Using ham bands for educational / research project

[Leo Szumel]

Hi,

What we'd like to do is use amateur radio for some university research
projects. Specifically, we would like to use AR equipment in sensor
network research. Sensor networks are basically like APRS without people
at the transmit nodes, and more than just position information is
reported (maybe temperature, etc). Also, multi-hop relay may be employed.

I've examined Part 97 rules and tried to read as many applicable threads
as possible. My interpretation is that:

(a) automated transmissions are OK (with caveats)
(b) AR can be used for educational (non-commercial) purposes
(c) AR can be used for data transmissions, using encrypted
authentication, provided the data payload is unencrypted

Part (b) is the most shaky becaues it seems to dependon "reasonable use"
and other gray terms. Certainly my proposed use is not "hobby" but it
seems to me to fall into the category of "experimentation" and
(hopefully) "advancing the field."

What do you think of using AR bands for relaying sensor information for
research purposes? Would an FCC Special Temporary Authority be
appropriate/required?

Sincerely,

--
Leo Szumel | ECE Graduate Student, UC Davis
Email:

[S. Sampson]

"Leo Szumel" > wrote
>
> What we'd like to do is use amateur radio for some university research
> projects.

I don't see a problem with that, as research is what interests Amateurs.

> Specifically, we would like to use AR equipment in sensor
> network research. Sensor networks are basically like APRS without people
> at the transmit nodes, and more than just position information is
> reported (maybe temperature, etc). Also, multi-hop relay may be employed.

Conducted every day.

> I've examined Part 97 rules and tried to read as many applicable threads
> as possible. My interpretation is that:
>
> (a) automated transmissions are OK (with caveats)

If you don't use a specified code, you must identify using a specified code.
For example, if you design your own protocol (unspecified code), then you
should design the system to ID every 10 minutes, or every transmission.

> (b) AR can be used for educational (non-commercial) purposes

See below

> (c) AR can be used for data transmissions, using encrypted
> authentication, provided the data payload is unencrypted

Yes. Phil Karn proposed a DES authentication many years ago, however, I
don't see why just a plain old MD5 checksum of the data and the time-stamp
wouldn't fit most requirements.

> Part (b) is the most shaky becaues it seems to dependon "reasonable use"
> and other gray terms. Certainly my proposed use is not "hobby" but it
> seems to me to fall into the category of "experimentation" and
> (hopefully) "advancing the field."

I don't see a problem in what you are proposing, and I think you could enlist
several amateurs who wanted to help. It goes without saying, that you would
need a ham license yourself, but that is pretty simple these days on a no-code
ticket.

Even if the money you use to buy the equipment, and power the equipment,
is grant money, it would be legal. Where you would begin to have problems,
is if you made the data proprietary, or sold subscriptions/membership/access
to say web sites where the data is stored. You could maintain a compilation
type copyright, and restrict access to the raw data and software, if you provided
say access to the processed data. I'm being vague, but the gist of it, is that you
can't make money, and I never heard of a research program that did.

73,

Steve

[Phil Kane]

(Message read and reply posted in rec.radio.amateur.policy)

On Wed, 2 Jul 2003 17:00:05 -0500, Dan/W4NTI wrote:

>You may want to try Mr. Hollingsworth at FCC and see what he says. He is
>chief of enforcement, FCC. Or maybe he can direct you to the proper desk.

Riley (who has plenty on his plate as it is) is in the Enforcement
Bureau, not the Wireless Telecomm Bureau that issues ham licenses
and interprets the rules thereof. He would not be involved in such
before-the-fact interpretations - it's the folks in Bill Cross' shop
at WTB who issue interpretations as to whether such operation is
permissible or not, and then Riley sees to the enforcement.

Off the top of my baldy bean, if there is any taint of remuneration
or pecuniary interest, I would advise a ham client that it would not
be permissable.

Then again, the wizards and wonders at the FCC's Office of
Engineering Technology have been known to issue Experimental
licenses for things which are the equivalent of attempts to mate a
zebra with a tiger.

Contact Carl Huie > who is a ham and the guy in OET who
handles such things.

--
73 de K2ASP - Phil Kane
ARRL Volunteer Counsel

[Phil Kane]

(Message read and reply posted in rec.radio.amateur.policy)

On Wed, 02 Jul 2003 21:46:45 GMT, S. Sampson wrote:

>I'm being vague, but the gist of it, is that you
>can't make money, and I never heard of a research program that did.

How do you think Tommy Lott developed ACSB when the land-mobile
big-three folks turned him down flat and he did the "research" for
the wannabee companies? Can you say 20 meters ?

Lots of us knew what he was doing but nobody wanted to blow the
whistle. Shame on me.

Then again, best to let that "creation" stay dead.....it's been about
25 years, and it never caught on, primarily because the manufacturers
who did fall for that scheme could never get the equipment to work
properly.

--
73 de K2ASP - Phil Kane

[Leo Szumel]

Dan, Steve,

S. Sampson wrote:
> If you don't use a specified code, you must identify using a specified code.
> For example, if you design your own protocol (unspecified code), then you
> should design the system to ID every 10 minutes, or every transmission.

That should not be a problem. I envisage we would use an unspecified
code for our data transmissions, but we could self-identify with an RTTY
broadcast every 10 min. This will all be computer-controlled so that
should be easy.

> Yes. Phil Karn proposed a DES authentication many years ago, however, I
> don't see why just a plain old MD5 checksum of the data and the time-stamp
> wouldn't fit most requirements.

Our motivation for authentication is that we are concerned with
controlling access to the sensor network; for instance, we want to be
the only ones who can give commands to the sensor nodes, like "turn off."

> I don't see a problem in what you are proposing, and I think you could enlist
> several amateurs who wanted to help. It goes without saying, that you would
> need a ham license yourself, but that is pretty simple these days on a no-code
> ticket.

I should have mentioned, I have a NCT license: KD5SZT. Issued last
summer. That's a great idea, getting hams involved. I think it would be
a fun project.

> Even if the money you use to buy the equipment, and power the equipment,
> is grant money, it would be legal. Where you would begin to have problems,
> is if you made the data proprietary, or sold subscriptions/membership/access
> to say web sites where the data is stored. You could maintain a compilation
> type copyright, and restrict access to the raw data and software, if you provided
> say access to the processed data. I'm being vague, but the gist of it, is that you
> can't make money, and I never heard of a research program that did.

Our goal is to provide a "service" to researchers; no compensation would
ever be accepted and the network is only for use in relaying sensor data
and sending commands to said sensors. Data produced would be freely
available. Sounds like our application is OK with the use policies.

Steve, thanks for your input!

Dan/W4NTI wrote:
> Do you have, or are you going to have, a ham license? Will all the
> stations involved have a ham licensee on hand? If not you will run >
into difficulties with the third party rules.

I do have a NCT license. I can imagine getting my advisor to get a
license, but I'm interesting in seeing if I can get around that. As I
see it, there would be several autonomous transmitters (relay devices)
and one control station, all of which would be under my control. As I do
sleep some of the time, is that a problem? :)

> What you describe may fall under 'experimental'. But I would check
with the
> FCC.

We want to design our system so that any manner of communication means
could be used to ferry the sensor data (internet, etc). But for our
initial experimentation, I think ham radio would be (a) very appropriate
and affordable and (b) fun. We will probably use ISM for short-range
communications and only rely on ham for longer range xmits.

> You may want to try Mr. Hollingsworth at FCC and see what he says. He is
> chief of enforcement, FCC. Or maybe he can direct you to the proper
desk.

Great, thanks for the reference. I will contact him.

Regards,

--
Leo Szumel | ECE Graduate Student, UC Davis | KD5SZT
Email:

[Dr. Anton Squeegee]

In article >,
says...

<snip>

> What do you think of using AR bands for relaying sensor information for
> research purposes? Would an FCC Special Temporary Authority be
> appropriate/required?

I think you need to get your Technician-class (or higher) ham
license. That, at least, would be a good start.


--
Dr. Anton Squeegee, Director, Dutch Surrealist Plumbing Institute.
(Known to some as Bruce Lane, KC7GR, Owner and Head Hardware Heavy,
Blue Feather Technologies -- http://www.bluefeathertech.com)
kyrrin a/t bluefeathertech dot c=o>m (Reassemble to use).
"Raf tras spintern. Raf tras spoit." (Keith Laumer, "The Galaxy
Builder")

[Ralph Mowery]

>
> What we'd like to do is use amateur radio for some university research
> projects. Specifically, we would like to use AR equipment in sensor
> network research. Sensor networks are basically like APRS without people
> at the transmit nodes, and more than just position information is
> reported (maybe temperature, etc). Also, multi-hop relay may be employed.

I would say find a comercial frequency and use it. YOu did not mention the
frequency that you would be using . If under 30 mhz it will be would wide.
If in the UHF and above you may go ok. Just remember you will be subject
to a shared frequency and others may use that frequency.

Sounds like one way or beacon modes to me.

[S. Sampson]

"Ralph Mowery" > wrote
>
> I would say find a comercial frequency and use it.

What does that mean? That his application is illegal, or you just don't
want him to experiment on the Ham bands?

> You did not mention the frequency that you would be using .

The only frequency he could use would be VHF and shorter wavelengths,
due to the automatic features he needs.

> If under 30 mhz it will be would wide.

World wide?? What does that have to do with anything?

> If in the UHF and above you may go ok. Just remember you will be subject
> to a shared frequency and others may use that frequency.

Duh... Although most VHF and UHF bands are about as empty as
the U.S. treasury, and two people using the same frequency would be as
likely as being hit with a metorite.

> Sounds like one way or beacon modes to me.

That's because you're very ignorant of the rules:

http://www.arrl.org/FandES/field/regulations/news/part97/

[Duane Allen]

Leo Szumel wrote:
> Hi,
>
> What we'd like to do is use amateur radio for some university research
> projects. ...
>
> I've examined Part 97 rules and tried to read as many applicable threads
> as possible. My interpretation is that:
>
> ...
> (b) AR can be used for educational (non-commercial) purposes
> ...
>
> Part (b) is the most shaky becaues it seems to dependon "reasonable use"
> and other gray terms. Certainly my proposed use is not "hobby" ...


Section 97.113(c) prohibits transmission of "Communications in which the
station licensee or control operator has a pecuniary interest, including
communications on behalf of an employer."

Are you being employeed by UC to conduct university research projects?

I would think that the University already has or can easily get
non-amateur resources (both hardware and spectrum allocation) that would
support your research projects. The challenging task is finding out who
may have such resources. In addition to checking with the project lead
faculty, you may need to check with the department head and the college
dean. An often overlooked channel for information is contacting the
purchasing persons at the department/college/campus levels. They know
who requisitioned what. From there you can go to the requisitioners and
find out what administrative activities they went through for licensing.

Good luck,

Duane Allen
N6JPO

[Duane Allen]

Leo Szumel wrote:
> Hi,
>
> What we'd like to do is use amateur radio for some university research
> projects. ...
>
> I've examined Part 97 rules and tried to read as many applicable threads
> as possible. My interpretation is that:
>
> ...
> (b) AR can be used for educational (non-commercial) purposes
> ...
>
> Part (b) is the most shaky becaues it seems to dependon "reasonable use"
> and other gray terms. Certainly my proposed use is not "hobby" ...


Section 97.113(a)(3) prohibits transmission of "Communications in which
the station licensee or control operator has a pecuniary interest,
including communications on behalf of an employer."

Are you being employeed by UC to conduct university research projects?

I would think that the University already has or can easily get
non-amateur resources (both hardware and spectrum allocation) that would
support your research projects. The challenging task is finding out who
may have such resources. In addition to checking with the project lead
faculty, you may need to check with the department head and the college
dean. An often overlooked channel for information is contacting the
purchasing persons at the department/college/campus levels. They know
who requisitioned what. From there you can go to the requisitioners and
find out what administrative activities they went through for licensing.

Good luck,

Duane Allen
N6JPO

[Phil Kane]

On Thu, 03 Jul 2003 13:54:46 GMT, Duane Allen wrote:

>I would think that the University already has or can easily get
>non-amateur resources (both hardware and spectrum allocation) that would
>support your research projects. The challenging task is finding out who
>may have such resources. In addition to checking with the project lead
>faculty, you may need to check with the department head and the college
>dean. An often overlooked channel for information is contacting the
>purchasing persons at the department/college/campus levels. They know
>who requisitioned what. From there you can go to the requisitioners and
>find out what administrative activities they went through for licensing.

Yes, UC does have such resources, and the source of who has what
where throughout the UC system is the Office of the Vice President
of Administration, located on the UC Berkeley campus.

At least that's who we used to deal with concerning radio spectrum
assignment and licensing matters for the UC system.

--
73 de K2ASP - Phil Kane

[Phil Kane]

On Thu, 03 Jul 2003 19:04:25 GMT, S. Sampson wrote:

>> Are you being employeed by UC to conduct university research projects?
>
>Graduate students aren't considered employee's of a University.

However, when I did my graduate research at UCLA 40+ years ago, the
result was considered "for" the University, not for me as a private
individual.

--
73 de K2ASP - Phil Kane

[S. Sampson]

"Phil Kane" > wrote
> > S. Sampson wrote:
> >
> >> Are you being employeed by UC to conduct university research projects?
> >
> >Graduate students aren't considered employee's of a University.
>
> However, when I did my graduate research at UCLA 40+ years ago, the
> result was considered "for" the University, not for me as a private
> individual.

I would put it this way: If the University intends to patent any part of the
research, then the ARS should not be used.

[N2EY]

Note: The following is just my interpretation of the rules.

In article >, Leo Szumel
> writes:

>> If you don't use a specified code, you must identify using a specified
>code.
>> For example, if you design your own protocol (unspecified code), then you
>> should design the system to ID every 10 minutes, or every transmission.
>
>That should not be a problem. I envisage we would use an unspecified
>code for our data transmissions, but we could self-identify with an RTTY
>broadcast every 10 min. This will all be computer-controlled so that
>should be easy.

I think there's a problem with using a code that is not publicly available. ID
is not enough; if the message cannot be read by a suitably-equipped monitoring
station (read: FCC) what you have is a form of encryption.

Amateurs are not allowed to intentionally encrypt or otherwise conceal
transmission meaning or content, with one exception: remote control commands.
So the "turn off" command would be OK to encrypt, but not the data coming from
the remote sensors.

73 es GL de Jim, N2EY

[Leo Szumel]

Hi Jim,

N2EY wrote:
> I think there's a problem with using a code that is not publicly available. ID
> is not enough; if the message cannot be read by a suitably-equipped monitoring
> station (read: FCC) what you have is a form of encryption.
>
> Amateurs are not allowed to intentionally encrypt or otherwise conceal
> transmission meaning or content, with one exception: remote control commands.
> So the "turn off" command would be OK to encrypt, but not the data coming from
> the remote sensors.

I see your point. How about this, though:

97.217:

"Telemetry transmitted by an amateur station on or within 50 km of the
Earth's surface is not considered to be codes or ciphers intended to
obscure the meaning of communications."

97.3(45):
"Telemetry. A one-way transmission of measurements at a distance from
the measuring instrument."

Also, 97.309(b) indicates that unspecified codes can be used so long as
the purpose is not to obscure the meaning of a communication.

Thanks for your input,

-Leo

--
Leo Szumel | ECE Graduate Student, UC Davis | KD5SZT
Email:

[N2EY]

In article >, Leo Szumel
> writes:

>Hi Jim,

Hello Leo
>
>N2EY wrote:
>> I think there's a problem with using a code that is not publicly available.
>> ID
>> is not enough; if the message cannot be read by a suitably-equipped
>> monitoring
>> station (read: FCC) what you have is a form of encryption.
>>
>> Amateurs are not allowed to intentionally encrypt or otherwise conceal
>> transmission meaning or content, with one exception: remote control
>> commands.
>> So the "turn off" command would be OK to encrypt, but not the data coming
>> from
>> the remote sensors.
>
>I see your point. How about this, though:
>
>97.217:
>
>"Telemetry transmitted by an amateur station on or within 50 km of the
>Earth's surface is not considered to be codes or ciphers intended to
>obscure the meaning of communications."
>
>97.3(45):
>"Telemetry. A one-way transmission of measurements at a distance from
>the measuring instrument."
>
>Also, 97.309(b) indicates that unspecified codes can be used so long as
>the purpose is not to obscure the meaning of a communication.
>
Good point!

As I interpret it, what this means is that the telemetry message doesn;t have
to be self-explanatory. For example, a remote sensor might report "534A0" as a
telemetry message in, say, ASCII, which is a "specified code", but there's no
need to have the remote sensor indicate what the symbols mean.

>Thanks for your input,

You're welcome!

73 de Jim, N2EY

[keep-it-clean]

Just go ahead and do it !!!

Don't worry about the "barracks lawyers". Hams are the biggest bunch of
wannabe cops that exist.

Your research will be a better use of the bandwidth than 99.999% of the
mindless jabber on the amateur bands today,

[charlesb]

Moron.

"keep-it-clean" > wrote in message
...
> Just go ahead and do it !!!
>
> Don't worry about the "barracks lawyers". Hams are the biggest bunch of
> wannabe cops that exist.
>
> Your research will be a better use of the bandwidth than 99.999% of the
> mindless jabber on the amateur bands today,
>
>
>
>

[S. Sampson]

"keep-it-clean" > wrote
>
> Now then, I take it you disagree with my advice to the original poster.

That really wasn't "advice," it was just noise.

[Phil Kane]

[K0HB]

Leo Szumel > wrote

> I am being paid by UC to do research in general.
> I would not receive compensation as a result of
> this specific research, so in my mind I have
> no pecuniary interest in the project.

If you are doing this research project within the scope of your paid
position, then you DO have a pecuniary interest, and Amateur Radio is
not an appropriate communications medium.

73, de Hans, K0HB

[Bill Frovik n0mnb]

go for it. as long as u share your info and results with the ham
community..and it wouldn't hurt to get ur ticket..
73's de n0mnb
"Leo Szumel" > wrote in message
...
> Hi,
>
> What we'd like to do is use amateur radio for some university research
> projects. Specifically, we would like to use AR equipment in sensor
> network research. Sensor networks are basically like APRS without people
> at the transmit nodes, and more than just position information is
> reported (maybe temperature, etc). Also, multi-hop relay may be employed.
>
> I've examined Part 97 rules and tried to read as many applicable threads
> as possible. My interpretation is that:
>
> (a) automated transmissions are OK (with caveats)
> (b) AR can be used for educational (non-commercial) purposes
> (c) AR can be used for data transmissions, using encrypted
> authentication, provided the data payload is unencrypted
>
> Part (b) is the most shaky becaues it seems to dependon "reasonable use"
> and other gray terms. Certainly my proposed use is not "hobby" but it
> seems to me to fall into the category of "experimentation" and
> (hopefully) "advancing the field."
>
> What do you think of using AR bands for relaying sensor information for
> research purposes? Would an FCC Special Temporary Authority be
> appropriate/required?
>
> Sincerely,
>
> --
> Leo Szumel | ECE Graduate Student, UC Davis
> Email:
>

[WB3FUP \(Mike Hall\)]

I believe that you have to have a properly
licensed control operator, at a control point, for
any transmission made on amateur radio except in
the case of emergency. Emergency is further
defined as threat to life and property.

I have, on various boy scout camporees, place a
two meter, rock controlled radio, set on 52, in
the disaster sight. The boys were on there own,
but there was always someone with a stronger
radio, close at hand, to monitor, w/o the boys
realizing it. Never had a problem, and did some
sole searching about definition of control point.
Decided that the stretch, if any was worth it, and
I was willing to defend my decision if necessary.

--
73 es cul

wb3fup
a Salty Bear

"Bill Frovik n0mnb" > wrote in
message ...
> go for it. as long as u share your info and
results with the ham
> community..and it wouldn't hurt to get ur
ticket..
> 73's de n0mnb
> "Leo Szumel" >
wrote in message
> ...
> > Hi,
> >
> > What we'd like to do is use amateur radio for
some university research
> > projects. Specifically, we would like to use
AR equipment in sensor
> > network research. Sensor networks are
basically like APRS without people
> > at the transmit nodes, and more than just
position information is
> > reported (maybe temperature, etc). Also,
multi-hop relay may be employed.
> >
> > I've examined Part 97 rules and tried to read
as many applicable threads
> > as possible. My interpretation is that:
> >
> > (a) automated transmissions are OK (with
caveats)
> > (b) AR can be used for educational
(non-commercial) purposes
> > (c) AR can be used for data transmissions,
using encrypted
> > authentication, provided the data payload is
unencrypted
> >
> > Part (b) is the most shaky becaues it seems to
dependon "reasonable use"
> > and other gray terms. Certainly my proposed
use is not "hobby" but it
> > seems to me to fall into the category of
"experimentation" and
> > (hopefully) "advancing the field."
> >
> > What do you think of using AR bands for
relaying sensor information for
> > research purposes? Would an FCC Special
Temporary Authority be
> > appropriate/required?
> >
> > Sincerely,
> >
> > --
> > Leo Szumel | ECE Graduate Student, UC Davis
> > Email:
> >
>
>

[Phil Kane]

On Sat, 2 Aug 2003 23:54:02 -0500, Bill Frovik n0mnb wrote:

> go for it. as long as u share your info and results with the ham
>community..and it wouldn't hurt to get ur ticket..
>73's de n0mnb

Leo and I kicked this around in private e-mail, and because of lots
of facts that you don't know, the use of amateur radio for this
project is NOT proper.

Gotta' know the whole story before you dispense quasi-legal
advice.....especially when said advice is incorrect.

--
73 de K2ASP - Phil Kane
Principal Attorney
Communications Law Center
San Francisco, CA