Hi John,

While the EasyPal program is primarily used on HF for image 
transmission, since it can send data in most any form, the Third Symbol 
does matter here in the U.S. since you can not send image (fax) in the 
RTTY/Data portions of the bands unless 500 Hz or narrower and EasyPal is 
closer to a phone bandwidth in size. Many countries have no specific 
rules like we have and while it is true that there are a number of 
scofflaw hams, the better way to handle this is to change the rules 
rather than violate them. Or at the very least, have a bureaucratic 
interpretation which then effectively has the force of law unless 
overridden by higher authority.

The land mobile services do not follow Part 97 rules so these rules do 
not apply to radio amateurs. If the FCC ignores certain rules (and they 
clearly do, based on what can only be described as stonewalling on some 
of these issues for quite some time), then it is difficult for them to 
argue when any rules are not followed. Not a good thing in my view and 
hopefully the view of most law abiding hams. But just because most of us 
follow the rules, (or try to t the best of our abilities), does not 
necessarily mean we agree with them. Unfortunately, the majority of U.S. 
hams do not support changes to these rules:(

My preference would be getting the FCC to agree that any files that 
could be sent by a program such as EasyPal would then be legal to use in 
the Phone/Image portions of the bands. I suppose sending a petition 
would be one way since they do not respond to those of us who have asked 
for an interpretation. I am guessing that they are betting that no one 
will petition them, which would be a 100 times more paperwork for them 
than just responding to a request. Otherwise, you would think that they 
would respond, as best they can, to avoid a petition. I would like to 
see it decided one way or the other.

73,

Rick, KV9U


John B. Stephensen wrote:
> EasyPal uses DRM so there are multiple subcarriers and its facsimile 
> as it displays an image on the screen so J2C seems appropriate. The 
> FCC definition of facsimile allows the image to be stored in a file 
> before or after transmission without affecting the emission 
> designator. If it is used to transmit a file that it can't display 
> then the third symbol might have to change to D but the FCC probably 
> doesn't care at this point as it allows data in broadcast TV 
> transmissions and RTTY mixed with voice transmissions in the land 
> mobile radio service.
>  
> 73,
>  
> John
> KD6OZH

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