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TCP-group 1994

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Re: 2.4 GHz and its future

If the band were going to be used for PCS, it wouldn't be so bad.
However, one of the major contenders are land-line telephone companies,
who want to replace copper local loops with radio. I'm certain they
won't want to share with us. They'll come back to FCC and Congress
and demand that no receivers that include that band be type-approved
any longer, because they don't want to spend the money to encrypt all
of those local loops. After all, if they wanted to do that, they'd
use copper.

	Bruce Perens

Since you brought up the subject, here's the comment I submitted for NCPA.

                                Before the
                           Washington, DC 20554

In the Matter of                   )
Allocation of Spectrum Below       )     ET Docket No. 94-32
5 GHz Transferred from             )
Federal Government Use             )


Submitted by:   Bruce Perens
                Northern California Packet Association
                c/o Pixar
                1001 W. Cutting Blvd. Suite 200
                Richmond, CA 94804
                Internet: Bruce@Pixar.com

Date of Submission: December 19, 1994

                              I. INTRODUCTION

1. Northern California Packet Association represents Radio Amateur packet
   radio operators in the Northern California area.

2. This response to FCC 94-272 (docket 94-32) contests assumptions made
   by Department of Commerce and FCC regarding the prospective impact upon
   the Amateur Radio Service of the reallocation of the 2390-2400 and
   2402-2417 MHz bands from Government to the private sector.

3. In addition, we present regulatory impediments that to date have
   hindered utilization of the 2390-2417 MHz frequency band by Radio
   Amateurs for experimentation in digital computer networking
   technology. Utilization of this band by radio amateurs for digital
   networking would have been much greater but for these regulatory
   impediments. Thus, we submit that current assumptions of low use
   of this band by Radio Amateurs are more a gauge of the effectiveness
   of over-government in depressing spectrum use than they are
   estimates of the potential for spectrum use by Radio Amateurs.

4. We propose changes that could be made to permit Radio
   Amateurs to be more effective contributors to the continued growth
   and development of advanced communications and technologies and in
   education, thus creating new high technology jobs and economic growth.

5. We consider the prospective favorable economic impact of a higher
   priority for Education as a frequency user, and the mission that
   Amateur Radio could perform in education.

6. We point out an area of the spectrum where unused frequencies are

7. We comment on the need for Amateurs to have primary allocation or
   equal status with other services in the bands that they are allocated,
   and point out current problems that have locked Amateurs and Part-15
   users out of 902-928 MHz in some urban areas.

                           II. BACKGROUND

1. FCC proposes to re-allocate two band segments: 2390-2400 MHz
   and 2402-2417 MHz.

2. Currently, 2390-2400 MHz is allocated on a primary basis
   to Government use, and on a secondary basis to Radio Amateurs. FCC
   proposes to transfer primary allocation of 2390-2400 MHz to private
   sector uses. This transfer may remove the secondary allocation to the
   Amateur Service, may reduce access to the band to Amateur operations
   because of the need to protect a new primary user from interference,
   or may make the allocation to the Amateur Service less useful due to
   an increase in harmful interference that must be tolerated by Amateurs.
3. The real primary users of 2400-2450 MHz are millions of microwave ovens
   that are permitted to operate in the 2400-2500 MHz Industrial,
   Scientific, and Medical (ISM) band. On paper, the 2400-2450 MHz band
   is allocated on a primary basis to government, and on a secondary
   basis to Radio Amateurs. However, both Government and Amateurs must
   accept harmful interference from ISM devices. The leakage limits on
   home microwave ovens prevent physical injury from their emissions,
   but these limits allow more than enough emissions to make the ovens
   powerful jammers of communications.

4. 2400-2483.5 MHz is also authorized for use by Part-15 (license free)
   devices. While these devices are required to protect Radio Amateurs
   from harmful interference, the reality is that protection of Radio
   Amateurs from Part-15 devices is rarely enforced. Commercial forces
   rather than the policy of FCC prevent this enforcement: if an Amateur
   and a Part-15 commercial installation are in conflict at a site such
   as a shared antenna tower or an urban building, the site's landlord
   will generally evict the Amateur rather than lose the business of the
   Part-15 commercial user. FCC's depleted enforcement budget also
   contributes to a lack of protection of Amateurs from Part-15 devices.

5. FCC proposes to transfer primary allocation of 2402-2417 MHz from
   government to private sector uses. This transfer may remove the
   secondary allocation to the Amateur Service, may reduce availability
   of the band to Amateur operations because of the need to protect a
   new primary user from interference, or may make the allocation to the
   Amateur Service less useful due to an increase in harmful interference
   that must be tolerated by Amateurs.

                           III. DISCUSSION

1. The conflicting authorizations in the 2400-2450 MHz band make it
   impractical for use by Radio Amateurs in digital networking over
   land paths of 5-50 miles where interfering devices may be in the path
   between two stations. 2400-2450 is still useful for space-to-ground
   communications, because highly directional antennas can be used to
   eliminate interference from ground-based devices. 2400-2450 is also
   still useful for very-short-range communications such as building-wide
   networks of Part-15 or Amateur devices, where interference can be
   surmounted by increased signal strength.
2. The conflicting authorizations in 2400-2450 MHz make 2390-2400 MHz
   the only practical band-segment for networking over land paths of
   5-50 miles. Thus, FCC and Department of Commerce should consider
   that the availability of the 2390-2400 MHz band in its presently
   "quieter" state has a significantly greater impact for Radio Amateurs
   than the availability of an equal-sized sub-band of 2402-2450 MHz.

3. FCC and Department of Commerce erred when they assumed that the
   remaining band segments of 2400-2402 and 2417-2450 MHz would be
   sufficient for Amateur use. Their error was that they did not take
   into account that the conflicting authorizations in these band segments
   make them impractical for communications over land paths of 5-50 miles
   because of the potential for interfering devices to lie in the path
   between two stations. The assumption might have been correct if the
   only Amateur uses for this band were space-to-ground and
   very-short-range communications.

4. FCC and Department of Commerce have requested information on present
   and predicted occupancy of 2300-2310 MHz, 2390-2400 MHz, and
   2402-2417 MHz by Radio Amateurs. The primary use we see for these band
   segments is digital computer networking. We observe that current
   regulation (certain elements of Part 97) has a depressing effect on
   the use of digital computer networking by Radio Amateurs.
   Relief from this regulation would result in greatly increased
   utilization of digital networking, and thus of the band segments
   under discussion, by Radio Amateurs. Thus, we question the
   utility of surveys of present and future occupancy that do not take
   into account the potential of increased utilization of the Amateur
   Service due to changes in regulation.

5. To support our argument, we shall go over elements of Part 97 that
   we propose could be changed to encourage use of digital computer
   networking by Radio Amateurs, and would thus remove factors that
   currently depress utilization of the 2390-2450 MHz band. We propose
   that increased involvement of Radio Amateurs in digital computer
   networking would have a positive impact on the United States economy
   because it would encourage development of new software and algorithms
   for computer networking, and would facilitate education in all
   technologies that are used in implementing and operating computer
   networks. We understand that the Commission may see this material as
   outside the scope of the NPRM, and may prefer for these proposals to
   be presented in a different form before they are considered. If that
   is the case, we request that they be considered at present only for
   their prospective impact on the increase of Radio Amateur
   utilization the 2300-2450 MHz frequency spectrum.
5a. 97.111(5) prohibits Radio Amateurs from carrying out "Communications,
    on a regular basis, which could reasonably be furnished alternatively
    through other radio services". We submit that this restriction is so
    broad that it could be interpreted as a ban upon an Amateur Radio
    digital communications network in the presence of other wireless
    networks, even networks of Part-15 devices. We surmise that this
    restriction may have been designed to protect a regulated monopoly
    that no longer exists.

5b. 97.111(6) prohibits broadcasting in general, and allows broadcasting
    of information that is of interest only to Radio Amateurs. We
    observe that a major mode of discussion on digital computer
    networks such as the Internet is called "Usenet", "Net-News" or the
    computer "bulletin board". Net-News and bulletin board discussions
    take the form of a broadcast message posted by one of the
    participants, after which other participants respond to the message
    by posting broadcast messages that continue the thread of argument
    on the same topic. While the messages are broadcast, they implement
    a round-table discussion. We submit that in the case of digital
    computer networks, broadcasting or not broadcasting is a technical
    communications protocol choice and does not have the same meaning
    that it has for broadcast voice communications. We request that FCC
    allow any subject that could be legally discussed without
    broadcasting to be discussed via a broadcast communications
    protocol on an Amateur Radio digital computer network.

5c. We ask FCC to recognize that a primary role of stations in a digital
    computer network is to move third-party information automatically.
    Much of the restriction that currently hampers the deployment of
    Amateur Radio digital computer networks is related to third-party
    messages and automatic operation while such messages are carried.

5d. 97.115(2) prohibits carriage of messages for a third party in another
    country unless that country has signed a third-party treaty with the
    United States. We request that FCC treat automatic digital message
    forwarding between UHF-band Amateur stations within the borders of
    the United States as domestic communications. We observe that
    third-party communications from nations with which no third-party
    treaty exists can enter the United States via another
    communications service than Amateur Radio, such as the Internet. We
    observe that there is no such third-party limitation on domestic
    services such as Cellular Radio Telephone, and that the Internet
    (the international network in which the National Information
    Infrastructure is our domestic component) has no prohibition upon
    communications between nations enforced upon it at all. We surmise
    that these third-party regulations were drafted to regulate
    short-wave communications of international range, not UHF domestic
    communications between two computers in a network, and that they
    were drafted in a vastly different technological and political
    climate than today. We understand  that international treaties that
    are difficult to change are involved, and thus request that FCC
    work out a means of permitting these third-party communications to
    be transmitted between domestic amateur stations in a UHF digital
    network once the messages have already entered the United States.
    We currently find it very difficult, in the context of border-free
    international networks such as the Internet, to operate the
    domestic Amateur Radio computer network as if certain nations did
    not exist.

5e. 97.109(e) requires the AX.25 protocol for automatic control of
    a station while transmitting third-party communications. This
    requirement has the unfortunate effect of prohibiting Radio
    Amateurs from converting surplus commercial radio data transceivers
    for use in an automatic-forwarding network, since such equipment
    is based on microcontroller firmware that rarely implements the
    AX.25 protocol. In theory, the firmware program of the equipment
    could be re-written to use AX.25. In practice, this is almost never
    possible due to the in-availability of the source code for modification
    by Radio Amateurs, or the storage of the firmware in such a way that
    it can not be modified without destroying the equipment. We observe
    that the AX.25 standard specified was designed in the early eighties,
    and the last version was released in 1984. It is now quite antique by
    the standards of computer software. We understand that this regulation
    was to make it possible for FCC to monitor Amateur Radio digital
    communications at a time when FCC owned little equipment for doing so.
    We urge the FCC to provide for the use of generally accepted computer
    networking protocols. For example, the protocols released by the
    Internet Engineering Task Force (the engineers of the National
    Information Infrastructure) should be allowed for use in automatic
    forwarding via Amateur Radio. Other protocols should be allowed as
    well. We suggest that FCC require only that the protocol provide for
    unambiguous identification of the communicating stations and the
    communications protocol, and that the details of any protocol be
    filed with FCC before that protocol may be used for automatic
    third-party forwarding.

5f. 97.311 restricts the modulation method of a station transmitting
    spread-spectrum emissions to a very few simple forms.
    This requirement has the unfortunate effect of prohibiting Radio
    Amateurs from converting surplus commercial spread spectrum radio
    modems for use on Amateur Radio, since it is very unlikely that those
    modems could be programmed to use one of the few spreading protocols
    that FCC allows Radio Amateurs. It also has the effect of banning
    experimental research on new spread-spectrum techniques by Radio
    Amateurs, who could potentially contribute much new art in this area.
    We understand that this regulation was to make it possible for FCC
    and other government agencies to monitor spread-spectrum
    communications at a time when they owned little equipment for doing
    so. We surmise that this regulation could also have been influenced
    by cold-war national security considerations that may no longer
    apply. Many of us have purchased surplus Part-15 spread-spectrum
    radio modems that we would convert to Amateur use if we were
    permitted to use the spreading schemes of those modems on the
    Amateur bands.  We suggest that FCC require only that the details
    of the protocol be filed with FCC before that protocol may be used,
    and that a station keep accurate logs of the spreading protocols
    used and the dates upon which use of those protocols was initiated
    and terminated.

5g. 97.1(b) states one of the purposes of the Amateur Radio Service
    is "Continuation and extension of the amateur's proven ability
    to contribute to the advancement of the radio art." Since much
    of what the Radio Amateur has to contribute today is Computer
    Science (in the form of software and algorithms for digital
    computer networking), we ask that FCC make it easier for us
    to justify the mission of Amateur Radio digital computer networks
    by substituting the more general word "technology" for "radio art"
    in 97.1(b).

5h. 97.1(d) states one of the purposes of the Amateur Radio Service is
    "Expansion of the existing reservoir within the amateur community
    of trained operators, technicians, and electronics experts." So that
    we can more easily justify the mission of Amateur Radio digital 
    computer networks, we ask that the more general language "experts
    in science and technology" could be substituted for "technicians
    and electronics experts" in 97.1(d). Again, this more general
    language would include the field of Computer Science.

5i. We request an explicit statement in 97.1 of Amateur Radio's mission
    in education, and its mission to encourage young people to explore
    careers in science and technology. We submit that this is one of
    the primary missions of Amateur Radio digital computer networking
    as well as Amateur Radio as a whole, and a mission of tremendous
    economic value to the United States.

6.  If the changes in 5a through 5i (above) were enacted, we would
    see an increase in the use of Amateur Radio for digital computer
    networking, a corresponding increase in experimentation and
    software development for digital computer networking by Radio
    Amateurs, and an increase in the utilization of amateur UHF spectrum
    for digital computer networking. Since software development is one
    of the technologies where individuals working in their spare time
    without the backing of large laboratories can still make a large
    contribution, this would result in increased growth and development
    of advanced digital computer networking technology, thereby creating
    new high technology jobs and economic growth. We'd also like to point
    out that increased involvement by Radio Amateurs in digital computer
    networking would lead to increased educational opportunities for
    young people in these technologies.

7.  The reason proposed for the transfer of this spectrum from
    Government to the private sector is economic benefit.
    We observe that the NPRM makes little mention of the potential for
    Education to be allocated a higher priority as a spectrum user. We
    suggest that a higher priority for Education would result in a
    larger, longer-term and more sustained economic benefit than the
    short-term benefit of funds from a frequency auction and employment
    of the frequencies for such cost-shaving optimizations as the
    replacement of copper local loops for "land-line" telephone companies.
    If the United States is to maintain its economic competitiveness, it
    needs to encourage more students to go into careers in science and
    technology. We suggest that the Amateur Radio service is an ideal
    vehicle for employment of this spectrum in education. There is
    considerable evidence for the role of Amateur Radio in a student's
    choice to make a career as a scientist or engineer. In addition,
    the accessibility of Amateur Radio to students should be considered:
    In any networking environment except for the Amateur service,
    equipment such as a network gateway would be kept locked away in
    a computer room and tended only by professional computer system
    administrators. In an Amateur Radio network, anyone can operate
    a network gateway that is available to a large user community,
    and thus anyone can learn about one. The same goes for networking
    hardware - only in the amateur service is a student not limited
    to extremely low power or pre-built type-approved equipment.
    An Amateur Radio network is also more permissive of applications
    that could be too expensive for a student to carry out on a
    commercial network, or could be disallowed by a commercial network

8.  If FCC and Department of Commerce are still looking for spectrum,
    we suggest they consider the extremely low utilization of the UHF
    television channels. Part of the reason for this low utilization is
    that the mission of these channels has been usurped by cable and by
    direct satellite broadcasting. Another reason is that until
    recently, poor implementation of receiver tuners prohibited the
    allocation of stations in an urban area with less than five channels
    of separation from each other. Rather than a broad transfer in
    allocation, we suggest that other services than television be granted
    access to currently-unallocated UHF television channels on a
    region-by-region basis.
9.  A secondary allocation for the Amateur service is sometimes little
    better than no allocation at all. As an example of this, we offer a
    current unfortunate situation of Amateurs being overly restricted
    by the primary user in another band. Amateurs and users of Part-15
    equipment are being locked out of the 902-928 band in urban areas
    by the primary user, the Automatic Vehicle Monitoring service. We
    observe that the technology of differential global positioning
    system receivers and the cellular telephone network has obsoleted
    the technology used by AVM. However, AVM operators persist in
    restricting Amateur operations to two 1 MHz sub-bands at the
    band-edge or even no operation at all. AVM operators severely
    restrict or attempt to make a total prohibition on operation of
    Part-15 devices within their shared spectrum. Education was to be
    a large user of Part-15 and Amateur devices in the 902-928 band,
    but is being restricted from these uses in the urban areas where
    they are most needed. We do not wish to see this same situation
    take place in the 2300-2450 MHz bands. We plead with FCC to look to
    the needs of Educational users in the 902-928 and 2300-2450 MHz
                                 * * *

<a href="http://www.rahul.net/perens>Bruce Perens AB6YM</a>
Voice phone: 510-215-3502  Internet: Bruce@Pixar.com
Amateur Radio TCP/IP: Bruce@ab6ym.ampr.org
Amateur Radio BBS network: ab6ym@n0ary.#nocal.ca.usa.noam

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