Codec2 Project Asks FCC To Modernize Regulations

Bruce Perens writes "The Codec2 project has developed FreeDV, a program to encode digital voice on two-way radio in only 1.125 KHz of bandwidth. But FCC regulations aren't up-to-speed with the challenges of software-defined radio and Open Source. A 24 page FCC filing created by Bruce Perens proposes that FCC allow all digital modulations and published digital codes on ham radio and switch to bandwidth-based regulation."

Comments

Be careful...

[fuzzyfuzzyfungus]

"Dear economically invisible 'ham radio' users;

  After an exhaustive modernization study underwritten in part by our good friends at Verizon, we have concluded that the future of digital voice should really cost ~$100/month and rely entirely on proprietary hardware and firmware. To this end, we will be lowballing every last scrap of spectrum we can to the nation's incumbent telcos as soon as possible.

XOXOXO,

The FCC"

I applaud modernization efforts, there is no reason why 'ham radio' should be forced to stick to ancient technology for reasons of sheer regulatory inertia when it could be fertile ground for experimentation; but I worry that (given the, um, limited war chests of ham nerds vs. other spectrum users) that perfectly sensible re-examinations of legacy rules might well end up becoming an exercise in malignant entities with better lobbyists using the rexamination of legacy rules to appropriate spectrum that was protected at the cost of a certain amount of anachronism...

Re:good luck with that

[vlm]

At the moment, US rules have separate sub-bands for voice, data and image transmissions.

Note that the FCC currently regulates by information content, not modulation. I guess a /. analogy is its like classifying networking tech first by layer 2/3 at the bottom as the "fundamental layer", then layer 1, then the upper layers, sorta. Which is obviously wrong. So if I send you a string of ones and zeros in PSK-31 modulation or whatever, that represents speech, we have to go in one subband on HF. Then if I send you ones and zeros representing text data, like this post, we have to QSY to yet another subband. Then if I send you ones and zeros representing a goatse jpeg picture (which would run afoul of the fcc reg against obscenity, but I digress), we have to QSY to yet another frequency... even if its all the same modulation technology, the same "stuff on the airwaves" for the ones and zeros. Maybe another way to put it, is our "MIME-type" is our frequency subband, not something a little more modern or realistic.

Legally/technically if I went on CW (aka morse code) and told you verbally how to draw an amplifier schematic that could be seen as illegal as its obviously image traffic, no worse than if I sent you postscript code or the ones and zeros of a .png file.

There are two killer problems which may or may not be discussed here.

First the proposal claims to promote "paperwork reduction" while installing a whole new crazy array of complicated regs ON TOP OF the existing overall rules for reasonable and prudent and good engineering practice and emergency traffic priority or WTF the exact phrases. In my opinion as a third generation ham with over three decades of experience, what works with the smart people on the VHF/UHF/microwave bands should work with the glorified CBers on the HF bands, which in summary is do whatever the heck you want as long as its good engineering practice and stays within ham band edges (note this is a simplification, but basically correct). Yes I know this is the peak of this solar cycle but when 10M is closed and dead I see no reason my buddy and I shoudn't be able to use 200 KHz of wideband FM on 10M across the city if we please, because it certainly can't hurt anyone. Or do something weird on 160M during the day time in summer, why not? So the most rational bandplan is not this proposal, but is: Do whatever the F you want between 3.5 MHz and 4 MHz as long as it stays in band edges and follows all the other numerous "content and performance based" regulations (like no intentional interference, good engineering standards, content rules wrt obscenity (which is certainly ignored on 80 and to some extent on 20 aka the high tech redneck CB bands, so why can't we accept that we'll ignore bandwidth limits too?), emergency traffic gets priority, blah blah blah)

The other thing carefully not discussed, regardless if true or not, the widely held belief was Bonnie's plan from a decade ago, mentioned in this very proposal, was just the thin edge of the wedge to fill 20M from band edge to band edge with psuedo-commercial winlink traffic. There's two problems with this. The first is it doesn't seem to modify the unattended operation rules but then again its the thin edge, the next proposal will be expanding the unattended operation subbands to 3.5 to 4 MHz for example, etc. The second is, see #1 above, why should anyone care if the vast majority of hams wanted to use winlink, if so, then let them... its not the "SSB-preservation amateur radio service" or the "AM amateur radio service" or for that matter the "CW amateur radio service".

Well, this mostly accurate history lesson outta stir the pot some.