AMSAT-NA Comments on FASC Discussion Paper

The Future of the Amateur Service Committee (FASC) of the International Amateur Radio Union (IARU) published a Discussion Paper entitled The International Regulations Affecting the Amateur Service in April 1996, as a preliminary step in preparation for the 1999 ITU World Radio Conference. At the AMSAT Board of Directors Meeting on June 29, 1996 in Silver Spring, Maryland, the Board finalized and approved the comments reproduced below for submission to the FASC. See the Board meeting minutes for further insight into the Board's discussion.

Comments on FASC Discussion Paper

The Radio Amateur Satellite Corporation (AMSAT-NA), with approximately 7,000 members, is the world's largest organization of radio amateurs participating in the amateur-satellite service, as well as the principal membership organization of such amateurs in North America. AMSAT-NA thanks FASC for the very thoughtful and professional way in which its discussion paper was prepared, and the invitation to offer comments. Accordingly, the following suggestions are offered for your consideration.

In this discussion, paragraph numbers refer to those in the FASC Discussion Paper, while those prefixed with the letter "S" refer to the interim numbering in the simplified radio regulations as adopted at WRC-95.

Paragraphs 6.1-6.5 discuss the present definition of the amateur service, at S1.56. FASC points out that this has remained essentially unchanged since 1927 and it is their conclusion that the present language is "entirely appropriate and that no change should be considered."

We do not propose any change in the key phrase, "solely with a personal aim and without pecuniary interest," which we consider entirely appropriate as does FASC. However, in FASC's extensive discussion of S1.56 one phrase, curiously enough, was passed over without comment -- "interested in radio technique." For reasons which will be more apparent following our discussion of paragraphs 7.1-7.6, we believe that updating this phrase may prove advantageous.

In point of fact, the "self-training, intercommunication and technical investigations" carried on over the air by today's radio amateurs involve interests that are far broader than the words "radio technique" would suggest -- indeed, so broad that attempting to characterize them in the ITU Regulations may now well be inappropriate. Our suggestion is simply to amend S1.56 by dropping these four words entirely; the new language would thus read:

S1.56. Amateur Service: A radiocommunication service for the purpose of self-training, intercommunication and technical investigations carried out by amateurs, that is, by duly authorized persons solely with a personal aim and without pecuniary interest.

We recognize that this suggestion is likely to be controversial. Our purpose in raising this issue at this early stage of IARU's decision process is to stimulate a full discussion of its potential consequences for amateur radio, pro or con, over the next three years. Because of its specific importance to the amateur-satellite service, we request that FASC continue to involve us in this discussion as it takes place.

AMSAT-NA has several issues relating to the nature and content of amateur transmissions, discussed by FASC at 7.1-7.6 and by ITU at S25.2-S25.4.

With respect to the use of "plain language" (7.2 and S25.2), national administrations from whose countries telecommand stations operate have frequently authorized exceptions for such operations, e.g., the following regulation and associated definition from the US Code of Federal Regulations (CFR):

A telecommand station may transmit special codes intended to obscure the meaning of telecommand messages to the station in space operation. [47 CFR Sec. 97.211(b)]
Telecommand station: An amateur station that transmits communications to initiate, modify or terminate functions of a space station. [47 CFR Sec. 97.3(a)(37)]

AMSAT-NA considers the ability to transmit enciphered telecommand messages to be absolutely essential to the fulfillment of the requirements of S22.1 and S25.11. Indeed, the telecommand of amateur space stations has been done in this way since the first remotely-commanded amateur spacecraft, Australis-OSCAR 5 in 1970. Further, it is frequently the case that the space station is licensed by one country while one or more of its authorized telecommand stations are licensed in other countries; AMSAT-OSCAR 13, for example, is licensed in Germany and telecommanded by authorized stations not only in that country but also in Australia, UK and the US. Thus, it is often the case telecommand transmissions are made "between amateur stations of different countries" (S25.2).

In view of the security concerns expressed by many emerging nations, we recognize that amending the "plain language" requirement itself may be difficult to accomplish. Rather, it may be more feasible to secure the adoption of a provision or footnote that expressly permits national administrations to authorize the use of special codes by telecommand stations, along the lines of the US regulatory language quoted above. To our knowledge, this issue has not been raised among administrations, but we are concerned that it may be at at some time in the future.

A second issue with respect to "plain language" concerns the use of digital coding techniques and/or spread spectrum emissions for transmissions to and from amateur satellite stations. AMSAT-NA believes that it must be mandatory that the codes and algorithms employed for such transmissions be widely published, to enable all amateurs worldwide to take part in the experiments involved. Furthermore, this provision should satisfy the security needs of national administrations (7.2) as well as assist amateur monitoring organizations such as the Intruder Watch.

Indeed, the use by amateurs of widely-published coding and data compression techniques, intended to facilitate communications rather than to obscure meaning, is hardly limited to transmissions to and from space. Picture files (eg, *.GIF), compressed data files (eg, *.ZIP) and forward error correction (FEC) are common examples. What all of these have in common is that the content of a transmission sent with them is context-dependent, i.e., a small snippet of reception conveys no information and the message can only be known after an entire transmission has been received and decoded.

We interpret the phrase "plain language," in the context of S25.2, to include any code or algorithm which has been widely published and is available to radio amateurs generally as well as to governmental monitoring agencies. If, in the opinion of FASC, this interpretation is not shared generally, then further attention must be given to this issue, as we consider it vital to continuing technical development of the amateur service and the amateur-satellite service.

We now turn to the content of amateur transmissions, discussed by FASC at 7.3 and 7.4. While we agree entirely with FASC's suggestion, made at 7.4, that the words "for which, by reason of their unimportance, recourse to the public telecommunications service is not justified" should be dropped as being unnecessary in today's environment, that in itself may not entirely resolve a problem with which the amateur-satellite service is increasingly confronted.

As many FASC members already know, a decreasing number of amateur radio satellites today are built in basement workshops or the equivalent, and launched free of charge by friendly government agencies, as occurred frequently in the past. In 1996, the typical satellite program in our service requires the out-of-pocket expenditure of up to several million dollars, much of which must go to pay for the launch itself. This situation is expected to remain, and become even more prevalent in the future.

For financial reasons as well as those having to do with the allocation of launch opportunities, the vast majority of spacecraft presently operating in and under construction for the amateur-satellite service today are the products of university laboratories; indeed, IARU's own International Satellite Forum takes place each year at the most prolific of such laboratories, that of the University of Surrey in Guildford, England.

Universities have many reasons for devoting their resources to the construction and operation of amateur radio satellites, but among them is the desire to conduct scientific research outside the earth's atmosphere and transmit the results to earth by means of telemetry.

The present language of S25.2, when read in conjunction with S1.56, may pose an barrier to university-affiliated groups seeking to provide additional satellites to our service.

Consider, for example, the transmission back to earth of results from a scientific experiment on board an amateur spacecraft. Such transmissions are obviously not "of a personal character," nor, after millions of dollars have been spent to make them possible, could they be considered to be "unimportant." What they are, however, could well be encompassed by the phrase "messages of a technical nature relating to tests" (S25.2).

The issue which we wish to raise, however, arises when that phrase in S25.2 is read in the light of S1.56, which defines the amateur service as one of "technical investigations carried out by amateurs, that is, by duly authorized persons interested in radio technique." Must the "tests" referred to in S25.2 pertain to "radio technique?" (S1.56)

Many of the university-based experiments now in progress via amateur radio satellites would be hard pressed to meet so narrow a definition, and AMSAT NA is frequently approached with proposals from other such groups that would be at least as far afield. Several of these are discussed in Note 1, below.

AMSAT-NA fully agrees with FASC that all transmissions from amateur stations, including those from space stations, should be "non commercial, non political, non religious, non entertainment and unpaid" (7.5). We ask whether a way should be found, within the ITU Regulations, to permit not-for-profit scientific research, the subject matter of which does not necessarily pertain to "radio technique," to be conducted within the amateur-satellite service by otherwise qualified stations and thus to facilitate the continuing supply of satellites for amateur use.

In addition to the consideration involving the providing of future amateur satellites, AMSAT-NA believes that there is another strong reason for liberalizing the ITU rules with respect to the content of amateur transmissions, as discussed above. We believe that such a change will encourage the use of the amateur service and the amateur-satellite service to participate in scientific research aimed at increasing mankind's knowledge in a variety of fields. This, we contend, will provide additional justification for maintaining amateur service and amateur-satellite service frequency allocations.

In this context, one can see the advantage to our service of eliminating the phrase "interested in radio technique" from S1.56, as proposed above. With this done, as well as the change to S25.2 suggested by FASC at 7.4 and our own earlier suggestion regarding telecommand stations, S25.2 (1) would read as follows:

S25.2 (1) When transmissions between amateur stations of different countries are permitted, they shall be made in plain language [footnote] and shall be limited to messages of a technical nature relating to tests and/or to remarks of a personal character.

[Footnote: Member countries may authorize their amateur stations, when transmitting communications for the purpose of initiating, modifying or terminating functions of a space station in the amateur-satellite service, to use means intended to obscure the meaning of such communications.]

Read in conjunction with the amended S1.56 discussed above, this language would, in effect, permit such "tests" to pertain to any technical subject as long as the transmission is carried out by duly authorized amateurs, solely with a personal aim and without pecuniary interest. National administrations, of course, would retain the right to interpret these requirements as they see fit, in the context of the prevailing customs and practices in their own countries, as long as they do not permit amateur stations to be used for reward or for carrying messages of a business character (8.13).

It will also be noted that we are suggesting that the word "and" in S25.2 (1) be changed to "and/or." No substantive change is intended by this suggestion, which in our opinion would simply be more descriptive of the actual situation than the existing language.

Turning to international communications more generally, we agree fully with the suggestions of FASC at 7.6, 8.10, 8.11 and 11.1.

AMSAT-NA concurs with FASC in its proposed changes to the international third party restrictions in the amateur-satellite service. These restrictions have severely limited the ability of our manned space program to stimulate students' interest in the fields of communications, technology and space sciences. Many opportunities for students to converse with astronauts and cosomauts have been missed because of existing restricions on third party traffic. This situation will grow in importance with the planned installation of an amateur station on the International Space Station because that Station will be manned by nationals of eight primary member countries. Only two of these countries currently have a third party traffic agreement with each other.

We also suggest that the change proposed by FASC is consistent with the many international declarations promoting the free flow of information between peoples of all nations.

We turn now to Section 12, which deals specifically with the regulations defining the amateur-satellite service itself and with certain requirements affecting this service.

AMSAT-NA agrees with FASC's suggestion, at 12.6, that S1.57 be amended by deleting the phrase, "on earth satellites" from the definition of the amateur-satellite service. In our view, no useful purpose is served by restricting amateur space stations to earth orbit. Proposals for amateur stations beyond earth orbit continue to be made from time to time; serious discussions have been held, for example, about a solar sailing experiment, payloads on the lunar surface and, most recently, an unmanned Mars probe [Note 1], all carrying amateur radio transmitters. In addition to these as-yet unrealized proposals, amateur stations have already been placed on rockets going beyond the major portion of the earth's atmosphere (hence, "space stations") but intended to return to earth rather than entering orbit. More such rocket experiments are anticipated in the near future and we see no reason why they should be discouraged by the wording of the Radio Regulations.

We also concur with FASC, at 12.9, that the amateur-satellite service should continue to be defined separately from the amateur service. We can see no advantage to merging the two; to quote an old American proverb, "if it ain't broke, don't fix it." Another advantage of keeping the two services separate might be to provide the flexibility of allowing some of the rule changes cited herein to be applied to one but not necessarily the other. Although AMSAT-NA belives that the provisions with respect to message content, suggested herein, should apply to both services, they might be easier to "sell" if they pertain only to the amateur-satellite service. It would also be desirable, we believe, to maintain the present distinction between the two services in the event that, in some future frequency allocation matter, a particular portion of the spectrum would be more suitable for one service than the other.

With respect to the discussion of interference and telecommand matters at 12.10-12.14, we agree with FASC that S25.11 appears redundant in view of S22.1 and S5.282, and in an ideal world should probably be deleted. On the other hand, as noted at 12.13, S25.11 adds no requirements to those already imposed by S22.1 and S5.282 and if raising the issue might be counterproductive, perhaps it would be best to leave the entire matter alone. The issue of whether or not we should seek the deletion of S25.11 should be discussed within IARU over the next two years to gain a better understanding of the political situation; either way, however, AMSAT-NA does not consider it a high-priority issue at this time.

We are very concerned, however, with upgrading the status of the amateur-satellite service bands above 146 MHz which are presently covered by S5.282. As noted by FASC at 12.14, this concern cannot be addressed except in the context of an allocation conference, but we wish to place the matter on IARU's agenda to be dealt with at an appropriate time. There are, in addition, other allocations matters which we would like to see brought before a future WRC and would propose a continuing dialogue with IARU with an aim of eventually bringing these about.

We look forward to continuing to work with FASC, with the IARU Satellite Adviser and IARU AMSAT Frequency Coordinator, and with IARU's regional organizations and member societies in furthering our common goal of a successful WRC-99.

Respectfully submitted,
Radio Amateur Satellite Corporation
by William A. Tynan, W3XO, President
June 29, 1996

Note 1: There are several instances of AMSAT-NA's having being approached on, or actually participating in projects which might have difficulty meeting a rigorous interpretation of S25.2.:

(a) One, which we felt we had to conclude was beyond the bounds of scientific data meeting the current rules, involved a satellite proposed by the University of Utah to fly a biological experiment. It was proposed to telemeter the results of this experiment on the 144 - 146 MHz amateur band because "simple, cheap readily available receivers (scanners) exist that will enable school children worldwide to participate in obtaining the experiment's results".

(b) Another involved the initial proposal for a satellite being built by Arizona State University. One of the original stated purposes of this satellite was to obtain data on erosion of a spacecraft's surface by micrometeorites. While not appearing to have anything to do with radio technique per se, we did conclude that we could support this effort under current international regulations because the data might be useful in designing future amateur satellites.

(c) Another example concerns a proposed project for an amateur Mars probe. This is also university based, in this case a German university. Aside from the objective of providing radio amateurs throughout the world the challenge of tracking and obtaining data from a spacecraft at interplanetary distances, it has been proposed that this probe, once in orbit around Mars, can be used to relay data from scientific data landed on the planet's surface by other, not necessarily amateur, space vehicles.

The original Comments paper was drafted by Ray Soifer, W2RS, and modified and approved by the Board of Directors of AMSAT-NA. Conversion to HTML for this page by Paul Williamson, KB5MU. Send your comments on this page to KB5MU.