On Nov 22, 2013, at 8:37 PM, Jeff Blaine wrote:
> As I look back at this topic, the ARRL actions and the arguments seen here
> are about the same ones as in 1995, but at that time, the winlink/pactor
> intention was a bit more obvious. This time it's a very low key operation...
Jeff,
It is low key, but either (1) they are naive, or (2) they think *we* are naive.
I encourage everyone to take a *close* look at ARRL's petition, as filed.
http://www.arrl.org/files/media/News/Petition%20for%20Rule%20Making%20AS-FILED%2011%2015%202013.pdf
(As with reading patents, where you can skip all the prior-art and stuff and
jump directly to Claims. In the case of this petition, you can jump past all
the lawyer talk and go directly to see the proposed changes. That is the part
that will affect us in the future, not the explanations and justifications.)
Specifically, go to near the end of the manuscript, where the proposed change
to 97.307 (f) (3) are listed. First...
(A) they removed the requirement that specific digital codes need to be used,
by adding a sentence that allows unpublished codes (see 97.309(b)) to be used
on Amateur bands!
Currently (before petition), you have to adhere to 97.309(a), which states that
the code used in a digital transmission must be either Baudot, ASCII, Amtor
(which is a 7 bit extension of Baudot), or if it is none of these, the code has
to be *publicly documented* (emphasis mine).
This makes PSK31 Varicode, DominoEX Varicode, etc also legit. While keeps
proprietary codes prohibited.
Modern proprietary codes are basically the same as encryption -- they are
usually weak encryption but nevertheless protected by the DMCA (Digital
Millennium Copyright Act, enacted by Congress in 1998). The DMCA thus keeps
you from being able to reverse engineer proprietary modems in order to decode
messages that passes through public Amateur air space.
Notice that by allowing unpublished code, the ARRL modifications will negate
the protection we have currently from manufacturers who obscure the protocols
and codes that are use in the proprietary modems which they sell.
When you get QRMed, you cannot tell who is QRMing you. Interference is
therefore unenforcible, since it cannot even be reported.
The petition then...
(B) removes the 300 baud restriction from 97.307 (f) (3).
That part at least follows the purported intent of the petition. However, the
petition goes on to ...
(C) allow bandwidths of up to 2.8 kHz.
Notice that of the changes that I listed above as (A), (B), and (C), *only*
item (B) has *anything* whatsoever to do with the purported objective of the
petition.
So, why did the ARRL include the changes (A) and (C) that I listed above?!
For those who are curious... as written, the proposed changes to 97.307 (f) (3)
allows Pactor 4, among probably some other modems to become legal. Pactor 4 is
not legal today.
Before today, I only had the 2004 version of Part 97 on my bookshelf, and held
back on commenting on what appeared to be a glaring problem in the petition.
The 2007 copy of Part 97 arrived at my doorstep late this afternoon. I wanted
to be sure that I was not imagining things as related to the current 97.309.
73
Chen, W7AY
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