[net.ham-radio] My comments to the FCC on the No Code NPRM -- did you submit yours yet?

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