W3MSH
| Joined: | Thu, Feb 21st 2013, 14:38 | Roles: | N/A | Moderates: | N/A |
Latest Posts
| Topic | Author | Posted On |
|---|---|---|
| Stamping on WSPR - an appeal to the ARRL | MW1CFN | on 16/5/17 |
| I purchased a WSPRLite about one month ago and was looking forward to using it to profile my HF antenna setup at my new QTH. However, after researching the use of unattended beacons on HF I am disappointed that I can’t use this ingenious device as designed (unattended beacon mode) to further my enjoyment of Amateur Radio. I have been in communication with Richard Newstead at Sotabeams and discussed that although the WSPRLite may be legal to use in many countries, it can only be used in attended mode by U.S. Amateurs. In light of this and to protect the interests of Sotabeams and U.S. resellers I recommended that Richard add a disclaimer on his website that WSPRLite must be used “in accordance with 97.203”. This disclaimer is now posted. It is frustrating to observe 20th century regulations – in my opinion - negatively impacting Amateur Radio’s use of this and as yet unknown rapidly advancing 21st century technology. Case in point is the still unresolved bandwidth vs. baud rate in the ARRL’s proposal to the FCC in RM 11708 filed in late 2013! I will be meeting with representatives of the ARRL at Hamvention with a bold proposal as follows: As Amateur Radio has always taken pride in our enthusiastic and effective efforts at self-regulation and enforcement I would like to open discussion on the feasibility of the ARRL as the largest organization supporting our Amateur Radio service to assume responsibility for the following within our current FCC-regulated frequency allocations: - Modes of operation, bandwidth and attended/unattended operation Properly vetted, we COULD put this to a vote of the entire Amateur Radio community similar to the VE examination process to ensure fairness to all. At the very least we could be granted an STA (special temporary authorization) for a set period of time as a test to verify the feasibility of new communications methods and work out any real or imagined interference as a result. This test period would substantiate the need/value of permanent changes in our rules. For now we’re just playing an unnecessary waiting game hoping the FCC will act – BUT OVER THREE YEARS FOR RM 11708? I find this an absurd situation that merits review. We currently all agree and abide by the frequency restrictions/allocations afforded our respective license classes. In many cases, these restrictions serve to encourage enhancement of our technical knowledge and ability to enjoy our privileges as Amateur Radio operators. These modified mode/bandwidth and unattended modes could be authorized to only Extra Class licensees to further encourage deeper knowledge of the communications art. The sheer enjoyment of Amateur Radio has built many successful careers (mine is one of them) and led to many new technologies that otherwise would have been implemented over a much-longer period of time or not at all. I know I’m not alone in the knowledge that we have earned this privilege and respectfully propose this for the benefit of all. I have been in communication with John Johnston, W3BE and Dan Henderson N1ND at the ARRL. As you may know, John was Chief of the FCC Rules Legal Branch of the Amateur Radio service for many decades. http://hamgallery.com/Tribute/W3BE/ Dan was referred to me at the ARRL as our organization’s authority on our rules and their interpretation. Both of them concurred, and responded with their authoritative interpretation of the rules. John’s is as follows: Whoops! Sounds like our amateur service may have going on here an example of Excuse No. 27 Squatters’ Rights as listed in Collection of Excuses for not complying with our amateur service rules BE Informed No. 3.3! Rather, here is the latest and greatest version of the original question that was asked: Q. Are unattended beacons prohibited on frequencies lower than 10M? A. Presently, no “unattended” amateur stations are authorized anywhere the FCC is our regulator. “Unattended” means that no one is paying any attention to the station. That would be at odds with the most bedrock requirement codified in Section 97.7: When transmitting, each amateur station must have a control operator. Ours is a tradition-bound unstructured old fashioned “hear and be heard” radio service that relies upon the Section 97.105 control operator performing properly certain duties, in particular the general standards codified in Section 97.101: (a) In all respects not specifically covered by FCC Rules each amateur station must be operated in accordance with good engineering and good amateur practice. (b) Each station licensee and each control operator must cooperate in selecting transmitting channels and in making the most effective use of the amateur service frequencies. No frequency will be assigned for the exclusive use of any station. (c) At all times and on all frequencies, each control operator must give priority to stations providing emergency communications, except to stations transmitting communications for training drills and tests in RACES. There are, however, special accommodations for beacon stations in Section 97.203. It says: (d) A beacon may be automatically controlled while it is transmitting on the 28.20-28.30 MHz, 50.06-50.08 MHz, 144.275-144.300 MHz, 222.05-222.06 MHz or 432.300-432.400 MHz segments, or on the 33 cm and shorter wavelength bands. “Automatic control” is defined as: The use of devices and procedures for control of a station when it is transmitting so that compliance with the FCC Rules is achieved without the control operator being present at a control point. Q. I'm not aware of any FCC rules regarding unattended beacons. Section 97.105 only requires that the control operator must "ensure the immediate proper operation of the station." The control operator is operating in accordance with the rule if he ensures the immediate proper operation of the station through any appropriate means. A. Some advocates of unattended amateur stations contend that such is already authorized for repeaters. But, if that was the case, however, there would be some mention of it in Part 97 and a record of the rulemaking proceeding that adopted that authorization. As it stands, there are no permissions for any type of unattended amateur station in places where the FCC is our regulator. It looks as though you might be trying to cope with the dilemma described in Excuse No. 13 Inventor’s Prerogative, as listed in Collection of Excuses for not complying with our amateur service rules BE Informed No. 3.3. Part 97 was last rewritten in plain language over a generation ago and has been amended as our regulator has accepted as necessary. Now, the promise of smart radios seems to make it thinkable for as many citizens as possible – per our VECs’ agenda - to intercommunicate, presumably as as a social media. Smart radios, moreover, gives cause for our amateur service community to question the effectiveness and need for the traditional Section 97.105 control operator whose role is deeply rooted in mid-19th century telegraphy communications practices. Q. What rule would be required to authorize “unattended” amateur stations? A. It would probably have to be codified in a new paragraph Section 97.109(e): When an amateur station is being unattended, the control operator need not be at the control point. Any station may be unattended. If that were ever to come about, there may be no need for Section 97.109(d) automatic control. Rulemaking for amendments to Part 97 in recent years, it must be said, has been very, very lengthy indeed. On the other hand, the opportunity may be near for our amateur service community to breakout from tradition and reset for smart ham radios. Read A New Era for Amateur Radio BE Informed No. 10.3 and New Era Q/A Providing a Net Social Benefit BE Informed No. 10.4. 73, Bill W3MSH |
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| WSPR 24/7 | WD8KNI | on 16/5/17 |
| I purchased a WSPRLite about one month ago and was looking forward to using it to profile my HF antenna setup at my new QTH. However, after researching the use of unattended beacons on HF I am disappointed that I can’t use this ingenious device as designed (unattended beacon mode) to further my enjoyment of Amateur Radio. I have been in communication with Richard Newstead at Sotabeams and discussed that although the WSPRLite may be legal to use in many countries, it can only be used in attended mode by U.S. Amateurs. In light of this and to protect the interests of Sotabeams and U.S. resellers I recommended that Richard add a disclaimer on his website that WSPRLite must be used “in accordance with 97.203”. This disclaimer is now posted. It is frustrating to observe 20th century regulations – in my opinion - negatively impacting Amateur Radio’s use of this and as yet unknown rapidly advancing 21st century technology. Case in point is the still unresolved bandwidth vs. baud rate in the ARRL’s proposal to the FCC in RM 11708 filed in late 2013! I will be meeting with representatives of the ARRL at Hamvention with a bold proposal as follows: As Amateur Radio has always taken pride in our enthusiastic and effective efforts at self-regulation and enforcement I would like to open discussion on the feasibility of the ARRL as the largest organization supporting our Amateur Radio service to assume responsibility for the following within our current FCC-regulated frequency allocations: - Modes of operation, bandwidth and attended/unattended operation Properly vetted, we COULD put this to a vote of the entire Amateur Radio community similar to the VE examination process to ensure fairness to all. At the very least we could be granted an STA (special temporary authorization) for a set period of time as a test to verify the feasibility of new communications methods and work out any real or imagined interference as a result. This test period would substantiate the need/value of permanent changes in our rules. For now we’re just playing an unnecessary waiting game hoping the FCC will act – BUT OVER THREE YEARS FOR RM 11708? I find this an absurd situation that merits review. We currently all agree and abide by the frequency restrictions/allocations afforded our respective license classes. In many cases, these restrictions serve to encourage enhancement of our technical knowledge and ability to enjoy our privileges as Amateur Radio operators. These modified mode/bandwidth and unattended modes could be authorized to only Extra Class licensees to further encourage deeper knowledge of the communications art. The sheer enjoyment of Amateur Radio has built many successful careers (mine is one of them) and led to many new technologies that otherwise would have been implemented over a much-longer period of time or not at all. I know I’m not alone in the knowledge that we have earned this privilege and respectfully propose this for the benefit of all. I have been in communication with John Johnston, W3BE and Dan Henderson N1ND at the ARRL. As you may know, John was Chief of the FCC Rules Legal Branch of the Amateur Radio service for many decades. http://hamgallery.com/Tribute/W3BE/ Dan was referred to me at the ARRL as our organization’s authority on our rules and their interpretation. Both of them concurred, and responded with their authoritative interpretation of the rules. John’s is as follows: Whoops! Sounds like our amateur service may have going on here an example of Excuse No. 27 Squatters’ Rights as listed in Collection of Excuses for not complying with our amateur service rules BE Informed No. 3.3! Rather, here is the latest and greatest version of the original question that was asked: Q. Are unattended beacons prohibited on frequencies lower than 10M? A. Presently, no “unattended” amateur stations are authorized anywhere the FCC is our regulator. “Unattended” means that no one is paying any attention to the station. That would be at odds with the most bedrock requirement codified in Section 97.7: When transmitting, each amateur station must have a control operator. Ours is a tradition-bound unstructured old fashioned “hear and be heard” radio service that relies upon the Section 97.105 control operator performing properly certain duties, in particular the general standards codified in Section 97.101: (a) In all respects not specifically covered by FCC Rules each amateur station must be operated in accordance with good engineering and good amateur practice. (b) Each station licensee and each control operator must cooperate in selecting transmitting channels and in making the most effective use of the amateur service frequencies. No frequency will be assigned for the exclusive use of any station. (c) At all times and on all frequencies, each control operator must give priority to stations providing emergency communications, except to stations transmitting communications for training drills and tests in RACES. There are, however, special accommodations for beacon stations in Section 97.203. It says: (d) A beacon may be automatically controlled while it is transmitting on the 28.20-28.30 MHz, 50.06-50.08 MHz, 144.275-144.300 MHz, 222.05-222.06 MHz or 432.300-432.400 MHz segments, or on the 33 cm and shorter wavelength bands. “Automatic control” is defined as: The use of devices and procedures for control of a station when it is transmitting so that compliance with the FCC Rules is achieved without the control operator being present at a control point. Q. I'm not aware of any FCC rules regarding unattended beacons. Section 97.105 only requires that the control operator must "ensure the immediate proper operation of the station." The control operator is operating in accordance with the rule if he ensures the immediate proper operation of the station through any appropriate means. A. Some advocates of unattended amateur stations contend that such is already authorized for repeaters. But, if that was the case, however, there would be some mention of it in Part 97 and a record of the rulemaking proceeding that adopted that authorization. As it stands, there are no permissions for any type of unattended amateur station in places where the FCC is our regulator. It looks as though you might be trying to cope with the dilemma described in Excuse No. 13 Inventor’s Prerogative, as listed in Collection of Excuses for not complying with our amateur service rules BE Informed No. 3.3. Part 97 was last rewritten in plain language over a generation ago and has been amended as our regulator has accepted as necessary. Now, the promise of smart radios seems to make it thinkable for as many citizens as possible – per our VECs’ agenda - to intercommunicate, presumably as as a social media. Smart radios, moreover, gives cause for our amateur service community to question the effectiveness and need for the traditional Section 97.105 control operator whose role is deeply rooted in mid-19th century telegraphy communications practices. Q. What rule would be required to authorize “unattended” amateur stations? A. It would probably have to be codified in a new paragraph Section 97.109(e): When an amateur station is being unattended, the control operator need not be at the control point. Any station may be unattended. If that were ever to come about, there may be no need for Section 97.109(d) automatic control. Rulemaking for amendments to Part 97 in recent years, it must be said, has been very, very lengthy indeed. On the other hand, the opportunity may be near for our amateur service community to breakout from tradition and reset for smart ham radios. Read A New Era for Amateur Radio BE Informed No. 10.3 and New Era Q/A Providing a Net Social Benefit BE Informed No. 10.4. 73, Bill W3MSH |
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