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From net.ham-radio Tue Feb 2 14:55:10 2016
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From: (Steven Wheatley)
Newsgroups: net.ham-radio
Subject: ARRL BULLETIN 8 (automatic control of digital operation above 50 mhz)
Message-ID:
Date: Fri, 31-Jan-86 11:02:08 EST
Article-I.D.: inuxi.281
Posted: Fri Jan 31 11:02:08 1986
Date-Received: Thu, 13-Feb-86 07:28:47 EST
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Organization: AT&T Consumer Products, Indianapolis
Lines: 29
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qst de k9eui
hr arrl bulletin nr 8 from arrl headquarters
newington ct january 23, 1986
to all radio amateurs bt

fcc has released a report and order in pr docket 85 105
allowing automatic control for digital operation on frequencies
50 mhz and above. automatic control privileges continue for
repeater, auxiliary and beacon operation. the new privileges
are effective march 1986.

there is a dark lining in this silver cloud. a major goal in
the securing of automatic control privileges for digital
operation at 50 mhz and above had been the facilitation of
packet radio data transfer, computer to computer communication
and packet switching systems. such operation has continued to
be hampered by the requirement that a control operator be
present when third party traffic is handled. fcc has provided
no relief in this quarter in its report and order in pr docket
85 105. fcc found that neither the speed with which a message
is transmitted, nor the operating mode, justified any deviation
from the rule requiring that the control operator of an amateur
station be present at the control point whenever a station
engages in third party traffic. under these circumstances, the
expanded automatic control privileges gained through 85 105 may
be a hollow victory. arrl response to this apparent setback
for packet radio is scheduled for discussion at the january
arrl board meeting, in progress at this writing. watch w1aw
and qst for further details ar


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From: (Bob Clements)
Newsgroups: net.ham-radio
Subject: FCC & Automatic control (long but important)
Message-ID:
Date: Sun, 26-Jan-86 00:41:02 EST
Article-I.D.: brl-tgr.1999
Posted: Sun Jan 26 00:41:02 1986
Date-Received: Thu, 30-Jan-86 01:10:37 EST
Sender:
Lines: 256
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Before the PR
Federal Communications Commission FCC 86-18
Washington DC 20554 36413

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. )

_REPORT AND ORDER_

Adopted: January 13, 1986; Released: January 16, 1986

By the Commission:

1. On April 5, 1985, the Commission adopted a Notice of Proposed
Rule Making (50 F.R. 15196; April 17, 1985) to permit any amateur
station to be under automatic control provided that operation was on
frequencies above 29.5 MHz and that no third-party traffic was
transmitted. This was an expansion of the proposal requested by The
American Radio Relay League, Inc. (ARRL), who had requested automatic
control only for stations transmitting digital communications while
operating on frequencies above 30 MHz. Nineteen comments and one reply
comment were filed in this proceeding. (1)

2. Our Notice of Proposed Rule Making in this proceeding, _supra_,
particularly invited amateur radio operators experienced in automatic
control to submit comments on the practicality of expanding automatic
control to encompass all amateur operations, not just digital
communications. Such comments were not forthcoming. Because of the
lack of user support, we will adopt only the ARRL's recommendation to
limit automatic control to digital communications on very high
frequencies (VHF) and above. (We select 50 MHz rather than 30 MHz, as
the petitioner requests, because there are no amateur frequencies
between 29.7 and 50 MHz).

________

(1) Comments filed by the American Radio Relay League, Inc., (ARRL),
Robert C. Clements, Jess de la Cuesta and Joseph Anthony Wolos were
filed late. Consideration of the viewpoints expressed in those
comments will aid in the resolution of this proceeding. Therefore,
we accept them.
__________________________________________________ ______________________

(Page 2)

3. In the Notice, _supra_, we reminded amateur operators that the
current rules require the presence of the control operator at the station
control point whenever third-party traffic is being transmitted. We
emphasized that the proposed amendments would still prohibit automatic
control of the station when it is transmitting third-party traffic.
Some commenters were confused about unsupervised third-party traffic.
For example, repeater stations are already permitted to be operated
under automatic control. However, as with any amateur station, when they
are transmitting third-party traffic, the control operator must be present
at the control point monitoring and supervising the transmissions.

4. Many of the commenters request that high-speed digital operating
modes, such as packet-switching, bulletin boards, computer based message
systems and electronic mailboxes be exempt from the requirement that the
control operator supervise third-party traffic. They believe that the
third-party rules as applied to such high-speed digital communications are
impracticable and would, in effect, nullify the advantages of automatic
control. To acquiesce in that request would be inconsistent with other
types of amateur operation. Third-party traffic is radio communications
on behalf of anyone other than the control operator.(2) Neither the speed
at which the message is transmitted nor the emission mode (voice,
telegraphy, digital etc.) changes its character. This was pointed
out in our letter of October 19, 1978, to Richard L. Baldwin, then General
Manager of the ARRL.(3) In that letter, we reiterated that unsupervised
third-party traffic by amateur stations is not permitted.

5. Some comments suggest that the third-party traffic rules be
amended so that they would be applicable only at the time the third-party
traffic is first introduced into the amateur communications system.
However, screening the message content at its introduction does not change
the character of the traffic. It is still third-party traffic which must
be closely regulated in the non-common carrier Amateur service. Otherwise,
amateur facilities and frequencies would be open to non-amateurs and could
eclipse other amateur uses. Moreover, we are also concerned about the
final destination of the message. We do not want to give our approbation
to a mechanism which could be used to circumvent the international Radio
Regulations which forbid exchange of amateur third-party traffic between
countries who are not parties to agreements permitting such traffic.

______

(2) Section 97.3(v).
(3) FCC 78-742; 70 F.C.C. 2d 1303. See also News Release No. 2028,
October 25, 1978.
__________________________________________________ ________________________

(page 3)

International third-party radio communications are prohibited by Section
97.114 of the amateur rules and Article 32, number 2733 of the
International Radio Regulations (Geneva, 1979), except where arrangements
have been made between the two countries involved, Article 32, number
2734.

6. Some commenters suggest that MF and HF frequencies between 1.8
and 29.5 MHz be added to the frequencies available for automatic control
or that automatic control be extended at least to all digital
communications below 29.5 MHz on a regular basis or by temporary special
authority (STA). They state that coast-to-coast coverage for
point-to-point message handling would be accommodated by including MF
and HF frequencies. Because of the possibility of congestion on the MF
and HF frequencies, we do not believe that it would be advisable to permit
automatic control on those frequencies.

7. Robert C. Clements is under the impression that we inserted a
clarification into the proposed Section 97.79 (b) that the station licensee
is presumed to be the control operator of the station, unless there is
documentation to the contrary. However, this is essentially the same as
the present wording of Section 97.79(b). The words "at all times" will
be deleted from this rule in order to be consistent with the revised
wording of Section 97.3(m)(3).

8. For the reasons given herein, we amend our rules to permit
automatic control only for digital communications on amateur frequencies
50 MHz and above. Further, we affirm our present rule that requires the
control operator to be present at the control point whenever the station
is engaging in third-party traffic.

9. IT IS ORDERED, That Part 97 is amended as set forth in the
Appendix hereto. This action is taken pursuant to the authority contained
in Sections 4 (i) and 303 (r) of the Communications Act of 1934, as
amended.

10. IT IS FURTHER ORDERED, That these rule amendments shall become
effective, March 14, 1986.

11. IT IS FURTHER ORDERED, That the Secretary shall cause a copy
of this Report and Order to be published in the Federal Register.

12. IT IS FURTHER ORDERED, That this proceeding is terminated.

__________________________________________________ ________________________

(Page 4)

13. Information in this matter may be obtained by contacting
Maurice J. DePont, (202) 632-4964. Private Radio Bureau, Federal
Communications Commission, Washington, D.C. 20554.

FEDERAL COMMUNICATIONS COMMISSION



William J. Tricarico
Secretary


Attachment: Appendix

__________________________________________________ ________________________

(Page 5)

_APPENDIX_

Part 97 of Chapter 1 of Title 47 of the Code of Federal Regulations is
amended, as follows:

1. The authority citation for Part 97 continues to read as follows:

Authority citation: 48 Stat. 1066, 1082, as amended;
47 U.S.C. 154, 303.


2. Section 97.3 (m) (3) is amended to read:

Sec 97.3 Definitions.

* * * *

(m) * * *

(1) * * *

(2) * * *

(3) _Automatic control_ means the use of devices and procedures for
control without the control operator being present at the control
point when the station is transmitting.

3. Section 97.79 (b) is amended to read:

Sec 97.79 Control operator requirements.

* * * *

(b) Every amateur radio station, when transmitting, must have a control
operator. The control operator must be present at the control point of
the station, except when the station is transmitting under automatic
control. The control operator must be a licensed amateur radio
operator or permittee designated by the station licensee. The control
operator and the station licensee are both responsible for the proper
operation of the station. For purposes of enforcement of the rules
of this part, the FCC will presume that the station licensee is the
control operator of the station, unless documentation to the contrary
exists.
__________________________________________________ ________________________

(Page 6)

4. Section 97.69 is amended by adding a new paragraph (d), as follows:

Sec. 97.69 Digital communications.

* * * *

(d) An amateur station may be under automatic control when
transmitting digital communications on frequencies 50 MHz and above.

5. A new section 97.80 is added, as follows:

Sec. 97.80 Operation under automatic control.

(a) When under automatic control, devices must be installed and
procedures must be implemented which will ensure compliance with
the rules when the control operator is not present at the control
point of the amateur station.

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

(c) Automatic control of an amateur station must cease upon
notification by the Engineer-in-Charge of a Commission field
office that the station is transmitting improperly or causing
harmful interference to other stations. Automatic operation
must not be resumed without prior approval of the Engineer-in-Charge.

6. Section 97.114 is amended by adding a new subparagraph (4) to
paragraph (b) as follows:


Sec. 97.114 Third-party traffic.

* * * *

(b) * * *

(4) Third-party traffic from an amateur station under automatic
control.

* * * *

__________________________________________________ ________________________

[The above copy retyped for distribution by Bob Clements, K1BC,
from the FCC text as obtained from ARRL. 25 January 1986.]


Relay-Version: version B 2.10 5/3/83; site utzoo.UUCP
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Path: utzoo!watmath!clyde!burl!ulysses!gamma!epsilon!zet a!sabre!petrus!bellcore!decvax!decwrl!amdcad!lll-crg!well!micropro!kepler!mojo
From: (Morris Jones)
Newsgroups: net.ham-radio
Subject: FCC & Automatic control (long but important)
Message-ID:
Date: Wed, 29-Jan-86 21:09:26 EST
Article-I.D.: kepler.471
Posted: Wed Jan 29 21:09:26 1986
Date-Received: Sat, 1-Feb-86 03:36:11 EST
References:
Reply-To: (Morris Jones)
Organization: MicroPro Int'l Corp., San Rafael, CA
Lines: 19
Summary: This is important!
Xref: dummy dummy:1
X-OldUsenet-Modified: added Xref

This Report and Order states in no uncertain terms that third-party
traffic may not be handled without a control operator present. But
what really struck home was the iteration of Part 97, "third party
traffic is traffic on behalf of anyone but the control operator."

That DOES NOT make an exception for traffic that originates from another
amateur radio operator.

That means no mailboxes, no RBBS, no network news reading without a
system control operator monitoring.

It's getting harder and harder to play by the rules.

Mojo, AA4KB

- --
Mojo
.... Morris Jones, MicroPro Product Development
{lll-crg,ptsfa,dual,well,pyramid}!micropro!kepler!mojo


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Hash: SHA1

This is from a web-site that is replaying Usenet, including
net.ham-radio, from 30 years ago (currently early 1986). The site is:

http://www.olduse.net

If you prefer to use your own newsreader, the site also supports an NNTP
connection at:

nntp.olduse.net:119


From net.ham-radio Sat Feb 13 12:12:52 2016
Relay-Version: version B 2.10 5/3/83; site utzoo.UUCP
Path: utzoo!watmath!clyde!burl!ulysses!bellcore!decvax!d ecwrl!amdcad!lll-crg!seismo!mo
From: (Mike O'Dell)
Newsgroups: net.ham-radio,net.ham-radio.packet
Subject: FCC awards pink ticket for BBS
Message-ID:
Date: Sun, 9-Feb-86 14:32:20 EST
Article-I.D.: seismo.1346
Posted: Sun Feb 9 14:32:20 1986
Date-Received: Tue, 11-Feb-86 07:20:08 EST
Organization: Center for Seismic Studies, Arlington, VA
Lines: 22
Keywords: BBS Pink
Xref: watmath net.ham-radio:3818 net.ham-radio.packet:222

I have just been informed that all the packet BBS's are now off the air.
A ham in Florida was just awarded a pink ticket for operating a packet
BBS. I don't have many (any!) details, but the cause cited appears
to be the bit about "no 3rd party traffic while under automatic control."
(See the latest ARRL newletter for details.... )

While I am not a fan of interconnecting BBS's (we know how well Usenet
works - I hope ham packet is more useful!), this materially restricts
why anyone would want to use packet in the first place - computer to
computer communications (yes, a TNC is a computer...).

Rumor has it that the august ARRL considers packet to vitally important
to the survival of ham radio. I suggest they mount an effort at least
as vocal as the last "no code" fiasco if they don't want to see it go
down in flames. The next thing you know, they'll be applying the ruling
to digipeaters.


"I learned the code, so now what can I connect to??"

-Mike O'Dell
KB4RGM


From net.ham-radio Sat Feb 13 12:13:00 2016
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Path: utzoo!linus!decvax!decwrl!pyramid!hplabs!well!micr opro!kepler!mojo
From: (Morris Jones)
Newsgroups: net.ham-radio,net.ham-radio.packet
Subject: FCC awards pink ticket for BBS
Message-ID:
Date: Tue, 11-Feb-86 17:14:29 EST
Article-I.D.: kepler.501
Posted: Tue Feb 11 17:14:29 1986
Date-Received: Thu, 13-Feb-86 19:05:49 EST
References:
Reply-To: (Morris Jones)
Organization: MicroPro Int'l Corp., San Rafael, CA
Lines: 29
Xref: linus net.ham-radio:3222 net.ham-radio.packet:230
Summary: The FCC has a point. Suggestions?

There's a very important point to the FCC ruling that we have to
remember. Amateur Radio CANNOT become a common carrier! Besides
providing unfair competition with the commercial carriers, it's
contrary to the spirit of *Amateur* Radio as experimentalists and
hobbyists.

Now how do we tread the fine line and operate our packet BBSes? If
there really is no control over third party traffic on Amateur Radio,
then we start to cross that line. I think at the very least we'll
have to emphasize clearly the nature of the third party traffic that
will be permissable (non-business, trivial, experimental -- following
the guideline that "Amateur Radio traffic must be trivial to the
degree that recourse to the established commercial carriers is not
justified").

I also think we're going to have to provide more control over the
BBSes -- more control operators and control points. It may mean
a set of rules for designating BBS users as control operators, and
providing protected access.

It won't be easy, but we can find a way to live with it.

Personally I think the spectrum should be chopped up and sold to
the highest bidder ....

- --
Mojo
.... Morris Jones, MicroPro Product Development
{lll-crg,ptsfa,dual,well,pyramid}!micropro!kepler!mojo


From net.ham-radio Sun Feb 21 10:11:33 2016
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From: (Paul Newland)
Newsgroups: net.ham-radio
Subject: packet in 3rd pty traffic
Message-ID:
Date: Fri, 21-Feb-86 08:36:24 EST
Article-I.D.: ky2d-2.135
Posted: Fri Feb 21 08:36:24 1986
Date-Received: Mon, 24-Feb-86 08:28:43 EST
Distribution: net
Organization: KY2D-2 Packet Radio Gateway, Little Silver, NJ
Lines: 133
Xref: dummy dummy:1
X-OldUsenet-Modified: added Xref


The following message from Tom Clark, W3IWI, was found on
NJIT's Digital Radio Net. I have posted it here for
your information, ad7i


M 16123 Tom Clark (W3IWI,2976) 2/21/86 1:02 AM L:124
KEYS:/FCC 85-105/K1OJH COMMENTS/NEWS FROM ARRL/BBS STATUS & RECOMMENDATIONS/
TO: (Group 95)

The following message may be of interest to those of you who are concerned
about FCC 85-105, what you can do, what the ARRL is doing, etc.
= = = = = = = = = = = = = = = = =
9953 PY 5749 K1BC K1OJH 860220 more on FCC rules
At K1OJH : 197 From K1OJH Rcvd 860219/0200, Sent 860219/1931
~Date: Feb. 18, 1986
To: NEPRA SYSOPs
~From: Dick Eastman
Subj: New FCC Regs

Just a note to let you know what I've been up to. In addition to
the various bits and pieces of messages that I have been
forwarding to you, I have also been talking with Perry Williams
at the ARRL. Perry is the person at the League who deals
primarily with the FCC. He did tell me a few things that have
been going on recently.

First of all, the FCC monitoring station in Maine that has been
getting all the publicity recently has not yet issued any
citations. They have called (at least) two SYSOPs that they
suspected might be running unattended H.F. stations. In one case,
they found no licensed Amateur on the premises during time of
operation. That person has not yet received a citation. If he
does get one, it will be for unattended operation below 30 MHz.
This issue is unrelated to the recent regulations issued.
Unattended operation below 30 MHz always has been and will
continue to be a violation of FCC regulations.

As to the new regulations, this is considered to be an "Open
Issue", with several items not yet clearly defined by the FCC.
The FCC's Chief of the Special Services Division (who is the Boss
of the head of the Private Radio Branch which administers Amateur
Radio) visited the ARRL in Newington last Thursday. He was given
a demonstration of packet radio, including traffic handling via
W1AW-4 running W0RLI software and W1AW-5 unattended digipeater.
The Chief was favorably impressed by what he saw and discussed it
at some length in a meeting afterwards. He stated that the FCC
should be encouraging development of Amateur Radio digital
networks.

ARRL President Price and several other reps, including Perry
Williams will meet with the head of the FCC's Private Radio
Bureau in Washington at the end of this month. At this meeting,
the ARRL will suggest new definitions of Amateur communications in
a "store and forward" mode versus Third Party Traffic. Both FCC
Chiefs have verbally recognized there is a difference and have
expressed willingness to consider them seperately. The League is
very optimistic on this issue. The regulatory authorities in several
European countries already differentiate handling messages on
behalf of hams versus non-Amateurs. Hopefully similar logic can
be worked into the FCC's regulations.

A second item on the agenda at this meeting will be a discussion
of who holds responsibility for "traditional" Third Party
Traffic. It is the League's position that the analogy is that of
a postcard in the Postal System. It's free and open, anyone in
the path may read it, but in most cases will not. The actual
responsibility lies with the person who originated the message,
not with eag("mailman" along the route. The FCC may or may not
agree with this analogy, the League has a bit less optimism on
this.

There is a side issue here that I did not discuss with Perry:
namely the rules about plain and unencrypted communications. I
really have reservations about the recent developments in
sending binary files back and forth. I'm not sure I know all
the ramifications of this, but I sure am uneasy about someone
loading a binary file onto a PBBS to be pulled later by
someone else. In a direct QSO, there would be less of a
question. I would sure hate to "muddy the waters" when
discussing BBS freedoms with the FCC.

Depending upon the outcome of the ARRL/FCC meeting, the ARRL will
file for Reconsideration of the recent rulemaking. Perry Williams
also recommends other interested individuals and groups should
also file for reconsideration. Calm, well-thought out comments in
volume will help. (Unless I hear otherwise from NEPRA's officers,
I will also file such a motion in the name of NEPRA.)

What do we do today? Perry very quickly pointed out that no one
at the League will recommend that you do or do not continue
operating your VHF BBS in unattended mode. He said that in his
recent discussions with FCC officials, it is clear to him that
the FCC has not finally decided how to handle ham radio "store
and forward" QSOs. The recent written rulemaking was very
definitive in some ways, yet does not reflect what the various
FCC officials are saying in face-to-face conversations.
xD
Perry Williams would not give an "official" League
recommendation, but did point out that W1AW-4 and W1AW-5 are
remaining in operation in unattended mode. In fact, this
unattended VHF BBS was demonstrated to a senior FCC official last~r
Thursday. Perry stated he would be "very surprised" if anyone
receives a citation for unattended operation of a BBS above 30
MHz.

What does NEPRA recommend to New England SYSOPs? The conservative
viewpoint is to operate only when the SYSOP is seated in front of
the screen with his finger on the switch. A more liberal method
is "damned the regulations, full speed ahead". I believe the
reality is some where in between. The FCC is very interested in
unattended operation on H.F., but has paid no attention to VHF
operations. Obviously, each of you must decide for yourselves.
Probably maintaining a low profile is best. I, for one, am very
willing to have an unattended VHF BBS in operation under my call.
If I had an H.F. gateway, I'd power the H.F. rig off whenever
there wasn't a licensed amateur in the house.

For the futu I (we) should file a Request for Reconsideration
with the FCC. Input is hereby solicited. Please pass on your
concerns to the traffic handlers using your BBS. The National
Traffic System should be heavily involved in this.

To quote that great American philosopher, Yogi Berra: the game
ain't over 'till it's over.

- Dick, K1OJH
= = = = = = = = = = = = = = = = =
You may be interested to know that TAPR is filing a strongly worded set
of comments with the FCC that are being written at this very minute. Those
who are coordinating this activity are NK6K, WA7GXD, WB9FLW, WB6YMH & W3IWI.

73 de Tom, W3IWI

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Hash: SHA1

This is from a web-site that is replaying Usenet, including
net.ham-radio, from 30 years ago (currently early 1986). The site is:

http://www.olduse.net

If you prefer to use your own newsreader, the site also supports an NNTP
connection at:

nntp.olduse.net:119


From net.ham-radio Sat Feb 27 19:00:31 2016
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From: (Paul)
Newsgroups: net.ham-radio
Subject: TAPR's request for reconsideration
Message-ID:
Date: Tue, 25-Feb-86 11:12:27 EST
Article-I.D.: ky2d-2.139
Posted: Tue Feb 25 11:12:27 1986
Date-Received: Fri, 28-Feb-86 08:17:38 EST
Distribution: net
Organization: KY2D-2 Packet Radio Gateway, Little Silver, NJ
Lines: 312
Xref: dummy dummy:1
X-OldUsenet-Modified: added Xref


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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From net.ham-radio Sat Mar 12 11:20:24 2016
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From: (Steven Wheatley)
Newsgroups: net.ham-radio
Subject: ARRL BULLETIN nr 17 (FCC Docket 85-105 auto. digital control above 50 MHz)
Message-ID:
Date: Tue, 11-Mar-86 10:43:00 EST
Article-I.D.: inuxi.299
Posted: Tue Mar 11 10:43:00 1986
Date-Received: Thu, 13-Mar-86 06:50:21 EST
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qst de k9eui
hr arrl bulletin nr 17 from arrl headquarters
newington ct march 5, 1986
to all radio amateurs bt

the arrl has filed a petition for extraordinary relief in
docket 85 105, requesting the fcc to temporarily rescind its
prohibition on the transmission of third party traffic by
amateur stations using digital communications under automatic
control above 50 mhz, while the fcc considers some 19 petitions
for reconsideration filed by amateur radio operators and
groups, including arrl. in its petition the league stated that
the fccs prohibition, if permitted to take effect, would have a
crippling effect on the development of packet radio. for
further details, see the arrl letter and happenings, may qst
ar

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