[44net] FW: hardware vs. software

Jeez, the mail list eliminated the indents. Here's another version with manually added ">" and "[N6MEF]" From: Michael E. Fox - N6MEF [mailto:n6mef@mefox.org] Sent: Tuesday, July 09, 2013 4:59 PM To: 'AMPRNet working group' Subject: RE: [44net] hardware vs. software Lynwood, [N6MEF] Good discussion. Thanks for challenging this. I really hope I'm wrong. I'd hate to unnecessarily limit what we can do. But I think you've made a few misinterpretations. To wit: 97 regarding data emissions; in addition, I wasn't >clear that you were referencing BBS software instead of standard email or webmail. [N6MEF] Right, but believe it or not, 1200 baud AFSK packet is not "data". See the definitions section, 97.3(b)(2), where "data" is defined as ". emissions having designators with A, C, D, F, G, H, J or R as the first symbol; 1 as the second symbol; D as the third symbol; and emission J2D. Only a digital code of the type specifically authorized in this part may be transmitted." [N6MEF] Unless I'm mistaken, 1200 baud AFSK is emission designator F2D. ("F" for FM, "2" for AFSK, "D" for Data, telemetry, telecommand). That's not listed in the definition for "data." And, the definition for data is specifically exclusive . i.e. "only these things and nothing else". [N6MEF] So, back to 97.109(c): "No station may be automatically controlled while transmitting third party communications, except a station transmitting a RTTY or data emission." And, as clarified above, 1200 baud AFSK packet is not a "data" emission as defined in part 97. [N6MEF] Continuing with 97.109(c): "All messages that are retransmitted must originate at a station that is being locally or remotely controlled." If I log into my BBS, I'm locally controlling that communication. This is how WL2K works. But if BBS B is the email gateway and is retransmitting to BBS A automatically, then BBS B is certainly not being locally or remotely controlled at the time. [N6MEF] There's also this: 97.115(b): The third party may participate in stating the message where: 97.115(b)(1): The control operator is present at the control point is continuously monitoring and supervising the third party's participation; and ." [N6MEF] Certainly, there is no control operator present to monitor and supervise the 3rd party as they create the email that causes the automatic transmission over amateur frequencies. [N6MEF] Another killer is: 97.219(d) "For stations participating in a message forwarding system, the control operator of the first forwarding station must: ." 97.219(d)(1) "Authenticate the identity of the station from which it accepts communications on behalf of the system; or ." 97.291(d)(2) "Accept accountability for any violation of the rules in this part contained in messages it retransmits to the system." [N6MEF] The way I read that is that whoever is the trustee for the gateway must make sure that incoming messages which will be forwarded between BBSs over amateur frequencies are not violating any of the other rules, like which countries and which individuals we can exchange 3rd party communications with, message content, etc. And that's virtually impossible to do in any practical way. But if the gateway is the same machine that I log into, then as I log in, that communication is under my control and I'm responsible. Again, that's how WL2K works. [N6MEF] I believe you're incorrect, see above. But continuing . only be reached via an Amateur RF link (e.g. a POP3 >or IMAP server [email-for-pickup] located in an Amateur SATERN communications mobile). In this case, you're providing email >service to non-amateurs over RF, which is not allowed anyway. [N6MEF] Yes, that would be an obvious violation - a non-ham directly using a ham frequency. is a non-amateur sending the email, care must be made >that the first leg is not via Part 97 RF (e.g. a local LAN at an EOC connected to AMPR). [N6MEF] I think I've shown above that it is NOT allowed, even if the first leg is not part 97 RF. But if I'm mistaken, please show me where. sending that message automatically to BBS A via >Amateur RF is allowed per 97.115(c). [N6MEF] Um, 97.115(c) relates to stations sending an ID. I think you mean 97.109(c) which I've already covered above. must be at some gateway between the commodity >Internet and AMPR, as the non-amateur should not have direct access to AMPR anyway. [N6MEF] Yes, of course. But I think I've show above that automatic forwarding (at least using AFSK) is specifically NOT allowed. non-amateur; that is not entirely the case, it somewhat >implies that if one end of the communication is Part 97, it can link to Part 15 equipment; such would not be the case, unless it's >first converted the data path to non-RF for the final leg (e.g. wired Ethernet). [N6MEF] No such implication was intended. I'm aware that many off-the-shelf products are modified to work on amateur frequencies. But, once modified, they are no longer "off-the-shelf" and would, of course, be governed by part 97. [N6MEF] Final note: I would love it if someone can show me where I'm wrong. Really! Michael N6MEF