[RTTY] List of Winlink stations

[Peter Laws]

On Sun, Mar 16, 2014 at 10:16 AM, Jeff AC0C <keepwalking188 at ac0c.com> wrote:
> John,
>
> Ah, if it were only so in reality.
>
> Winlink interprets the subband restriction as specifically **not** applying
> to their system.  See paragraph #2 on this page:
>
> http://www.winlink.org/guidelines
>
> They argue that the guy on the boat is actually the control op for the shore
> station.
>

Interesting.  Let me see if I have this right.

The claim is that these stations (let's call them mailhosts) are not
"Automatically controlled digital stations" under 47 CFR 97.221 so we
ignore anything in that part (like the frequency ranges in which they
can transmit and the 500-Hz bandwidth limitation).

The mailhosts are not automatically controlled because, the theory
says, they are controlled by the operator at the other end of the
link.

If that's the case, then mailhosts are operated remotely.  The rules
are confusing here because, beyond the definition of "remote control",
there isn't much about remote control of a station.  47 CFR 97.3(a)
has these definitions:

"(39) Remote control. The use of a control operator who indirectly
manipulates the operating adjustments in the station through a control
link to achieve compliance with the FCC Rules."

"(44) Telecommand. A one-way transmission to initiate, modify, or
terminate functions of a device at a distance."

"(45) Telecommand station. An amateur station that transmits
communications to initiate, modify or terminate functions of a space
station."

Note that the FCC doesn't define a "remote control station" and remote
control is not an authorized transmission under 47 CFR 97.111 so we
have to assume that the station remotely controlling the mailhost is a
telecommand station (telecommand is an authorized transmission per 47
CFR 97.111(b)(3)).

Telecommand stations fall under 47 CFR 97.213 where (a) says that if
the station being telecommanded does not have a wireline control link,
then the link must be done via an auxiliary station and (b) says that
there must be "Provisions [...] incorporated to limit transmission by
the station [under telecommand]  to a period of no more than 3 minutes
in the event of malfunction in the control link."

I'll stipulate that the mailhosts probably meet (b) but (a) is a
problem because, per 47 CFR 97.201(b), "An auxiliary station may
transmit only on the 2 m and shorter wavelength bands, except the
144.0-144.5 MHz, 145.8-146.0 MHz, 219-220 MHz, 222.00-222.15 MHz,
431-433 MHz, and 435-438 MHz segments."

Since that likely never the case, how is this legal?

Either mailhosts are an "automatically controlled digital station"
under 97.221, and hence are limited in bandwidth and by band plan, or
they are being remotely controlled by stations under 97.213's
telecommand provisions, in which case they can only be controlled by
wireline or auxiliary station and the stations remotely controlling
the mailhosts never meet the definition of an auxiliary station.

Happy to be wrong but I don't see how they can have it both ways.

Go ahead and poke holes in this.  Please.


-- 
Peter Laws | N5UWY | plaws plaws net | Travel by Train!