gnu (03/08/83)
Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) PR Docket No. 83-28 Establishment of a Class of ) Amateur Operator License Not ) Requiring a Demonstration of ) Proficiency in the International) Morse Code. ) COMMENTS I am overjoyed to see a proposal for a codeless Amateur Radio Operator's License. I am a computer programmer, 27 years old, with more than 10 years' experience in computers. Two years ago I became heavily involved with the local Amateur Packet Radio group, headed by Hank Magnuski, KA6M. (The group has since become the Pacific Packet Radio Society.) At that time there were about 30 people in the group. I was excited by the idea and the potential of packet radio and was willing to learn and to help it get going. I started collecting information and equipment. I subscribed to the newsletters of the Vancouver Area Digital Communications Group and the Hamilton (Ont.) packet radio club, and bought the AMRAD Packet Radio Conference proceedings. I bought a 1200 baud modem and a packet radio "terminal node controller" board. I started reading listings of the software that runs in the controller board. I reviewed a Canadian book (from Tab Press) on packet radio. At the same time, I was attending Packet Radio meetings and meeting many of the hams involved. I discovered that, to connect a radio to my computer and send 1200-baud ASCII computer data over the air, I was required to deal with a Federal agency and to learn an archaic transmission code well enough to decode it in my head "on the fly". I began to see why packet radio was still holding meetings and not building a network. I'm not sure how familiar you are with the history of the computer industry. I am not the person to teach it, but one thing has been clear to me: Much technological progress has occurred because anyone could attempt to design and build an improved anything -- hardware, software, communications network, mass storage device, you name it -- and it was NOT controlled by the Government, choked by bureacracy, or shielded by special interest rules and legislation. If I liked ASCII better than EBCDIC for my application, there was nobody who could force me to use EBCDIC. If I found a way to store twice as many bits on a disk, or push twice as many down a local area network cable, the marketplace and my organizational ability would decide whether my invention was worth its salt. I began to learn about Amateur Radio from the hams around me. Here is what I learned: * Whether or not I ever USE Morse code, I need to learn it to pass this test. Being able to write a program that can read it off the air and translate to ASCII on my screen is not good enough. The idiot work must be done by a human to be worthwhile. * If I don't go get a license, but just set up a radio and a modem and start transmitting, I am committing a Federal crime, and there are plenty of old hams who do nothing but sit in their homes and listen for people like me so they can turn me in to the Feds. This is true whether or not I cause any harm or interference to anyone else. * It's theoretically possible to run our packet radios faster than 1200 baud -- in fact by using telephone style modems we are using a lot more bandwidth than we need -- but it would take a special variance from the FCC even to experiment with it, and there's no guarantee that it would ever be legal for the general public anyway. * Yes, I could hook up a packet radio to my Computer Bulletin Board System (which had been running for about a year, accepting public telephone calls on my Apple computer to allow people to send and receive messages with each other) and let people send and receive messages over the radio, but there are laws that require me to be there at all times so I can cut them off if they swear or something. (I need a "control operator".) Furthermore, I can't pass "third party traffic" and if someone might use my system instead of making a toll phone call then I am illegally using amateur radio to steal business from the phone company. * I have some good ideas, but why don't I go get a license and then I'll really have something to say. My opinion is not worth much because my name doesn't have random letters and numbers after it. (This was not true of everyone but was definitely there in some.) This was daunting, but I still had enough excitement and energy to continue working. (Partly, I couldn't believe things were really that bad. If I built a packet radio station and got it working and providing a useful service to the Amateur community, nobody would really play straight-and-narrow with the rules, would they?) I bought parts for my Terminal Node Controller board and started to build and debug it -- buying and borrowing tools and equipment, setting up a room in my house for electronics work. I got a copy of the FCC Working Paper on deregulation of Amateur Radio and prayed and tried to get people to read it. I enrolled in the San Francisco Radio Club's class for novices and started to learn radio theory (easy), regulations (rote memorization), and Morse code. I kept going to Packet Radio meetings and eventually ended up on the Steering Committee -- it turned out that since many of the hams there had little computer experience, they'd never been exposed to networking concepts, ideas, or implementations. As a result I was one of the three or four people in the club who could actually UNDERSTAND the protocol being used and the program that implemented it. "They also serve who stand and rag-chew", I guess, but they weren't helping to design the network, which I was. Alas, my Morse Code classes weren't going very well. They were trying to teach at 15-18 words a minute, so we'd eventually be comfortable at 13 words a minute. It was an effort, and I wasn't interested; I was interested in getting past the regulations so I could start to get some real work done. The radio theory was going fine and there was interesting information there, things that I would need to know. But after a month of two-night-a-week classes, I dropped out. We hadn't even been taught all the letters yet! I tried to stir up some sentiment in the Packet Radio Society that we should work towards a code-free license, by passing a resolution and sending it to the FCC, ham magazines, etc. The general feeling was that I should get a license first and then they'd think about it. I tried to find out why people felt so strongly about Morse code. Most of them admitted that they never used it themselves except for I.D.; they all used voice and packet. So what was the fuss? Here were some answers I got. Some were used as arguments, some were told in private by friends, some were figured out by me: * We had to do it, so you will too. No punk kid is going to get away with getting in easy when I had to pay my dues. * If we removed the code test, the airwaves would be flooded with trash. It would be just like CB. We've got to hold on to the spctrum space and not let it get crowded or it won't be any good anymore. * It's not such a big deal, it only took me a week, so what are you so worried about? * That's the way it is and you'll understand after you've been in this field as long as I have. * It's useful in emergencies, you might hear an SOS that nobody else hears and save a life. * You could transmit using nothing but a rusty spoon and a piece of rock when the earthquake happens and your packet radio is smashed. * It can get thru many kinds of interference that voice and computer data just can't penetrate. Some of these need no rebuttal, but others might: * The airwaves belong to "the public". Hams seem to feel that the airwaves belong to hams -- that it's fine for them to carry around a handy-talky and talk to their friends all day on the repeaters, but for the general public to do that would spoil their game. They aren't advancing the state of the art of radio -- why do they get privileged use of the airwaves? * If the communications modes in use now are too crowded, the solution is not to create a privileged class -- the solution is to use new modes, such as packet rather than Morse, which allow more people to share the same channels that are now crowded. * Maybe with the right teacher it IS possible to learn the code in a week. I didn't get that teacher. Mine tried to teach me far more than I wanted to know or needed to know. As a result, I never learned it -- should that be a reason to keep me from advancing the state of the art of radio networking? * Cardio-Pulmonary Resuscitation and first aid are useful in emergencies too, but not knowing them doesn't keep you from getting a ham radio license. The government can encourage emergency preparedness but to mandate it just means that people who would contribute in other ways won't contribute at all. * After the earthquake there will be several thousand voice handy-talkies around, as well as good old CB radios. Civilization is not going to disappear from the Earth without killing all the humans too, so building radios from natural raw materials is not going to be a problem. * Packet radio gear automatically detects garbled transmissions and will retry them without my even noticing most of the time. If packet won't get thru and it's really important, of course, I'll use the telphone. I can always use a program to transmit and receive in Morse when conditions are bad and the phones are down, if I ever need to -- the same way I'd use a program to talk packets (much faster) under normal conditions. Meanwhile, back in the hardware lab, the circuit board I was building was giving me problems. I'd tried to replace the memory section with one that only required 5 volts instead of 5, 12, and -5, and had a power supply that was too small for the board. I had managed to burn out 3 or 4 central processor chips and possibly some of the auxiliary chips while debugging. The board worked once in someone else's system but I never got it to work by itself. Between the lack of support on the code&license question, and the hardware problems, my active interest in packet radio started to dwindle. I kept attending meetings and talking with Hank (KA6M) on the protocol, but eventually sold the circuit board to someone who could debug it, returned the borrowed scope, disassembled the wire-wrapped PROM burner, and went back to working on software. To this day I haven't made an active contribution to the technical art of packet radio -- I've critiqued several designs and offerred suggestions, but I never got the chance to work on the software or hardware to actually implement the designs. That's where the crying need is now. There are plenty of people who know how to build a radio, put up an antenna, organize a ham society. There are only two people in our group (of about 40, still) who have worked on the software, though -- and they aren't likely to get new recruits who aren't already hams. For someone coming from the free-and-easy world of computers, coping with the attitudes of hams and the bureacracy that governs their behaviour is a serious problem. We and the other packet radio groups would like to build a nationwide network of store-and-forward packet radio repeaters. This requires a lot of work -- much of it organizational, some of it in hardware, and a lot in software. That's where I can make my contribution -- except there's a whale in the way. You, the FCC, are that whale. When I gave up, I resolved to just sit back and wait until the ham radio situation straightened itself out (if ever) before attempting again to contribute. The current proposal (for a code-free license) is a step in the right direction. If you implement it, I will get a license (although that alone will probably take six months of paper-shuffling) and get some more hardware and go back to trying to do some good for the packet radio world. If not, I'll sit waiting in the wings until some of the old (and young) reactionary hams die off and maybe there is some acceptance of new ideas. My ultimate fantasy is to see black boxes with an RS232 (serial computer data connector) plug on one end and an antenna on the other. Anyone could walk into their favorite computer store, Radio Shack, or ham store, and buy one, plug it into their home computer, and be interconnected with the other packet radio users in their city (and thru their city's connection to the packet radio backbone network and packet radio amateur satellites, to all other packet radio sites in the world). Right now, due to earlier FCC deregulation efforts, that kind of networking is possible with a 300-baud direct-connect telephone modem -- and thousands of people have bought and used them for exactly that (such as with my Apple Bulletin Board System). Curiously enough, visitors from other countries express the same incomprehension at seeing this that hams express at the idea of people just buying a packet radio and turning it on. The problems with telephone modems are that they are slow and only provide local communication -- nobody can afford to use one for long-distance communication unless they can write it off as a business expense. Imagine what would occur if you could buy an Atari or Apple or IBM home computer with a communications box -- one that didn't cost $20/hr on the telephone, but still put you in touch with the world. I've been using computer networks for close to 10 years and I have some idea of the amount of information that would be available -- that would make peoples lives and jobs easier -- that would provide conversation and company to people who are feeling alienated -- that would provide a forum for people upset or enraged or interested in a public discussion -- that would bring the Information Age into the homes of the people, not for the benefit of a corporation, not with a monopoly deciding what information would get into the network and who would get it out, but for the benefit of all the people helping each other to build their dreams, share their knowledge and their energies and their pleasures, and live their lives a little closer to the way they want them. There are people attempting to build the first hardware toward this vision -- the Tucson Amateur Packet Radio Society. (Their box does not include the radio; you have to add a handy-talky.) There are people, of whom I am one, working on and using networking software that connects over four hundred diverse computers around the world into an anarchistic computerized forum -- controlled by no-one, participated in by all. (All messages are transferred over phone lines, and any long-distance calls are paid for by business and University computer budgets.) This network is called the Usenet and much of its software is in the public domain. I and others from the computer field can adapt this, and other, software, and contribute the knowledge of networking required to make it work. There are people who have been trying to design "WorldNet" for years now -- figuring out the software and administrative requirements for a network that anyone could connect to or disconnect from at will, a network that could handle a million or 100 million users, in their usual state of motion and change, without falling apart. We're professionals who realize the potentials and are afraid that, as in the past, most of the benefits of computer technology will continue to go to businesses and governments, operating to restrain peoples' choices instead of expanding them, giving the public pay-TV, video games, and central control over information distribution, instead of an improved society. But WorldNet is still a fantasy. Some of the problem is economics -- technology is taking care of that. Most of the rest of the problem is governments. Within the U.S., that means the FCC. Even with a code-free license, a license is still required, classes have to be taken, there's an N-month delay while the bureacracy shuffles your papers. To many people, it's just not worth hassling with -- there are so many other interesting things that they could be doing with their computers -- they'll find another interest. One where they can walk in, buy it, and use it, without asking the government. And those places are where the products will be introduced, where the technical advances and the price reductions will be made, where the public will be served. Not in packet radio or WorldNet. Not unless the regulations get as loose as CB, or looser. I realize that it takes time to dismantle a legacy of bureacracy, and I've been encouraged in recent years to believe that is the job the FCC has undertaken to do. The code-free license is an important step on that path, and no matter how much it angers the existing special-interest-group (many Amateur Radio Operators), it will be for the ultimate good of the country and will contribute to the world's progress both in the radio art and in the improvement of the general quality of life. I believe that removing the current Morse code requirement from the Technician Class license is the best way to introduce the code-free license into the existing licensing structure. It significantly reduces the administrative burden on the FCC without significantly altering the requirements of the license or the privileges granted by it, in comparison with the proposed Experimenter Class. It also imposes no new burden on the ARRL volunteer licensing program (except larger volumes of people taking the existing tests, which the ARRL can hardly object to). I furthermore believe that the frequencies and transmission modes authorized for the codeless license should be the same as those of the current Technician's and General licenses (subject to restrictions imposed by international agreements). I believe that, in general, the introduction of new communications methods into the Amateur service will be hastened by as few restrictions and regulations as possible; a competent Technician should not be required to upgrade her or his license to use a frequency band or a transmission mode which was previously unused for similar methods. In other words, as many possiblilties should be legalized at once as is possible, to avoid later having to spend time removing restrictions, and to avoid discouraging good new ideas because a long-drawn regulatory process is required to experiment with them. I realize that some areas must be reserved for Advanced and Extra classes as an incentive measure, but this should not be applied such that the set of available frequencies for experimental Technican and General use is too small. In particular, almost all current Packet Radio work is going on in the 2-meter bands, because equipment is cheap and plentiful. If the 2-meter band was not available, packet development work would have to move to 220 or 440MHz where equipment is costlier. This would also split the existing packet radio groups between old-timers who could continue to use 2 meters, and newcomers who'd be forced into other bands. I note that the ARRL's editorial against this proposal (March 1983 QST, page 9) never once mentions an argument against the proposal; it simply states that most amateurs oppose it, and rages against the FCC's refusal to obey the ARRL in this important matter. Personally, I'm on your side. I have enclosed a few comments that were exchanged on the Usenet (the computer network mentioned above) on the subject of code-free licenses. I have also put these comments into the Usenet, and encouraged others to send their own. A few sentences will clear up some terminology problems: Phrases like "decwrl!decvax!harpo!floyd!peri!sbcs!rick" identify the path that the message has taken thru the network, from Rick on machine "sbcs" (SUNY Stony Brook computer science dept.), thru machine "peri", to "floyd", and so on to "decwrl" (Digital Equipment Corp's Western Research Lab). A "flame" is a heated reply; e.g. a response made while annoyed, rather than after deliberation. The enclosed are only a few of the comments that were made on the topic; I started to save them but quickly realized that there were far too many messages to save, so these are only the first few. The last message was sent by me in response to a general "Hey, has anybody used packet radio out there?" query. Respectfully submitted 7 March 1983 John C. Gilmore Sun Microsystems, Inc. 2550 Garcia Ave. Mt. View, CA 95051 (415) 960-1300 x309 CC: Usenet newsgroup net.ham-radio Hank Magnuski, KA6M Curtis Spangler, N6ECT Vic Clark, W4KFC Paul Rinaldo, W4RI