I believe that your analysis of part 97 is correct. 73,
Dave, AA6YQ --- In digitalradio@yahoogroups.com, Rick <[EMAIL PROTECTED]> wrote: > > Andy has some very good points, > > If you are a human operator and listen on the frequency for a period of > time, ideally at least a few minutes if you do not use QRL or a voice > equivalent, and do not hear any other activity, you may be fairly safe > in assuming the frequency is not in use. It is not 100%, of course, > since the hidden station could be transmitting and you can not detect > that station. > > Unlike voice or CW, the 12 seconds (or whatever you have the parameter > set to in the program), is quite a lengthy period of time. One partial > solution would be to have a shorter QRL type of mode. In fact, it could > even be QRL? in CW, since that is the only mode that can be used on all > frequencies that digital modes can be used in the voice/image and text > digital portions of the bands. Similarly, there would have to be some > way for other stations to respond immediately that the frequency is in > use and that would be very difficult to do without some major design > changes in our digital programs. But it could be done if it was mandated. > > Incidentally, this is one of the benefits of ARQ operation between two > stations. A third station will hear one of the two sides of the > conversation so they know that the frequency is in use, even if they can > not monitor the content. > > Unattended operation is considered illegal by the FCC here in the U.S. > and this seems to be glossed over by the proponents of these kinds of > automatic modes. As the FCC enforcement folks have said that all > stations must have a control operator even if they are not at the > control point. Mr. Hollingsworth has stated: > > "Furthermore, "automatic" control does not mean "unattended" > operation." and also "Unattended operation is not authorized under the > rules." And this is referring to repeater operation which many of us > think of as being basically unattended much of the time. What he seems > to really mean is that even if you are not directly controlling at the > control point, you are always held responsible for your station > activities because you are still the control operator. > > But realistically, there are "unattended" operations. Even ARRL has uses > the word, even if the FCC does not. (There is no such thing as > unattended operation in Part 97.) Some may think of beacon operation as > being "unattended." But beacons are normally not legal under Part 97, > below 28.0 MHz, even though an increasing number of stations are > effectively operating as beacons if they are transmitting without a > human operator present and are doing it for such things as propagation > studies. > > 97.3(a)(9)/ Beacon/. An amateur station transmitting communications for > the purposes of observation of propagation and reception or other > related experimental activities. > > This is exactly what PropNet and part of the time what ALE is doing, is > it not? > > 97.203 (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. > > There are no lower frequencies where automatically controlled beacons > are permitted by licensed radio amateurs in the U.S. If the control > operator is present, then it is not automatically controlled and could > be legal, as long as you listen before transmitting to insure the > frequency is not in use. > > I have developed a number of questions that I will be forwarding to the > FCC for help in understanding how the rules are being applied (or not > being applied?). Before doing that, I have forwarded these questions to > ARRL Regulatory Branch as of this morning, for their help in > understanding why there seems to be a discrepancy between the rules and > what is actually happening on the ham bands as of late. Depending upon > their response, I will then contact FCC enforcement and find out their > understanding. > > If a group member believes that I am not understanding Part 97 > correctly, then please point out my error(s). I have asked this several > times, and except for private e-mails on the subject, no one seems to > want to deal with this issue. > > 73, > > Rick, KV9U > > > > Andrew O'Brien wrote: > > PC-ALE , and I assume Multipsk ALE, is designed to work in attended > > mode for almost all applications other than two likely scenarios. > > > > 1. Soundings: This now referred to as "station ID" by the HFLINK web > > site ( http://hflink.net/qso/). I think this is a fair description, > > since it simply sends the callsign "this is K3UK" for a 12 second > > period (approximately). It is likely that the station's ID will be > > sent , once, on all HF bands over a 5 minute period, usually once per > > hour > > > > > > 2. Individual Call: A station manually initiates a call to a station > > but PC_ALE uses look-up tables to determine which band to start on , > > and moves up or down the bands until al link is found , or all bands > > have been tried once and the attempt is ended. This is a longer > > call, similar yo a voice station sending "P5DX de K3UK" for a 20- 30 > > second period . > > > > > > Both scenarios are likely unattended. When I do this I am actually in > > the shack and usually need to make sure the SWR on all bands is "good" > > while I am calling. I am guilty of sometimes heading to the kitchen > > for a quick snack and arrive back at the shack to find that I have > > already transmitted on a couple of bands. > > > > As Bonnie mentioned last week, ALE has no busy detect for none ALE > > signals. So yes, Soundings and certain other aspects of ALE cause > > QRM. However, what is the REAL difference between sending your > > callsign a few times via ALE , versus picking up the Mic and asking > > "is this frequency in use" ? I wonder if ALE soundings consisted of > > "QRL? QRL ? de K3UK K3UK K3UK K " and then stopped , would we object? > > > > Andy. > > > > > > On 10/1/07, *Rick* <[EMAIL PROTECTED] > > <mailto:[EMAIL PROTECTED]>> wrote: > > > > After the contact, I switched over to ALE 141A and listened for quite > > some time in unproto mode. Later on I heard an eastern station > > calling > > the HFN, which must be the HFLink Network. This can not be an > > automatic > > station as it was outside the automatic subband. I am not suggesting > > that it was the eastern station since I could not monitor ALE > > while in > > Olivia mode. > > > > This frequency turns out to be Channel 21, which is one of the 40 HF > > "channels" that is claimed by the HFLink group. > > > > It is still possible for the first operator to hear a mode being > > used on > > a given frequency and then when the second operator turns it over > > to the > > third operator, and the first operator can not hear the third > > operator, > > they may incorrectly assume that the frequency is not in use. This is > > one of the fairly downsides to having many digital modes that can not > > understand the content of most other modes (except for CW and voice). > > Even having an identifier would not help if they do not realize > > that the > > two stations are having a QSO. > > > > 73, > > > > Rick, KV9U > > >