Friday 9:15 AM, Greene County Fairgrounds, Forum Room 1: Dave Larsen, KV0S, will moderate the forum and discuss the development of the ka9q-radio, ka9q-web and wsprdaemon collaboration. Paul Elliott, WB6CXC, will discuss sdr accessories and the wsprsonde multi-channel TX server.
Paul / WB6CXC -- that's me! I'm going to be talking about the analog side of digital communications (dynamic range of SDRs, sampling issues, frequency / timing accuracy, and ways to optimize, etc.) I will cover some details of the TAPR and Turn Island gear, and (I hope!) open a conversation about any interesting details. The WSPRSONDE is an 8-channel propagation research transmitter (and killer WSPR/FST4W transmitter) that I am particularly proud of.
Paul - If I'm not otherwise occupied, I'll attend the TAPR seminar, but I confess that I didn't see anything described in the seminar description that I'm not already aware of that hasn't been out in the world for some time. Your TIS hardware's capabilities is indeed impressive, and if I had more time in my life, and a suitable (unique) location, I'd be tempted to put one on the air just to contribute to the overall HamSCI effort. I'm sure we'll cross paths at Hamvention and finally meet up in person.
It's not as detailed as yours, Steve, but I too got tangled in the weeds of Part 97 and decided to submit a more high-level response before the deadline. Now let's see what happens and prepare for defense if it becomes necessary.
Paul - Despite my statement that I wouldn't look at comments this weekend, I weakened and did, and saw yours. Kudos! I think we both used the word "accreted" in reference to the Part 97 regulations. Great minds...
Excellent comments Steve! The repeater coordination one may elicit some spicy responses haha.
If the ARRL filed it must have been too late to be posted by COB on the 11th. Very curious to read their comments and if they mention 219 MHz.
In general I was very disappointed by the other comments. They generally fell into a few categories:
1. Fellow amateurs copy-pasting pleas to not change a single thing in Part 97 (this was probably 60-70% of the total comments). It's really a shame so many didn't stop to think that this might be an opportunity to improve our hobby. To be clear, I didn't see any commercial interest in our spectrum in the comments.
2. Business trade groups begging to be able to robocall and text spam people again
3. Anti 5G people (no clue what that had to do with deleting regulations but man did they come in hot and heavy). I'll lump the anti smart meter people in here too.
4. GMRS people really mad they can't have linked repeaters. Some of these same people were advocating for a no-test "Novice" amateur radio license that grants you limited privileges. Maybe this makes me an elitist ham, but I'll be filing reply comments against that. The Tech exam can be taken online now and is in no way a barrier. Also I'm pretty sure testing is required by treaty.
5. Tons of stuff about LPFM ownership and operating requirements I didn't quite understand since I'm not in that world. There were those both for and against changes
There were several good amateur radio ones, yours included. Hopefully we get some good results!
Justin - I couldn't help myself in dipping (lightly) into the comments on my tablet during TV time last night. My overall conclusions about the reply types largely mirror yours.
Yep - the "anti-RF" folks did indeed weigh in hot and heavy. I'll add that there were a lot of folks who kind of missed the point of the exercise that the FCC was asking "What can we DELETE?" and suggested all kinds of restructuring, additional regulation, etc. which I don't think will get much traction with the FCC.
I didn't communicate with anyone about what I intended to write, and no one communicated with me (other than you notifying me of ORI's filed comments), so the following is just a guess on my part.
I suspect that the vast majority of organizations (and their Washington legal representation) looked over GN Docket 25-133 soberly and decided that this wasn't a serious effort on the part of the FCC. Thus "sticking their necks out" with a formal reply, in their name, wasn't worth the repetutional risk of being associated with the... "colorful?" comments that we both read with amusement. Except for the folks that had some grievances (perceived, or real, such as the anti phone spam regulations) that they wanted to register with the FCC.
I'll go further out on a limb and guess that FCC legal firms querying their "inside contacts" at the FCC got an answer of "the DOGErs did this, not us" and thus GN Docket 25-133 will end up being mostly performance theater and have no followup at the FCC.
But there was no way to know how this would go, until we could see all the filed comments up through the deadline (and, on Monday, see what came in over the weekend). Thus I think the caution of filing comments was prudent. Although I don't agree with the "don't change Amateur Radio one smidgen" commenters, I respect their passion and dedication to Amateur Radio in going to the trouble to file comments. Most Amateur Radio comments, that I've read to date, were well composed.
I'm glad that no commercial organizations seemed to take any swipes at Amateur Radio spectrum (that I've seen, or have seen reported, to date), but there's still Reply Comments time, so we'll have to be vigilant.
This is a good take. I think it's most likely this won't lead to anything and we'll end up filing the 219 stuff as a separate NPRM. It was written with that in mind. Oh well!
VArAC 11: There are some very nice and welcome features, with the exception of the email gateway. I think this is extremely dangerous and superfluous.
First: If you can do VarAC, you can also do Winlink.
Second: These days, criminals intensively use new technology. The VarAC email gateway would be a great way to send emails anonymously with hardly any possibility to trace the writer!
To play devil's advocate: Someone sets up a 500 EUR shortwave station, makes up call signs and distributes access data for Web sites with child pornography. Suddenly a swat team storms the house of the radio amateur...
Alexander - I'm not discounting what you're saying. The possibility you're stating is certainly present. But (solely in my opinion) it's easier and safer (for the perpetrator) to transfer illicit types of data solely via Internet or mobile phone (for example, using a "burner phone") than trying to use Amateur Radio. It's left to the individual station to manage their email relay. In my case, if / when I set up such a system, I will be intensely monitoring it to guard against the kind of abuse you're positing. Not to mention, the Amateur Radio bands are wide open for monitoring by others, so I have no pretense of any secrecy of anything I do over Amateur Radio.
Steve, thanks for your very well thought-out and considered replies to the FCC. I wish more people would put forth the same effort for the good of our hobby. All of your suggestions are great EXCEPT the 'anything goes' modulation on CB, FRS, etc. Methinks doing that would cause SOME issues of incompatibility with regular ol' voice users. Perhaps allowing non-analog signals on only some channels? OTOH, any regulations for CB are a waste of time.
John - Thanks for your kind words. Keep in mind that FRS and the other services are pretty localized, so local consensus will emerge such as a GMRS repeater using digital modulation, and others that prefer to remain analog. Yes, it could be a bit messy in the short term, but I don't think the services, and the users, are being well served by retarding the available technology. We used to have the luxury of segmenting different technologies into different portions of spectrum - such as AM broadcast versus FM broadcast versus TV broadcast. But now, we don't have that luxury - ALL the spectrum is allocated. So just like the mobile phone industry adopted digital techniques, so I think these services (and the users, and the vendors) should, and will, adopt digital techniques, to their long term benefit. None of these consumer devices are so expensive that they can't be replaced (and other than GMRS repeaters, there's no expensive infrastructure) with units that perform better and offer more capabilities such as an FRS radio that uses digital modulation and a data function.
John - IIRC, LTE on Amateur Radio is already being done; I just cannot cite the source of that info at the moment. I think I reported on it in a previous ZR. LTE is a "bit heavy" (in my opinion) for Amateur Radio and the "citizen" radio services, with lots of protocol and overhead (the carriers want everything that happens on "their" spectrum to be potential billable events). But, certainly the underlying technologies such as OFDM are usable on Amateur Radio and the "citizen" radio services.
I've been pondering digital over FRS and I believe the key is a feature built into every radio I've seen CTCSS and DCS. Most FRS users just want to talk to their group anyway, so as long as you don't hear the burst, it should mostly work out.
I'll note that in northern Utah there is a P25 Repeater and a FM repeater on the same channel pair. So far it seems to work fine because there are only a few P25 users so they don't have to hear the FM users, and the FM users don't here them as long as they use CTCSS rather than just a PL tone to open the repeater.
Bill - I'm imagining filing a Notice of Proposed Rulemaking for selecting a UHF television channel and expanding FRS (including data) into that because FRS TX power is so low, and so narrow channel that they couldn't possibly cause any interference to over the air television now that it's digital and being transmitted in... Megawatts? If that channel ever does get reallocated to cellular, the low value of the FRS units are easily throwaway and there's no infrastructure (and thus no high powered expensive repeaters) to worry about.
Hamvention: TAPR Forum
Friday 9:15 AM, Greene County Fairgrounds, Forum Room 1: Dave Larsen, KV0S, will moderate the forum and discuss the development of the ka9q-radio, ka9q-web and wsprdaemon collaboration. Paul Elliott, WB6CXC, will discuss sdr accessories and the wsprsonde multi-channel TX server.
Paul / WB6CXC -- that's me! I'm going to be talking about the analog side of digital communications (dynamic range of SDRs, sampling issues, frequency / timing accuracy, and ways to optimize, etc.) I will cover some details of the TAPR and Turn Island gear, and (I hope!) open a conversation about any interesting details. The WSPRSONDE is an 8-channel propagation research transmitter (and killer WSPR/FST4W transmitter) that I am particularly proud of.
Paul - If I'm not otherwise occupied, I'll attend the TAPR seminar, but I confess that I didn't see anything described in the seminar description that I'm not already aware of that hasn't been out in the world for some time. Your TIS hardware's capabilities is indeed impressive, and if I had more time in my life, and a suitable (unique) location, I'd be tempted to put one on the air just to contribute to the overall HamSCI effort. I'm sure we'll cross paths at Hamvention and finally meet up in person.
FCC - "Delete": I submitted my response just under the wire (https://www.fcc.gov/ecfs/document/10411066269015/1)
It's not as detailed as yours, Steve, but I too got tangled in the weeds of Part 97 and decided to submit a more high-level response before the deadline. Now let's see what happens and prepare for defense if it becomes necessary.
Paul - Despite my statement that I wouldn't look at comments this weekend, I weakened and did, and saw yours. Kudos! I think we both used the word "accreted" in reference to the Part 97 regulations. Great minds...
Excellent comments Steve! The repeater coordination one may elicit some spicy responses haha.
If the ARRL filed it must have been too late to be posted by COB on the 11th. Very curious to read their comments and if they mention 219 MHz.
In general I was very disappointed by the other comments. They generally fell into a few categories:
1. Fellow amateurs copy-pasting pleas to not change a single thing in Part 97 (this was probably 60-70% of the total comments). It's really a shame so many didn't stop to think that this might be an opportunity to improve our hobby. To be clear, I didn't see any commercial interest in our spectrum in the comments.
2. Business trade groups begging to be able to robocall and text spam people again
3. Anti 5G people (no clue what that had to do with deleting regulations but man did they come in hot and heavy). I'll lump the anti smart meter people in here too.
4. GMRS people really mad they can't have linked repeaters. Some of these same people were advocating for a no-test "Novice" amateur radio license that grants you limited privileges. Maybe this makes me an elitist ham, but I'll be filing reply comments against that. The Tech exam can be taken online now and is in no way a barrier. Also I'm pretty sure testing is required by treaty.
5. Tons of stuff about LPFM ownership and operating requirements I didn't quite understand since I'm not in that world. There were those both for and against changes
There were several good amateur radio ones, yours included. Hopefully we get some good results!
Justin - I couldn't help myself in dipping (lightly) into the comments on my tablet during TV time last night. My overall conclusions about the reply types largely mirror yours.
Yep - the "anti-RF" folks did indeed weigh in hot and heavy. I'll add that there were a lot of folks who kind of missed the point of the exercise that the FCC was asking "What can we DELETE?" and suggested all kinds of restructuring, additional regulation, etc. which I don't think will get much traction with the FCC.
I didn't communicate with anyone about what I intended to write, and no one communicated with me (other than you notifying me of ORI's filed comments), so the following is just a guess on my part.
I suspect that the vast majority of organizations (and their Washington legal representation) looked over GN Docket 25-133 soberly and decided that this wasn't a serious effort on the part of the FCC. Thus "sticking their necks out" with a formal reply, in their name, wasn't worth the repetutional risk of being associated with the... "colorful?" comments that we both read with amusement. Except for the folks that had some grievances (perceived, or real, such as the anti phone spam regulations) that they wanted to register with the FCC.
I'll go further out on a limb and guess that FCC legal firms querying their "inside contacts" at the FCC got an answer of "the DOGErs did this, not us" and thus GN Docket 25-133 will end up being mostly performance theater and have no followup at the FCC.
But there was no way to know how this would go, until we could see all the filed comments up through the deadline (and, on Monday, see what came in over the weekend). Thus I think the caution of filing comments was prudent. Although I don't agree with the "don't change Amateur Radio one smidgen" commenters, I respect their passion and dedication to Amateur Radio in going to the trouble to file comments. Most Amateur Radio comments, that I've read to date, were well composed.
I'm glad that no commercial organizations seemed to take any swipes at Amateur Radio spectrum (that I've seen, or have seen reported, to date), but there's still Reply Comments time, so we'll have to be vigilant.
This is a good take. I think it's most likely this won't lead to anything and we'll end up filing the 219 stuff as a separate NPRM. It was written with that in mind. Oh well!
VArAC 11: There are some very nice and welcome features, with the exception of the email gateway. I think this is extremely dangerous and superfluous.
First: If you can do VarAC, you can also do Winlink.
Second: These days, criminals intensively use new technology. The VarAC email gateway would be a great way to send emails anonymously with hardly any possibility to trace the writer!
To play devil's advocate: Someone sets up a 500 EUR shortwave station, makes up call signs and distributes access data for Web sites with child pornography. Suddenly a swat team storms the house of the radio amateur...
Alexander - I'm not discounting what you're saying. The possibility you're stating is certainly present. But (solely in my opinion) it's easier and safer (for the perpetrator) to transfer illicit types of data solely via Internet or mobile phone (for example, using a "burner phone") than trying to use Amateur Radio. It's left to the individual station to manage their email relay. In my case, if / when I set up such a system, I will be intensely monitoring it to guard against the kind of abuse you're positing. Not to mention, the Amateur Radio bands are wide open for monitoring by others, so I have no pretense of any secrecy of anything I do over Amateur Radio.
Steve, thanks for your very well thought-out and considered replies to the FCC. I wish more people would put forth the same effort for the good of our hobby. All of your suggestions are great EXCEPT the 'anything goes' modulation on CB, FRS, etc. Methinks doing that would cause SOME issues of incompatibility with regular ol' voice users. Perhaps allowing non-analog signals on only some channels? OTOH, any regulations for CB are a waste of time.
John - Thanks for your kind words. Keep in mind that FRS and the other services are pretty localized, so local consensus will emerge such as a GMRS repeater using digital modulation, and others that prefer to remain analog. Yes, it could be a bit messy in the short term, but I don't think the services, and the users, are being well served by retarding the available technology. We used to have the luxury of segmenting different technologies into different portions of spectrum - such as AM broadcast versus FM broadcast versus TV broadcast. But now, we don't have that luxury - ALL the spectrum is allocated. So just like the mobile phone industry adopted digital techniques, so I think these services (and the users, and the vendors) should, and will, adopt digital techniques, to their long term benefit. None of these consumer devices are so expensive that they can't be replaced (and other than GMRS repeaters, there's no expensive infrastructure) with units that perform better and offer more capabilities such as an FRS radio that uses digital modulation and a data function.
Ah, Steve, you raise points I had not considered. Fork: LTE on the ham band(s)? Wow, what we could do!
John - IIRC, LTE on Amateur Radio is already being done; I just cannot cite the source of that info at the moment. I think I reported on it in a previous ZR. LTE is a "bit heavy" (in my opinion) for Amateur Radio and the "citizen" radio services, with lots of protocol and overhead (the carriers want everything that happens on "their" spectrum to be potential billable events). But, certainly the underlying technologies such as OFDM are usable on Amateur Radio and the "citizen" radio services.
Found the link - Amateur Cellular project (https://xcl.is). Bad news is that I found it in this article - https://www.openresearch.institute/2025/04/29/are-multi-carrier-data-modes-illegal-in-amateur-radio/.
I've been pondering digital over FRS and I believe the key is a feature built into every radio I've seen CTCSS and DCS. Most FRS users just want to talk to their group anyway, so as long as you don't hear the burst, it should mostly work out.
I'll note that in northern Utah there is a P25 Repeater and a FM repeater on the same channel pair. So far it seems to work fine because there are only a few P25 users so they don't have to hear the FM users, and the FM users don't here them as long as they use CTCSS rather than just a PL tone to open the repeater.
Bill - I'm imagining filing a Notice of Proposed Rulemaking for selecting a UHF television channel and expanding FRS (including data) into that because FRS TX power is so low, and so narrow channel that they couldn't possibly cause any interference to over the air television now that it's digital and being transmitted in... Megawatts? If that channel ever does get reallocated to cellular, the low value of the FRS units are easily throwaway and there's no infrastructure (and thus no high powered expensive repeaters) to worry about.