4. Logic Flaws! Why are these statements flawed? First, the radio side of the HF channels cannot be simply modeled. Gaussian noise is the least of the problems. QRM and QRN must be considered. Even more severe are effects of multipath. Papers at the ARRL Networking Conferences and in QEX by VE3JF, KB1JY and W3IWI as well as in the professional literature have demonstrated that on links well below the MUF, multipath causes significant intersymbol distor- tion at data rates about about 75 baud (symbol times shorter than about 15 msec). On "long-path" links near the MUF, rates well above 300 baud can be supported. The packet world has been tarred and feathered about performance when in fact the modem/data rate chosen for a the links were in error. I've had trouble copying 110 baud RTTY from W1AW on 80M. That is the fault of RTTY -- it's the attempt to use symbols that are too short to propagate thru the ionosphere. Proper application of improved adaptive modem technology (like Clover, like the idea I presented at the 7th Network- ing Conference, and like the ideas proposed by VE3JF and N4HY) will benefit all the techniques. Modems and the ionosphere are but one link-level issue. A second concerns the lowest level protocols. Clearly the error correction that AMTOR uses is a major key to its good demonstrated performance. In essence AMTOR is packet-like with a frame length < 20 bits. HF packet uses frames 500-1000 bits long with only error detection; it only works when bit error rates are below 1x10e-3 -- a rather stringent requirement for marginal HF paths. Pactor and Clover makes an effort to bridge this gap, as do other link-level protocols proposed and being developed by N4HY, VE3JF and W3IWI. At a higher level, another protocol issue which makes the "my technique is better than yours" arguments difficult is the time domain. RTTY and AMTOR tend to require that only one link (i.e. QSO) be in progress on a frequency at a given time. Packet (and Pactor) allow for time-domain channel sharing. This is an advantage when the different sessions occupying a given frequency can hear each other. When they can't, the "hidden terminal" problem occurs and everyone suffers when the different users step on each other. The regulated, established HF nets attempt to deal with this by limiting membership and enforcing time slotting. Protocol enhancements involving backoff timers, prioritized "acks", etc have been proposed and tested, but more development is still required. At still a higher protocol level, the present protocols all have weaknesses. The current use of connected-mode AX.25 is flawed. NK6K, K8KA, KA9Q and W3IWI have all proposed datagram-based "broadcast" protocols (much like those used in the NK6L/K8KA PACSAT protocols) on HF. I have stressed these future developments/augmentations to make a point. The committee proposal tries to cast the present system in concrete. It is flawed in its simplistic "automatic vs. semi-automatic" distinction. As a case in point -- I can envision adaptive protocols that (like current AMTOR) "probe" a number of frequencies trying to find a path. Once a path is found, some information is transmitted, but not all of it makes it thru. Several hours later, the "probe" finds a new path on a new band and some more data is transferred. Depending on the amount of information, this might take a whole day. The data (message) has been fragmented and can only be reassembled after it is received in its entirety. This seems, to me, to be an exciting technical development that only amateurs could do. But, unless the person at the manually-operated end of the semi- automated link is willing to sit at the rig for 24 hours, it REQUIRES automated stations. Why should we push the world (FCC, IARU, etc) to adopt "rules" which tie our hands? The committee report sort-of agrees with my statements about the future trends: > Digital techniques for h.f. operation are improving and newer > technologies such as PACTOR and Clover promise significant near- > term improvements in spectrum utilization, throughput, and > performance under difficult h.f. radio conditions. The current > rules do not appear to have contemplated these new modes in the > h.f. portion of the spectrum and the Committee believes the rules > require a modest change to encourage these and other new more > effective digital modes and to promote operation in the narrowest > possible bandwidth. In the last sentence, I would again stress that bandwidth per se is only part of the issue. The number of users sharing x kHz of spectrum and the number of bytes they can send per minute (or hour or day) also need to be part of the criteria. 5. Interference: Throughout the report (I won't quote the specific sections) there is a lot of discussion about interference. Let us consider for the moment that digital techniques are intrinsically channelized. Packet operation assumes that there will be interference from other users on the channel. The hardware and software detect the other signals, and when problems occur, the user automatically slows down to share the channel. AMTOR has developed frequency hopping as a way to automatically cope with channel congestion. While malicious interference is morally and socially unacceptable, channel sharing (in time and/or frequency) is a proven way to cope with the problem. Problems develop only when the modes are incompatible and channel "assignments" are violated. 6. What the committee proposes and its implications. Again I quote: > Fully-Automatic Unattended Operation > > The proposal to authorize fully-automatic unattended operation > represents distinct departure from past practices. A clear > majority of the respondents to the survey opposed any fully- > automatic operation on the amateur h.f. bands. How long is the integration time for the words "past practices"? Certainly fully automated unattended packet operations have been going on for at least 8 years! And I suspect that some of the automated AMTOR systems now on the air are also running the same way. The Committee's recommendations seem to be based on numerical replies. I doubt that the average packet user bothered to "vote" because the survey was not addressed to him/her. But the <<implications>> of this action will have a marked effect on them. In point of fact, a large fraction of the long-haul packet messaging outside a user's local area is carried on HF by automatic, unattended HF packet stations. Yes, some fraction is now being handled by the limited amateur satellite resources the community has built over the past few years; some fraction is handled by the (semi-)automatic AMTOR stations; and some fraction is handled on non-amateur (i.e. wire) links bypassing amateur radio completely. > To authorize fully-automatic operation without restriction, as some > of the respondents to the survey advocate, would seriously > undermine the fiber of mutual cooperation that h.f. operation > requires. The Committee rejects such operation as undesirable on > its face. > > It was also proposed to authorize fully-automatic operation with > restrictions, either to the frequencies allowed, to a few > privileged stations, or both. The committee saw no purpose in > limiting the frequency bands alone since the number of stations > that would attempt unattended operation would make the mode and > allocated frequency useless to everyone. Limiting the number of > participating stations was also rejected by the committee because > there was no conceivable way to equitably allocate the privilege to > specific stations nor was the committee willing to set aside any > portion of the band to stations with special privileges. The Implications: I'll speak for myself and ask the other operators on the HF networks to comment on their own views. W3IWI now handles thousands of user messages each month on HF under the aegis of the STA, operating automatically and unattended under the current STA. My professional commitments require me to be away from home quite a bit. When I am away I leave instructions on how to kill the radio if a <<technical>> malfunction occurs, but the messages keep being sent automatically. Recently I was in DL/UA/OH/LA/SM for 3 weeks. Several thousand messages passed thru the HF port here. I even sent mail from UA3/W3IWI back home thru the system. If the Committee's recommendations are adopted, or if some alternative to the present STA is not found, I will be forced to go QRT. I simply cannot operate in the ill-defined "semi-automatic" (which I liken to being half-pregnant or having half a pair of pliers!) mode legally. I hope that someone else will step up to the task of providing the service I have prided myself in for the past 6 years. In anticipation of comments like mine, the committee states: > Further, the Committee does not believe that these is any service > being provided by fully-automatic operation that is not also > available by other means without the associated problems of fully- > automatic operation. Nor does the Committee know of any reason why > packet operation cannot also be operated in semi-automatic mode, > thereby eliminating the need for a rule-mandated sub-band. I am unconvinced. Who is correct? If you have any comments on these ideas I urge you to contact your ARRL Director immediately so that he can cast an informed vote during the ARRL BOD meeting next week (7/17). 73 de Tom, W3IWI ----------------- Well, the ARRL Board met. Here are extracts of the relevant portions of their minutes: 32) Comstock, as Chairman, presented the report of the ARRL Committee on Amateur Radio Digital Communications. The committee reviewed the role of digital communications in emergencies, the "state of the art" for digital modes and their impact on HF spectrum use and the responses from the digital survey conducted by QST and the RTTY Journal. The committee then examined at length all of the issues raised in connection with the operation of unattended amateur HF digital stations. 33) It was moved by Comstock, seconded by Heyn, that the General Counsel, with the assistance of the Exec VP and the staff, is authorized to prepare a draft Petition for FCC Rulemaking to permit the operation of a new category of amateur station, "unattended digital station," on RTTY/data frequencies below 30 MHz. Only amateur stations under the active control of a control operator would be permitted to communicate with unattended digital stations; unattended digital stations would not be permitted to engage in one-way communications; and appropriate safeguards would be required to prevent unattended digital stations from causing harmful interference to other amateur stations. The draft is to be circulated to the Executive Committee for review and final approval before filing. Further, the Digital Committee is requested to continue its study of the issue of unattended digital operation, with the objective of developing future recommendations for increased flexibility of operation of this class of station. It was then moved by Quiat, seconded by Kanode, to strike the text and substitute the following: That the ARRL petition the FCC for a Notice of Proposed Rulemaking to provide for: (1) Fully unattended HF digital BBS operations under 47 CFR Part 97, subject to the following: (a) Data control--at the point of origination, all bulletins would be held for SysOps' review to screen out Part 97 violations, such as those having commercial or other inappropriate or unlawful textual content. (b) Equipment Control--all automatic HF BBS operators will include hardware, such as a telephone link or UHF/VHF link to shut down the HF port in case of awareness of, or reported, hardware malfunction. Additionally, locked-key sensors and over-temperature sensors shall be installed to shut down the HF port if the above or other prohibited conditions are detected. (2) Digital transmission rates up to 1200 bauds shall be allowed of HF amateur bands from 3-30 MHz. (3) Bandplanning within a maximum of 30 kHz of any amateur band to allow safe bandwidth margins for 1200-baud transmission will be implemented by agreement and understanding within the Amateur Radio community. After discussion, however, the motion to amend was LOST. Whereupon, the question being on Comstock's motion, the same was ADOPTED. Turnbull, Burden, McConnell and Grauer requested to be recorded as voting no. I talked with Director Turnbull (W3ABC) after the meeting. He told me that Quait's motion was very confused and was defeated by a vote of 14-1. I gather that many of the directors didn't understand the issues. He reported that no other director offered an alternative to Comstock's motion and that it was passed. Turnbull further stated: ... my position has been consistent for the past 4 years. There are two issues involved. FIRST - The need for a spectrum management policy (call it band planning, if you wish) that will be reviewed periodically and avoid some of the perceived chaos and/or incompatabilities. SECOND - The need for automatic efficient information handling systems where the content is the responsibility of the originator. Both items should be determined not only on the basis of current and future technnical requirements developed by those knowledgable, but also from the responsible inputs of both the user and provider communities. 73/Hugh W3ABC So, the SKIPNET community is left in limbo. As of December the present STA will expire. Who knows what the FCC will decide. Most of the present STA stations (both packet and AMTOR) expect to shut down because they are unable to operate in the "half-pregnant" semi-automatic mode. Unless the problem is solved, our only channel for trans- and inter-continental message handling will be via the satellites, or else by routing everything thru Canada. To show the users what they are in for, the Colorado SYSOPS are staging a two-day hiatus, as seen in these comments from W0LJF: The following is one of many bulletins sent to the BBS sysop's in Colorado defining our short-term plan to open the eyes of the local users to our plight. Next weekend [Aug 1/2], the BBS stations are going to shut down completely for 2 days. We are hoping that this will shock the users into appropriate action. In all actuality, we'll probably be called dirty names and accused of playing GOD; but we have to try SOMETHING drastic, as time is short. I am not trying to influence you to do the same in your states, but simply to let you know ONE of the things that CO is doing to further our cause. ..73..Ed W0LJF.. Bulletin to SYSOP @ COBBS follows: I just had a long talk with W0GVT on the tele. He suggests, and quite properly so, that AFTER the weekend blackout (I may go longer on the local blockout) that we send a bulletin to ALL users that this is what can be expected after December 31, 1992 UNLESS we get the ARRL Digital Committee, The ARRL proper and the FCC to change their course of action. He says to also provide names, addresses for comments to the proper parties. I concur....good idea. We need to get the addresses of these folks. Do any of you have this information? I would send a similiar bulletin to the the users right now, but they have no incentive at the present to petition these folks. Once they actually see that their hobby is in jeopardy, "they will see with open eyes", to loosely quote a verse from the Bible. One thing that everyone in the BBS biz should remember is that when the STA expires, that's it. There is NO unattended autoforwarding UNLESS the FCC modifies part 97. No matter what the ARRL recommends, we need to influence the FCC to see it our way. I have no idea how much the under- staffed FCC actually listens to the ARRL. Comments, please. Time to mow the lawn if it's dry enough. 73..Ed W0LJF@W0LJF.#NECO.CO.USA.NOAM.. Wynne, W0IUQ in Iowa sent me a note recommending: I do not think a slow-down or stoppage of service is a good idea, since it can easily backfire. In some areas, like Iowa, where the service is already pretty poor, it may go unnoticed and that could be used as evidence that the system isn't working and isn`t needed. Besides, it is negative and smacks of a lack of cooperation, like labor strikes aimed at the general public. Instead, I think we should take positive action, and some possibilities are the following: (1) The STA group could respond directly to the FCC and deliver the results of the study promised by the ARRL, proving that unattended operations are feasible and do not cause interference. (2) A group could separately petition the FCC for the unattended operations we want, and it would be best if that could be done before the ARRL gets theirs in. (3) Petitions could be circulated at hamfests and club meetings. (4) An article on this could be written for QST (which they may or may not publish). (5) Get lots of people talking about this on packet. (I have seen only a few, poorly-thought-out bulletins, and that surprises me.) (6) Encourage letters to the ARRL and/or the FCC. (7) Appeal at a personal level to the FCC. (Do you know anyone there?) (8) Apply pressure to the Board of Directors, as you suggested, citing their votes on this issue. It is also important to work together and coordinate our efforts. If I can do anything, please let me know. 73. Wynne. If and when the ARRL files with the FCC, then we will have the opportunity to comment. Here are some remaks from AD8I: After watching the disgraceful charade orchestrated by the ARRL power structure, the packed Digital Committee and the back room dealing by the Board of Directors, I have decided to let each of you know where I stand in the 'automatic operation' debate and let you know what I intend to do. I will terminate *ALL* packet operations at 23:59z 31 December 1992 unless the FCC has acted to allow full automatic operation for *ALL* classes of digital stations. I will resume VHF only operation of the GLOBAL WP SERVER after 30 days. If the ARRL presents a proposal to the FCC that discriminates against ANY class of automatic digital operations, I will file a very strongly worded set of comments in opposition. Those comments will be based on our collective experince under the STA. They will state that there is no technical justification to prohibit fully automatic operation of digital stations below 50 MHZ. They will state that there is no valid reason to permit only semi-automatic operation. Finally, they will recommend the COMPLETE PROHIBITION OF ANY AMATEUR OPERATION IN WHICH THERE IS NO CONTROL OPERATOR PHYSICALLY PRESENT AT THE LICENSED CONTROL POINT. As far as I am concerned, the ARRL elite can not have it both ways, either automatic operation is OK for everybody or it is not right for anybody. It is time to make a stand ... time to point expose the emperor's new clothes for what they really are! ... Joe Subich, AD8I The other approach is to make a preemptive strike and directly petition the FCC for a Notice of Proposed Rulemaking befroe the ARRL does. This could be done by concerned individuals, or it could be done by TAPR as the premier packet radio organization. If the TAPR membership feels strongly about this issue, let us know ASAP. Thanks to all who have made comments in the past month. Sorry I couldn't include them all. Much of the material included in this report was taken verbatum from the inputs, so don't blame me for any errors in the quotes! 73, Tom