[net.ham-radio] Proposal

mikey@techsup (12/30/85)

The folowing is the text of a letter sent to the FCC.  It has been 
assigned an RM number, I just don't have it now.  I'm posting this
to see what kinds of comments are generated, personally, I'm 
slightly favorable to the proposition, but time and arguements
will tell.  Responses can be sent to me at trsvax!techsup!bbimg!mikey
or to Mr. Stoner, who was the author of the article.

Any mail sent to me will just be forwarded to Mr. Stoner at his
Compuserve address.

Just for info, the responses on HAMNET  of Compuserve have been
very positive, the only concerns seriously addressed as of this 
posting have been about 6 meters and model airplane people.

Anyway, the text follows

mikey  N1DVJ
trsvax!techsup!bbimg!mikey



-------------------------- tear here ----------------------------




Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554
In the matter of               
)
)
Creation of a new radio class   
)
and allocation of spectrum for  
)
the owners of personal computers
)
)
TO: The members of the Commission)

PROPOSAL FOR THE CREATION OF THE PUBLIC DIGITAL RADIO SERVICE

FILED BY
Donald L. Stoner, W6TNS
October 20 1985

SUMMARY OF PETITION

This petition is to identify the need for a new class of radio service. 
This radio service is described in the petition as the PUBLIC DIGITAL 
RADIO SERVICE.

The petition shows that creation of the service and the allocation of 
spectrum is in the public interest, convenience and necessity.

Presently, computer-to-computer communication by the general public is 
confined to the telephone network.  Millions of computer owners find 
that it is increasingly expensive to  utilize this network to satisfy 
their communication needs.

Establishment of the PUBLIC DIGITAL RADIO SERVICE would permit the 
owners of personal computers to communicate by radio.  Instead of a 
traditional channelized scheme, the petition describes a radio Local 
Area Network (LAN).  The PUBLIC DIGITAL RADIO SERVICE permits an 
infinite number of local area radio networks to be interconnected into 
a national packet radio network.

The PUBLIC DIGITAL RADIO SERVICE would allow computer owners to 
exchange messages, bulletins, computer programs and other information 
by radio, and at no cost.  

The petition describes how the Commission could create the PUBLIC 
DIGITAL RADIO SERVICE, which will adequately serve the needs of the 
public for at least the remainder of this century.

BACKGROUND OF PETITIONER

I have been a radio amateur (W6TNS) since 1954.  A large part of my 
career has been devoted to the field of writing.  For an extended 
period, I was the Novice and Technician editor of CQ Magazine.  I have 
written hundreds of articles and authored several books on the subject 
of amateur radio and computer communications.  I was also responsible 
for the idea which grew to become the OSCAR satellite, and I was able 
to make useful contributions to the program during its early stages.  I have been an educator and  taught at Chaffey College in Southern 
California.

This experience provided an opportunity to observe and study personal 
motivation, goals, effort versus reward, and so on.  During the 70's I 
was involved in the manufacturing of Citizens Band communictaions 
equipment.  Thus, I was able to write about CB initially and then 
participate in its "self destruction".  The experience afforded the 
opportunity to see what "went wrong" and, with hindsight, to realize 
how to avoid these mistakes in the future.

In 1983, I made a reply comment to PR Docket No. 83-28.  This was the 
controversial "No-Code" document.  As part of my reply, I proposed "THE 
CREATION OF A COMPUTER HOBBYIST LICENSE CLASS".

It was (and is) my contention that this license class would have 
brought in literally millions people into amateur radio.  However, the 
amateur fraternity decided that no amateur radio licenses should be 
granted, under any circumstances without a Morse code examination.

Clearly, the proposal for a "computer radio band" received considerable 
attention on the part of the Commission.  In its decision relative to 
Docket 83-28, the Commission left open the possibility of a radio 
service for computer hobbyists.  However, radio spectrum was not 
allocated for such a service.

It is the purpose of this document to further amplify the need for such 
a service, to make a recommendation on spectrum allocation, and to 
outline technical specifications which will ensure the successful 
introduction and usage of the PUBLIC DIGITAL RADIO SERVICE.

The accumulated knowledge of the writer has provided certain insights, 
many of which have contributed to the preparation of this document.  A 
careful and serious consideration of my petition by the Commission is 
sincerely appreciated

THE PETITION

Why Is A Computer Radio Band Needed? The increasing popularity of 
personal computing is well known.  There are presently more than 18 
million of these devices in the hands of the public.  Today, a computer 
can be purchased for less than $100.  Thus any American, rich or poor, 
can afford to own a personal computer.  Many experts feel there will be 
a ten-fold increase in the acquisition of computers by the end of this 
decade.

The Commission is aware of the popularity of computers.  High frequency 
digital circuits produce radio and television interference.  The 
Commission recognized the growth in the personal computer market and 
regulated interference levels before an untenable situation occurred.

The Commission is also aware of the popularity of computer 
communications via the telephone network.  As a result of the 
"Carterphone Decision", there has been an enormous increase in type 
acceptance applications for telephone modem devices.  According to 
Creative Strategies International, a Cupertino Calif., research firm, 
the modem market will reach $555 million by the end of 1985 and is 
expected to top $1.5 billion by 1988.  The bulk of these telephone 
modem sales are to the owners of personal computers.  It is presently 
possible to purchase an FCC approved modem for as little as $29.95.  If 
one assumes an average price of $100.00, there will be 15 million 
modems in use by the end of this decade.

Why do owners of personal computers utilize modems?  The desire to 
communicate with others having like interests does not diminish with 
the acquisition of a computer.  Computer owners like to play 
interactive games, exchange messages and software, assist others having 
like computers, and so on.  This desire to communicate has provided the 
basis for a number of national information utilities such as The 
Source, CompuServe, PlayNet, Delphi and The Shuttle.  These 
organizations allow computer owners to interconnect and exchange all 
manner of information via the national telephone network.  These 
services are extremely popular.  CompuServe, for example, claims to 
have 250,000 members.

The exchange of information between computer owners is not free, 
however.  These information utilities charge hourly fees varying 
between $3.00 and $20.00, depending on time of access and the data 
rate.

More relevant to this discussion is the cost for the transport medium, 
the telephone network.  In the previous decade, the cost of a computer 
was relatively high while telephone costs were relatively low.  In this 
decade the situation has reversed.  Telephone companies are begining to 
implement charges based on time and distance for local calls.  Thus the 
cost to the public for computer communications will increase 
significantly.  

Recently, a number of telephone companies attempted to impose a 
surchage on those using modems.  Some modem users have added an 
expensive second telephone line.  Without this alternate path, the 
telephone is essentially out-of-service while the user is on-line with 
the computer.  Thus the user is unable to receive emergency calls.  At 
the slow data rates prevalent on telephone networks, these periods can 
be quite lengthy.

It should be stressed that much of the existing and future computer 
communications could be handled by suitable radio devices.   Recently 
there has been a significant increase in the interest and use of radio 
waves to transport computer data.  The trade press regularly mentions 
companies trying various approaches which avoid the use of telephone 
lines for data communications.  The most common activity seems to be 
the use of FM subcarriers for point-to- multipoint networks.

Motorola has been a leader in the area of point-to-point data 
communications.  They offer a wireless data system which allows 
portable-computer owners (possessing Motorola cellular-radio 
telephones) to transmit data at speeds up to 1200 baud.

Motorola has also supplied a hand-held terminal for IBM field 
engineers.  It allows two-way communication with a central tranmitter 
and computer.

Finally, Motorola has recently petitioned the Commission to share 
satellite frequencies in the 1.7 gHz.  range to create local area 
business radio networks.

All of the above products benefit the business community.  They are 
designed to make businesses more profitable, productive and/or 
efficient by transmitting computer data via radio.

None of the products described above are intended to benefit the 
general public.  The PUBLIC DIGITAL RADIO SERVICE can make personal 
computers more useful, interesting and/or productive to the general 
public.  It is in the public interest, convenience and necessity that 
the public also have access to this precious resource called the radio 
spectrum.

While modem communications will continue to be popular, an alternate 
cost-free communication path should be available to the computer 
public.  

This document describes such a service, called the PUBLIC DIGITAL RADIO 
SERVICE.  It petitions the Commission to create such a service with 
suitable regulations and to allocate sufficient spectrum to insure the 
success of the service.

TYPE OF SERVICE PROPOSED

In the past, there has been some discussion of permitting computer 
communications on the Citizens Band.  CB usage and channel loading is 
currently a fraction of what it was during the previous decade.  Four 
additional CB frequencies, formerly used for the remote control of 
objects, are virtually unused.  Other bands (in particular, 49 and 72 
mHz) could accomodate computer communications.

In the above examples, a channel scheme is implied.  The use of 
communnication channels, however, leads to ham type operations ("send 
the data to me on channel X").  Channelized operation and shared 
services would probably not work for the PUBLIC DIGITAL RADIO SERVICE.  
The users of this service will expect operation and performance similar 
to that of a telephone modem.  Telephone modems do not have channels.

The computer public is not interested in the radio aspects of 
communication other than as a means to an end.  Thus there is no need 
or desire for voice communications as part of an equivalent radio 
modem.  This precludes the "chit-chat" type of operation which was 
destructive on the Citizens Band.

Sharing frequencies with voice communication (such as on CB) would be 
unacceptable.  Interference, caused by frequency sharing, would garble 
the received data.  Since the interference is transparent, the typical 
user will assume that data errors are caused by equipment faults.  
Thus, it is essential that the frequency allocation for the PUBLIC 
DIGITAL RADIO SERVICE not be shared with any other service.

Channelized plans inevitably lead to a further problem.  If the service 
becomes popular, there will ultimately be a need for more channels.  
This is exactly the situation which occurred on the Citizens Band.  The 
Commission is well aware of the problems which resulted from the 
disruption of adding additional CB channels.  

The alternative to a channelized scheme is to send the data at high 
rates using packet technology.  A single wideband channel can be 
thought of as a digital highway with addressed packets entering and 
leaving the route in a highly organized manner (see "What Is A Packet 
Radio Network?").

AN ALLOCATION OF SPECTRUM FOR
THE PUBLIC DIGITAL RADIO SERVICE

A wideband digital channel can only be accomodated within the VHF band 
or higher frequencies.  To keep the cost of equipment low, a band 
between 30 and 300 mHz is ideal.  Some readers may feel that a service 
as described should be placed in the UHF or SHF range.  This might be 
true if a suitable allocation within the 30-300 mHz band did not exist.

However, within this frequency range there is a band, 2 mHz in width, 
which is virtually unoccuplied and therefore unused.  I refer to the 
spectrum between 52 and 54 mHz.  Radio amateurs are permitted to 
operate on frequencies between 50 and 54 mHz (the six meter band).  For 
a number of reasons, this band is "underoccupied".

It is estimated that out of 400,000 radio amateurs in the United 
States, less than 1,000 are active on the six meter band.

Due to the potential for inteference with adjacent television channel 2 
(54-60 mHz), virtually all six meter users operate between 50 and 52 
mHz.  For all practical purposes the radio spectrum between 52 and 54 
mHz is wasted.

The radio spectrum is a precious natural resource much the same as our 
beaches and national parks.  The public access to the radio spectrum 
resource is severely limited.  The entry fee is an amateur radio 
license.  This can be justified in instances where the resource is 
severely limited or where national security is involved.  It cannot be 
justified by any stretch of the imagination when the beach or park is 
totally deserted!

POTENTIAL FOR TV INTERFERENCE

The Cause of Interference- Radio amateurs have not used the 52.0- 54.0 
mHz portion of the six meter band due to the high risk of television 
interference.  This interference problem occurs through no fault of the 
amateur or the transmitting equipment.

A typical ham six meter transmitter can induce several volts of radio 
frequency energy in a nearby television antenna.  The induced voltage 
can be thousands of times stronger than the television station being 
received.  Thus, the strong signal from the ham station can overload 
the TV receiver.  

This effect is called crossmodulation and can cause interference on all 
channels.  The level of interference can vary in intensity from 
"crosshatching" to a total loss of the picture.

Radio amateurs have access to many bands of frequencies throughout the 
radio spectrum.  None of the other bands share the close proximity to 
television channels as does the six meter band.  Clearly, amateurs have 
resolved the problem of television interference simply by not using 
this portion of the six meter band.

To date, no one has addressed the problem of using these frequencies in 
a manner which will not cause television interference.

This portion of the spectrum could be utilized by reducing the power 
output of the transmitter below the point where television interference 
can occur.

Eliminating Interference- It is the opinion and experience of the 
writer that no televison interference can occur from a radio modem 
operating in the 52.0- 54.0 mHz band if the following conditions are 
met:
1.  The signal strength of the TV station being received exceeds 100 
uvolts.
2.  The effective radiated power of an adjacent radio modem does not 
exceed one watt.
3.  The separation between the radio modem antenna and the television 
antenna exceeds 8 meters.
4.  The radio modem antenna is vertically polarized with respect to the 
horizontally polarized TV receiving antenna.
5.  All modulation and spurious products which fall outside the 
authorized bandwidth conform to the FCC 43 plus 10 log10 rule.

If these conditions are met, the 52.0- 54.0 mHz band will be suitable 
for the PUBLIC DIGITAL RADIO SERVICE and no significant television 
interference will occur.

WHAT IS A PACKET RADIO NETWORK?

The reader may be familar with the term "local area network" (LAN).  In 
this system a limited number of computers are connected together by 
cable in a manner which permits intercommunication.  A packet radio 
network is an infinite number of LAN's connected together by radio 
waves.

A packet radio network may be thought of as a digital equivalent of the 
U.S.  Postal Service.  The information to be sent to another computer 
is equivalent to a letter.  The letter is placed in an envelope which 
includes a destination address.  This is called the packet.  This 
packet is sent along with those of other users into the network, which 
acts like a mailbag.

The packet address also includes something like a postal zip code.  The 
postal analogy varies somewhat in the handling of messages.  Each radio 
modem connected to the network is a destination mailbox.  At the same 
time it can also act as a "post office" for others connected to the 
network.

Each user is considered to be a "node" in the PUBLIC DIGITAL RADIO 
SERVICE.  These stations or nodes constantly monitor the transmissions 
(mailbags), looking for packets (envelopes) which are addressed to 
them.  If a message addressed to the node is detected, it is held in 
memory (the recipients mailbox).

The message may be intended for a nearby node as indicated by the "zip 
code".  In this case, the node "mailbox" does not activate.  Rather, 
the node becomes a "post office" and passes the message to one or more 
other nodes.  The reply from the destination computer is handled in the 
same manner but the direction is reversed.

Packet radio transmission (movement of the "mailbags") can occur at 
very high speed.  In fact, the speed is only limited by the bandwidth 
of frequencies alloted to the network.  This petition requests a band 
of frequencies 2 mHz in width.  This is sufficent to handle data rates 
in excess of 1 million bits per second.  When one considers that the 
typical rate of data transmission on a telephone network is 300 bits 
per second, it can be seen that the PUBLIC DIGITAL RADIO SERVICE can 
handle a large number of simultaneous users.

Unlimited Users- Actually, the number of simultaneous users is 
unlimited due to an advantage of FM radio transmission called the 
"capture effect".  Each node will "hear" (or capture) only the 
strongest stations in the immediate area of the node.  More distant 
stations will be inaudible and will not cause interference.  Thus users 
in two adjacent cities (for example) can communicate within the cities 
without interference from users in the adjacent city.  Of course, if it 
is desired to send a message to a user in the adacent city, the 
appropriate nodes will repeat the message until it reaches the 
destination and triggers a delivery acknowledgement.  Other messages, 
not addressed to the adjacent city, will be ignored.

WHAT IS A RADIO MODEM?

The device to control the node (see previous section) functions similar 
to a ham radio "digipeater" but at a much higher speed.  Since the the 
term "digipeater" has no significance to the general public, the node 
controller is refered to as a "radio modem".

What is it?- Technically speaking, the radio modem is a non-persistent, 
carrier sense, multiple access with collision avoidance device.  In 
practice, the radio modem consists of a small box, whip antenna and 
coaxial cable.  The unit contains a receiver and transmitter, in 
addition to an RS-232 computer interface.

In addition to acting as a transceiving device, the radio modem is also 
capable of repeating received packets on the basis of a stored 
algorithm.  In other words, it will receive, store and retransmit 
messages along the addressees route.  Note that it is capable of acting 
as a repeater even if it is not connected to a computing device.

Training-  Upon activation, the radio modem executes a stored training 
sequence.  When first installed, the radio announces its presence and 
digital address in the network.  The radio modem transmits its position 
with respect to other units, determines the digital address of other 
nearby units and finally, adjusts its power output to the minimum 
required to maintain communications with the other nearby units.  This 
power can vary from 1 milliwatt for densely populated areas to the 1 
watt maxiumum in rural areas.  It is essential that the radio modem 
transmit only sufficient energy to maintain contact with other nearby 
radio modems (nodes).

Training the radio modem for power output insures that a minimum signal 
level is radiated by the antenna.  The purpose is to minimize the 
possiblilty of television interference.  Some readers may point out 
that one watt is simply not enough power for rural areas.  However, it 
is not the purpose of the PUBLIC DIGITAL RADIO NETWORK to duplicate the 
elaborate trunks of the public telephone network.  There are bound to 
be areas which cannot pass messages.  Under no circumstances should 
consideration be given to increased power output in these instances.  
If a high power mode is available, it will be abused.

A COMPARISON WITH CB RADIO

Those reviewing this petition may have a tendency to make comparisons 
with the introduction, usage and the degeneration of the 27 mHz 
Citizens Radio band.

The following points are presented with this comparison in mind.  No 
one, including the petitioner, would like to see the PUBLIC DIGITAL 
RADIO SERVICE meet the same fate as the 27 mHz Citizens Band.

There is a major reason for the chaos which developed on the 27 mHz 
Citizens Band.  The licensees of this service did not feel it was in 
their interests to abide by the Rules and Regulations.  We can learn 
from this experience by designing a service  where Rule compliance is 
in the interests of the user.

MODULATION- There must be no provision for voice communications in the 
PUBLIC DIGITAL RADIO SERVICE.  Users of radio modems wish to exchange 
digital data, not the spoken word.

IDENTIFICATION- Enactment of a PUBLIC DIGITAL RADIO SERVICE will not 
affect the licensing workload of the Commission.  Services which are 
essentially self-regulating (such as the remote control of objects, 
garage door openers, etc.) do not require the use of call letters.  
Inherent in the addressability of the radio modem, is a built-in aid to 
compliance and enforcement.  Each radio modem has its own unique 
identification code, that is, its packet address.  This is both the 
serial number and digital address of the unit.  This code also 
identifies the manufacturer and the physical location of the radio 
modem.  Violations of technical requirements can be easily be 
correlated by manufacturer.  In other words, if a significant number of 
units are observed to be defective, the manufacturer can be immediately 
determined by serial number correlation.

If a unit is found to be non-complying, a message can be addressed to 
that radio modem advising the user of the problem.  The Commission 
personnel sending the message receives the customary delivery 
acknowledgement of the message.  Thus there can be no question that the 
user received the Notice of Violation.

POWER OUTPUT- A major contributing factor to the "CB problem" was the 
addition of power amplifiers to CB radios in an effort to increase the 
talk range.

Adding a power amplifier to a radio modem will produce no increase in 
performance.  The unit will "retrain" to reduce its power output to 
maintain the nominal signal level at nearby radio modems.  Thus, the 
power delivered to the antenna might be 50 milliwatts (as an example), 
with or without the power amplifier.

ANTENNA- To further increase transmitting range, high gain, directional 
antennas were connected to CB radios.  If the same type of antenna were 
connected to a radio modem, it would result in a "negative 
improvement".  There would be no increase in range, since the radio 
modem would retrain to produce the nominal signal strength at nearby 
nodes.   More important, the radio modem connected to a directive 
antenna could miss messages arriving from directions other than the 
antenna principal gain lobe.  By the same token, raising the elevation 
of the antenna would cause no noticable increase in communication 
range.

OFF FREQUENCY OPERATION- Illegal out-of-band operation caused sizable 
headaches for the Commission enforcement personel.  This will never be 
the case with the PUBLIC DIGITAL RADIO SYSTEM however.  There is only 
one "channel" or band.  If, by some means, the frequency of a radio 
modem were lowered, the data would be destroyed by amateur radio 
transmissions.  If it were raised, video information from TV channel 2 
would do the same thing.

TECHNICAL SPECIFICATIONS

The "radio modem" (node controller) to be used in the PUBLIC DIGITAL 
RADIO SERVICE shall meet the following specifications:

FREQUENCY BAND- Equipment authorized to operate in the PUBLIC DIGITAL 
RADIO SERVICE shall be capable of receiving and transmitting data 
within the band from 52.0 to 53.999 mHz.

MODULATION- The data shall frequency modulate the carrier in a 
frequency shift keyed scheme.  Under no circumstances will equipment 
authorized for use in the PUBLIC DIGITAL RADIO SERVICE have provision 
for voice modulation or detection.

MODULATION AND SPURIOUS PRODUCTS-

The data rate (see Note 1), waveform and signal processing shall be 
such that all products which fall outside the authorized bandwidth be 
suppressed by 43 plus 10 log10 (mean output power, in watts) decibels.

POWER OUTPUT- The power delivered by the final amplifier stage into a 
72 ohm load shall not exceed 1.0 watts.  Further, the radio modem (node 
controller) shall have an initial powerup "training" mode.  Upon 
powerup, the power output will be 1 milliwatt.

The power will increase during "training" in 3 db.  steps until contact 
is established with nearby radio modems (node controllers).  This value 
is stored in memory and becomes the nominal power output for the radio 
modem.

ANTENNA- The antenna shall consist of a vertical radiator which does 
not exceed one-quarter wavelength.  The antenna shall exhibit no gain 
or directional characteristics.  The antenna shall be supplied with a 
nominal length of coaxial cable.

TRANSMITTER IDENTIFICATION- Each radio modem shall have an imbedded 
identification which is transmitted as part of its packet address.  The 
address will be used to identify the manufacturer, the serial number 
and the routing code of the equipment.

PACKET CONSTRUCTION- The packet and destination address will be 
contained in the header.  The header will be constructed to limit the 
number of destination addresses.  This is done to specifically preclude 
the transmission of "junk mail".

REMUNERATION- Users of the PUBLIC DIGITAL RADIO SERVICE shall be 
specifically prohibited from receiving any form of remuneration or 
compensation, either in the form of funds, goods or services, for 
handling data on the PUBLIC DIGITAL RADIO SERVICE (see Note 2).

TYPE ACCEPTANCE- Type acceptance procedures, similar to those for 
Citizens Band equipment, will be required.  This insures that 
commercially manufactured equipment used in the PUBLIC DIGITAL RADIO 
SERVICE meets the specified technical requirements for this service.

NOTE 1- No data rate is given in these proposed specifications.  It 
should be left to industry to determine the data rate.  Schemes, 
unknown to the writer or Commission, may permit higher rates within the 
authorized bandwidth than conventional theory would dictate.

NOTE 2- The purpose of this provision is to prevent the use of the 
PUBLIC DIGITAL RADIO SERVICE for the benefit of common carriers.  The 
restriction should not be construed to preclude the use of the PUBLIC 
DIGITAL RADIO SERVICE for business applications.  For example, the 
radio modem would be extremely useful within buildings to avoid the 
need for local area network cabling.  It is likely the signals of an 
office radio LAN would not connect to the external PUBLIC DIGITAL RADIO 
SERVICE.

The reader might envision that the service would be usurped by the 
business community.  This is not likely, however, due to the 
self-regulating nature of the PUBLIC DIGITAL RADIO SERVICE.  Businesses 
are used to the near instantaneous response of telephone data 
communications.

In comparison, the message response of a packet radio network is 
relatively slow.  Only small businesses would find these delays 
tolerable.  These are the same business which can least afford the 
increase in telephone rates.

There is an analogy in the use of the Citizens Band.  Numerous channels 
are available and the equipment is quite inexpensive.  Even so, this 
band is seldom used for business purposes.  There are simply too many 
disadvantages for the business community.

CONCLUSION

In response to this petition, the Commission may point out that there 
has been no popular "groundswell" to create a computer radio service.  
Likewise, there was no public interest in the creation of a television 
service in the 30's.  However, in 1932, the Commission recognized the 
significance of television and allocated two bands for development of 
this new technology.  

By the same token, the Commission recognized the impact that FM radio 
broadcasting would have on sound reproduction.  In 1941 they allocated 
an eight mHz band to bring high fidelity sounds to the public.

In either case, there was very little awareness that such technologies 
were possible when the allocations were made.  

The creation of a PUBLIC DIGITAL RADIO SERVICE is another instance 
where the Commission could take the initiative and create a new service 
in keeping with current technology.

International Regulations-  Since the allocation is above 50 mHz, it 
appears that no international treaties would be involved in making the 
proposed allocation.  Rather, it is likely that other countries would 
develop a similar service for their citizens.

Amateur Radio Opposition- It is safe to assume there will be sizable 
opposition to this petition by amateurs.  The writer has been a radio 
amateur for 30 years.  During this period, no permanant allocation has 
been "taken away" from the amateur radio fraternity.

However, there can be no defense by amateurs of the inactivity on 6 
meters.  A reallocation of the frequencies requested would benefit the 
majority at virtually no expense to the minority.

Amateur Radio Colaboration- The principal purpose of this petition is 
to obtain an allocation for a public computer communication band.  The 
writer would not object if this goal could be achieved as part of the 
Radio Amateur Service.  The computer public would accept an 
administrative fee in return for access to the radio spectrum.  
However, they would never accept any sort of "testing" to achieve this 
goal.

The writer would like to thank the Commission for the opportunity to 
submit this petition.  Further, the writer appreciates the 
consideration this petition will receive by the members of the 
Commission.

Signed 20 October, 1985
----------------------
Donald L. Stoner, W6TNS
6014 E. Mercer Way
Mercer Island, Wa.  98040
(206) 232-6968

karn@petrus.UUCP (Phil R. Karn) (01/04/86)

What follows are my initial reactions to the Stoner proposal for creation
of a Public Digital Radio Service.  Since I do not have access to Compuserve,
I'd appreciate it if somebody forwarded this note to Don Stoner.

I agree that the time has come for such a service. As involved as I am in
the development of amateur packet radio, I can see plenty of legitimate
applications for low cost, personal digital radio communications that
properly lie outside the scope of the Amateur Service (e.g., business use,
need for encryption, etc). Further, the need for such a service is enhanced
by the amateur community's continuing opposition to any form of "no code"
license, an irrational attitude that will surely prevent packet radio from
ever reaching its full potential in the Amateur Service.

Having said this, however, I must take issue with the details of Stoner's
proposal, in particular his frequency and bandwidth recommendations. As a
radio amateur, I instinctively resist the "giving away" of any amateur
allocation, even one as lightly used as 52-54 Mhz. I am also not convinced by
Stoner's contention that an inexpensive radio modem, particularly one with
an emission bandwidth of 2 megahertz, could be operated without interference
to nearby TV receivers tuned to Channel 2. At the very least, I would like
to see the results of any tests he has conducted to reach this conclusion.

Another problem I forsee with such a large allocation, which apparently would
be used for a single, wideband RF channel, is multipath dispersion.
The DARPA packet radio community has found that packet radios operating
in a typical urban or suburban environment are effectively limited to
data rates of 100 to 400 kilobaud because of the intersymbol interference
caused by multipath propagation effects. Only when a strong line-of-sight
signal component fully captures the receiver is it possible to operate at
higher speeds. Therefore, it is clearly not necessary to allocate such a wide
portion of spectrum if the intent is only to provide a single RF channel.

I think that Mr. Stoner's proposal would be an excellent one once he finds
another, smaller, piece of spectrum outside the amateur bands to use.

Phil Karn, KA9Q

mikey@techsup (01/09/86)

I posted the original of Mr. Stoners letter to usenet, and I'll forward
all respones to him.

All comments are appreciated, both pro and con.

For the record, I've gotten information that the ARRL will oppose
this proposal.

Finally, I'll reread the original and other documents that I didn't post
to usenet and any that are relevent, I will post here.  I didn't post
them all before, but I see a need now as there seems to be the feeling
here that we are 'giving up' a section of the spectrum when the feeling
from the other documents is that this will not be a surrender, just that
there would be an additional service, as it would require a license to
operate but that would be allowed under technician and higher class
license.  In other words, this would be a new 'no code' license for
'digital' use only.  I personally think it is a great vehicle for enticing
new blood into the HAM ranks, as newcomers will get a taste of the RF
spectrum and then want to move up to VHF high or UHF once they get their
TECH license, or into HF if they learn more than the minimum code.

mikey N1DVJ
trsvax!techsup!bbimg!mikey

stephany.WBST@XEROX.COM (01/16/86)

Objections to Mr. Stoners proposal:

(1) The fundamental communication link in this world is cable, not
radio.  (read any engineering handbook on communication).  There is far
too little spectrum space for the communication of the world.  radio
only comes in when (1) mobile units are involved which cannot be
connected by radio, and (2) remote areas where it is impracticle for a
cable.  This is the present thinking and the proposal of spectrum for
units that can be connected by cable would be a waste of spectrum.
Tradition grants BC and TV spectrum on the basis of historical use,
which could be replaced by cable, but this cannot occur with present
thinking.  

Since the proposal is only as a convenience and cost reduction for
computer 
people it would hardly justify spectrum space, not being a necessity.
There are dozens of people that want spectrum space as a convenience and
dont get it because it is not a necessity.

(2) The Canadian digital brought in about 200 people.  Since the
population of the U.S. is about 10 times that of Canada, then the
estimated number would be 2000.  This is not sufficinet to justify a new
licese class.  Experience has shown that what keeps out people is the
technical test, not code, particularly in young people.  You propose the
oppocite, no code yet technical knowledge.

(3)  The proposal licenses a mode that is already licenses.  If we allow
digital licenses, then why not CW only or phone only, or TTY only?  It
makes little logical sence.

I am not saying you may not have merits to your proposal, I am saying
the above arguments against your proposal must have good answers.  If
you can't come up with some, then your out.

Good luck.
			Joe N2XS