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From: (Paul)
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Subject: TAPR's request for reconsideration
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Date: Tue, 25-Feb-86 11:12:27 EST
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Posted: Tue Feb 25 11:12:27 1986
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from NJIT's Digital Radio Net

M 17419 Tom Clark (W3IWI,2976) 2/24/86 10:44 PM L:305
KEYS:/FCC 85-105/TAPR FILES PETITION FOR RECONSIDERATION/FULL TEXT/PSE
CIRCULATE/
TO: (Group 95)

The following document was filed by TAPR with the FCC on Feb.24 in
response to the recent FCC Report and Order 85-105 pertaining to
automatic control of packet radio systems operating at frequencies
above 50 MHz. The credit for pulling this document together should
go to Harold Price, NK6K with some of the various ideas and comments
having been generated by WA7GXD, WB6YMH, W3VS and W3IWI.

73 de Tom, W3IWI

= = = = = = = = = = = = = = = = = = =

February 24, 1986

Before the
Federal Communications Commission
Washington, DC 20554

In the matter of )
Amendment of Part 97 of the ) PR Docket No. 85-105
Commission's Rules to permit )
automatic control of amateur ) RM-4879
radio stations. )

PETITION FOR RECONSIDERATION
----------------------------

Filed by:
Tucson Amateur Packet Radio
P.O. Box 22888
Tucson, Arizona 85734


To the Commission:

Tucson Amateur Packet Radio, a club with international membership
consisting of 1400 amateur packet radio enthusiasts which has
coordinated the volunteer development of many of the major build-
ing blocks of the existing amateur packet network, and whose
members have contributed since 1981 in the development of packet
radio hardware, software, and operating procedures, hereby
submits this petition for reconsideration of the report and order
on PR docket No. 85-105. Our comments are limited to activities
and operation above 50 MHz, as 85-105 only addresses these
frequencies.

Our reasons for requesting a reconsideration a

1) The inclusion of third-party traffic limitations, given the
current definition of third-party traffic, puts severe con-
straints on the design and utilization of the developing packet
radio network.


The questions that arise in the amateur packet community over
this issue are mainly semantic ones, caused by attempting to
force new technologies to fit the old definitions supplied by
97.3. The FCC has stated both at amateur gatherings and in the
comments associated with several recent actions that it is in-
terested in promoting computer assisted amateur communications
and what is commonly referred to as Computer-Based-Message-
Systems (CBMS), or Bulletin Board Systems (BBS). Bulletin Boards
are central repositories of messages sent between two or more
parties. The messages are stored for indefinite periods of time
on the bulletin board until they have been read by all parties
concerned. The messages are seldom sent on behalf of the control
operator of the BBS itself, and that's where the third-party
rules begin to cloud the issue.

By strict application of the current definition of third party
traffic :

97.3(v) Third party Traffic. Amateur radio communica-
tion by or under the supervision of the control operator
at an amateur radio station on behalf of anyone other
than the control operator.

A digital BBS system under automatic control could not transmit
messages stored on it that are not originated by or destined for
the control operator of that BBS. This makes illegal the major
purpose of the bulletin board system.

During the early development and on the air testing of packet
radio message systems, amateurs have viewed the message relay
device as a repeater. A repeater, as defined by 97.3(l), is a
device that automatically retransmits the radio signals of other
amateur radio stations. Part 97 does not specify a minimum
length for the time delay between receipt of the radio signal and
its retransmission.

Repeaters, as commonly used, can pass traffic between two
amateurs, neither of whom are control operators of the repeater,
with out having that traffic defined as third-party. Repeaters
have regulatory limitations of their own, however, and the
development of more complex message systems and other packet
switching devices will soon pass beyond the limits of the current
definition of "repeater".

Existing amateur BBS systems are already handling large numbers
of messages. Recent statistics reported by east coast stations
show counts of more than 1000 messages per month at each of
several sites. These systems are developing more sophisticated
methods of automatically forwarding messages from site to site.

To review, the language specified by 85-105, makes the BBS func-
tion, desired by both the amateur population and the FCC, illegal
unless the BBS is classed as a repeater. Imminent developments
in packet radio will make this classification invalid for some
devices under the current definitions. Therefore, 85-105, while
attempting to permit continued experimentation, actually inhibits
it.

A fix for this problem could be to include language in part 97
that specifically states that traffic originated by an amateur
station on behalf of an amateur and destined for an amateur is
not third-party traffic. This would make the permitted ac-
tivities of automatic control digital devices, serving in a
relay capacity but not classified as repeaters under the current
definitions, match the permitted activities of classic repeaters.
We note that several countries which prohibit third party mes-
sages (including West Germany, Norway, Japan and New Zealand)
have chosen the interpretation that amateur-to-amateur messages
passed thru packet radio BBS networks do not constitute third
party traffic.

2) The inclusion of third-party traffic restrictions, for
traffic of a character not discussed in 1) above, will severely
limit the utility of packet radio networks for public service ap-
plications.

The following discussion presumes the acceptance of the above
argument, and that the type of third-party traffic discussed is
traffic on behalf of someone other than the control operator of
the origination or destination station.

The FCC has done much to promote the use of high speed digital
communications in the amateur service. The constant growth of
experimentation in packet radio began when the use of the ASCII
code at speeds of 300 bps and more were permitted. The majority
of digital communications currently takes place at 1200 bps.
9600 bps is in limited use now, with 56kbps devices under con-
struction.

A requirement that third-party traffic be monitored at each relay
point in the network will limit the speed of the network to that
of the reading speed of the slowest control operator. It would
probably force the construction of two parallel networks, one at
low speed for third-party traffic, and one at high speed for non-
third-party traffic. This is undesirable.

The requirement to monitor the traffic at each relay point in the
network also places severe constraints on the design and im-
plementation of the network. In most of the networks now under
discussion, the message is only guaranteed to appear in its en-
tirety at its entry to the network, and at its exit. While the
message is in the network, it is broken into many small pieces.
They may be out of sequence as they pass a relay point. Some
parts of the message may take a different path through the
network.

With such message fragmentation, a control operator at an inter-
mediate relay point may not have sufficient information as to the
content of the message being relayed to correctly judge whether
the character of the message is that of third-party traffic or
not.

On the other hand, TAPR and its members share the FCC's concern
over potential abuse of the network by commercial interests. The
problem then becomes one of making sure the amateur regulations
are followed, while at the same time making it possible to build
the network.

We believe that it is possible to meet both of these goals. The
key is in treating the packet radio network, consisting of an un-
specified number of relay stations, as a "pipe". The pipe has an
input and an output. At the entrance and exit to the pipe are
non-automated control operators, who are ensuring compliance with
the rules. Once a message has been placed in the pipe by a
control operator, it need not be rechecked by an operator at each
relay point that makes up the pipe. The message is again checked
by a control operator at the end of the pipe if it is destined
for a third-party. The amateur who was the control operator at
the origination point of the message is responsible for ensuring
compliance with the rules.

We cite as an example: Assume that a network exists between San
Francisco and Los Angeles. There are two parallel paths in this
network, one that runs down the coast at 9600 bps on 221.95 MHz,
and a second that runs via Sacramento through the central valley.
An earthquake simulation is taking place between the Red Cross in
San Francisco and the State Office of Emergency Services (OES) in
Los Angeles. The Red Cross has entered a series of damage
reports and hospital bed estimates into a hand-held computer.
There are 40,000 characters of data involved. They hand the com-
puter to an amateur to transmit the data to Los Angeles over the
amateur packet network. This is obviously third-party traffic.
It is also obviously something that could not have been sent
using voice, Morse code, or other slow data rate modes, in less
than five hours.

The amateur in San Francisco reviews the data and determines that
it meets the amateur rules and regulations. He then, as control
operator of a station attached to the entry point of the network,
(the pipe), enters the data into the network. It now flows
through the pipe toward Los Angeles. Also in the pipe, simul-
taneously, are perhaps 20 other two way conversations. Monitor-
ing of the messages while in transit through the pipe is dif-
ficult to do as it flows at high speed through two different
paths. Part of the messages may even be automatically stored on
disk at an intermediate point if the Los Angeles end of the
network is down or congested. Once the message traffic is in Los
Angeles, the control operator of the station at the final des-
tination reviews them before passing them to the third-party.

A question that will certainly be raised at this point is, "Is
this actually likely to occur in the near future?" Yes. The
predecessor to the network above exists now. There are 5 relay
points along the coast between Los Angeles and San Francisco
operating on 145.01 MHz at 1200 baud. There are 4 relay points
that go up the central valley on 145.05 MHz at 1200 baud. During
an exercise with the State OES, amateurs were handed a disk from
an Apple II computer which contained simulated third-party
traffic. This traffic was relayed through the network to an at-
tended BBS system in San Francisco where it was stored and later
transmitted through a second network to Sacramento. Similar net-
works and public service drills exist in other areas of the
country. Large networks exist in the New England area, the Mid
Atlantic States, and in Florida.

The only thing missing between the imaginary scenario and the
actual one is higher baud rates and an increased level of
automatic control. Both of those elements will be required if
the amateur network is to provide a high level of service and
reliability in time of need.

To review, we suggest that the network be viewed as a pipe, and
that control operators at the input and the output to the pipe
are sufficient to ensure compliance with third party traffic
regulations.

At no time do we recommend that the third parties themselves be
given direct access to the network.

The question of unauthorized, i.e. commercial, access to the
network must be discussed. Since the regulations for traditional
non-digital repeaters do not require constant monitoring, neither
should the elements of a digital network. The only monitoring
required for repeaters under automatic control is when third-
party traffic is involved, this topic is discussed above.
Monitoring does go on, however, in the course of daily amateur
activities.

Policing of the amateur frequencies to keep intruders out has
always had a great deal of support in the amateur community, and
high speed digital communications will be no different. Although
the same things that make it hard to monitor third-party traffic
"in the pipe" will also affect an intruder watch, the intruder
must still use the same pipe input as everyone else. Here,
monitoring is easy. In fact, at its simplest level, packet radio
is the embodiment of the FCC's underlying requirements for
automatic control, "devices must be installed and procedures must
be implemented...". The network entry and exit points are
rigidly controlled by the protocols inherent in packet radio.
Although the particular procedures will change as the network
evolves, their attributes will remain the same. The originating
and destination station are readily discernible. Activity is
easily monitored and tracked by a computer. The devices neces-
sary to do this monitoring will be readily available, since they
are the same devices used by the general amateur population for
access to the network. The prices of such devices have fallen
from 00 to 9.00 in three years as the number of amateurs
using the mode rose from 200 to 14,000.

In summary for point 2), we believe that a requirement to monitor
third-party traffic at each relay point in the network places
such severe constraints on the design and implementation of the
network as to bring the feasibility of construction of such a
network into question. The alternative of making the network
off-limits to third-party traffic would be to fall far short of
the requirements of 97.1(a).


We believe that this problem can be fixed by adding a clause to
the new 97.80(b) as follows:

[(b) No amateur station may be operated under automatic
control while transmitting third-party traffic]

, unless that station is serving in a relay role in a
network of digital stations where the traffic was
originated at a station not under automatic control.

and elsewhere when third-party traffic is discussed.

TAPR wishes to thank the FCC staff for their obvious interest in
amateur packet radio and its continuing development.


/s/

Dr. Thomas A. Clark, W3IWI, Director
for Lyle Johnson, WA7GXD, President
Tucson Amateur Packet Radio
P.O. Box 22888
Tucson, Arizona 85734

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