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Re: FCC elevates hams to primary status, 2400-2402 MHz



I heard about the NPRM when a former colleague forwarded me a note
from Dave Farber's "Interesting People" mailing list. It came from
someone on the other side of the fence from us, a leading proponent
of expanded Part 15.247 (e.g., 802.11) usage.

http://www.interesting-people.org/archives/interesting-people/200205/msg00056.html

To say he was upset would be an understatement. I think he also went off
a little half-cocked. Here are responses by myself and Louie Mamakos, WA3YMH:

http://www.interesting-people.org/archives/interesting-people/200205/msg00064.html
http://www.interesting-people.org/archives/interesting-people/200205/msg00057.html

Also of interest is the flurry of private email I got in response to
my posting. Two gave me permission to forward it. I think they
exemplify how ham radio is now seen by many, if not most technically
oriented people outside ham radio. To say that we have an image
problem is putting it mildly. Keep in mind I'm just the messenger
here.

My first exchange is with David Reed. BTW, Reed is a co-author of the
classic paper "End-to-End Arguments in System Design", one of the
earliest (and in my opinion most influential) statements of the
Internet's design philosophy.

Date: Fri, 10 May 2002 15:06:03 -0400
To: karn@ka9q.net, dave@oldcolo.com, dewayne@warpspeed.com
From: "David P. Reed" <dpreed@reed.com>
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz 

Phil -

At 01:50 PM 5/10/2002 -0400, Dave Farber wrote:
>Subject: FCC Proposes Primary Status for Amateur Service at 2.4 GHz
>Reply-To: karn@ka9q.net
>Message-Id: <E176DnI-0001pw-00@maggie.ka9q.net>
>From: Phil Karn <karn@maggie.ka9q.net>
>Date: Fri, 10 May 2002 10:03:00 -0700
>
>However, the 2400-2402 segment is very important to the amateur
>service as amateur radio satellites are already using it.  Users of
>those amateur satellites are already encountering significant harmful
>interference from Part 15 devices.

This could use a little clarification, Phil.

Amateur satellites are using it already, but they are not primary?   A 
sensible view of such things is "let them live with their choice" - 
otherwise, they are merely trying to use "squatters rights" arguments to 
extend their domain after the fact.

The use of "harmful" in this sentence probably indicates your political 
bias.   The Amateur Radio Service's lobbying organization (ARRL) is acting 
high-handed lately in attacking UWB, 802.11, etc.   It might want to start 
getting ready to justify its "control" over a lot of valuable spectrum real 
estate.

One could point out that the economic role of Amateur Radio is a miniscule 
fraction of 802.11, and has been going down rapidly, while the economic 
role of high tech wireless communications has been accelerating.

It's probably time to rethink the entire basis of Amateur Radio's argument 
for spectrum, just as it's time to do so for most of the other ancient 
"legacy" services.

There are a small number of hams (you are, in my mind, one of the best 
examples) who represent the best of what the ARS does.   But the whole 
service looks like a privileged playground for a group that sucks up to 
Congress and fights innovative progress on all fronts.

To: dpreed@reed.com
CC: dave@oldcolo.com, dewayne@warpspeed.com
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz
From: Phil Karn <karn@maggie.ka9q.net>
Date: Fri, 10 May 2002 14:45:15 -0700

>This could use a little clarification, Phil.

Certainly.

>Amateur satellites are using it already, but they are not primary?   A 
>sensible view of such things is "let them live with their choice" - 
>otherwise, they are merely trying to use "squatters rights" arguments to 
>extend their domain after the fact.

The amateur service is currently primary at 2402-2417 MHz.  It is
currently secondary at 2400-2402 MHz. According to the FCC, no service
currently has a primary allocation in that range.

Since WiFi channel 1 extends from 2401-2423 MHz between nulls, it is
not possible for it to operate in the current 2400-2402 MHz secondary
amateur allocation without also operating on the 2402-2417 MHz primary
amateur allocation that already exists.

But even the amateur service's secondary allocation is still enough to
trump Part 15.247 (i.e., WiFi). So for two different reasons, this
proposed rulemaking would have *no* effect on WiFi's status relative
to the amateur service.

>The use of "harmful" in this sentence probably indicates your
>political bias.

Actually, no. I was using the formal FCC definition of "harmful
interference" as follows:

  Harmful interference. Interference which endangers the functioning
  of a radionavigation service or of other safety services or
  seriously degrades, obstructs or repeatedly interrupts a
  radiocommunication service operating in accordance with the Radio
  Regulations.

This is from 47CFR97.3(a)(23), the rules for the amateur service.  The
same text is found elsewhere in the rules for other services.

Note that the interference has to "seriously degrade, obstruct or
repeatedly interrupt" a radiocommunication service.  The mere fact
that a ham can hear or detect a neighbor's WiFi network doesn't
constitute "harmful interference" unless the foregoing is also true.

>One could point out that the economic role of Amateur Radio is a miniscule 
>fraction of 802.11, and has been going down rapidly, while the economic 
>role of high tech wireless communications has been accelerating.

>It's probably time to rethink the entire basis of Amateur Radio's argument 
>for spectrum, just as it's time to do so for most of the other ancient 
>"legacy" services.

>There are a small number of hams (you are, in my mind, one of the best 
>examples) who represent the best of what the ARS does.   But the whole 
>service looks like a privileged playground for a group that sucks up to 
>Congress and fights innovative progress on all fronts.

I will not deny any of this. In fact, I've been making the very same
arguments to fellow hams for many years, stressing that the only real
role left for ham radio is as an educational vehicle.

However, I'll say here what I've already told my ham satellite
friends: I don't see a need to fight a war here. Many hams, including
myself, are also major WiFi users. We can find ways to coexist,
especially since there is already a WiFi channel (11) that is
completely out of the ham band.

Do you mind if I forward your message to some of my ham friends?

Phil

Date: Fri, 10 May 2002 20:29:09 -0400
To: karn@ka9q.net
From: "David P. Reed" <dpreed@reed.com>
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz
Cc: dave@oldcolo.com, dewayne@warpspeed.com

Thank you.  This is very helpful.

Feel free to pass on my message to your ham friends.  I think hams could 
contribute greatly to demonstrating how new technology and approaches can 
allow much more efficient and cooperative sharing.   To my mind, that would 
be best done by lobbying the FCC to restructure the ham bands as a commons 
for innovation in scalable radio networking, using state of the art 
technology and protocol designs, software radios and experimental 
modulation, antennas, and power management.   Like the Internet, these new 
commons bands should not have a bar against commercial participation, as 
long as the commercial participants are barred from forming exclusive 
networks - i.e. they must interconnect and cooperate in use of spectrum.

The hams should be leaders in demonstrating new large-scale services, just 
as Tim Berners-Lee did with WWW, and the GNU group did with open source 
programming tools.

That would be in the true spirit of the first radio amateurs.

To: dpreed@reed.com
CC: dave@oldcolo.com, dewayne@warpspeed.com
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz
From: Phil Karn <karn@maggie.ka9q.net>
Date: Fri, 10 May 2002 18:17:14 -0700

>Feel free to pass on my message to your ham friends.  I think hams could 
>contribute greatly to demonstrating how new technology and approaches can 
>allow much more efficient and cooperative sharing.

Thanks. And I fully agree with everything you said. But I have to say
that I encounter a lot of resistance from what we call "old farts".
You wouldn't believe the hostile reaction I got about 6 years ago when
I gave a basic tutorial on spread spectrum to a ham radio convention,
explaining how it worked, why it was an important technology, and why
we hams should experiment with it. All that went right over their
heads.

All the audience could think of was how "all this broadband noise"
would wreck their cozy little weak signal segments. And special
opprobrium was directed at the execrable concept of using ham radio as
links within the Internet. How *dare* ham radio be prostituted in such
a way!

Paul Rinaldo of ARRL summed up the popular (ham) perception of spread
spectrum thusly: "You can't hear it, and it interferes with
everybody". Kind of a strange pair of statements to hold
simultaneously, huh?

There is even active (but fortunately not universal) opposition to the
idea of university satellite projects operating on the amateur
satellite bands, as if they aren't one of the most productive
educational applications of the ham spectrum that I can think of.

It's a steep uphill climb, and I'm often tempted to give up in defeat.
But ham radio started me on my career path, and I guess I'm too
sentimental about it to not try to save it for another generation to
benefit from it as I have.

Phil

[end of dpreed exchange]

Here's another exchange:

Date: Fri, 10 May 2002 14:58:22 -0600
To: karn@ka9q.net
From: Brett Glass <brett@lariat.org>
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz 

At 11:50 AM 5/10/2002, Phil Karn wrote:

>However, the 2400-2402 segment is very important to the amateur
>service as amateur radio satellites are already using it.  Users of
>those amateur satellites are already encountering significant harmful
>interference from Part 15 devices.
>
>You'll also find that the amateur allocation extends up to only 2450
>MHz, while Part 15.247 devices can operate all the way up to 2483.5
>MHz.  That leaves 802.11 channel 11, 2451-2463 MHz between first
>nulls, completely outside the amateur band.

And leaves no room if someone is already using that channel. This
means that either there can be no choice of wireless ISPs within
an area or that service will be badly degraded by interference.

Sorry, Phil, but the narrow interests of amateur radio hobbyists should
not trump those of the general public. It's already scandalous that
they have been empowered to drown out, or remove, existing wireless
broadband operators, costing families and small businesses their
Internet access. Hams have been far too greedy about spectrum, and (IMHO) 
should be removed from all Part 15 bands.

--Brett

To: brett@lariat.org
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz
From: Phil Karn <karn@maggie.ka9q.net>
Date: Fri, 10 May 2002 16:29:27 -0700

>Sorry, Phil, but the narrow interests of amateur radio hobbyists should
>not trump those of the general public.

I'm simply explaining the rules as they presently are, not how they
should be.

Do you mind if I forward your message to my ham friends? It would help
underscore a message I've been trying to make for a long time.

Phil

Date: Fri, 10 May 2002 19:12:49 -0600
To: karn@ka9q.net
From: Brett Glass <brett@lariat.org>
Subject: Re: IP: more on FCC Proposes Primary Status for Amateur
  Service at 2.4 GHz

At 05:29 PM 5/10/2002, Phil Karn wrote:

>I'm simply explaining the rules as they presently are, not how they
>should be.
>
>Do you mind if I forward your message to my ham friends? It would help
>underscore a message I've been trying to make for a long time.

Go ahead. I'll take some heat for sure, but I'm used to that. You might
add that if the people lobbying for this were truly civic-minded, they'd
WILLINGLY agree to forfeit licensed use of the Part 15 spread spectrum 
bands -- perhaps in return for use of the old "citizens' band," which now 
lies mostly unused.

--Brett Glass
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