My comments on Docket 92-136
Phil Karn
Before the
Federal Communications Commission
Washington, D. C. 20554
In the matter of )
)
Amendment of Part 97 of the ) PR Docket 92-136
Commission's Rules to Relax )
Restrictions on the Scope of )
Permissible Communications )
in the Amateur Service )
To: The Commission
COMMENTS OF PHILIP R. KARN, JR., KA9Q
_ 1. _ I_ n_ t_ r_ o_ d_ u_ c_ t_ i_ o_ n _ a_ n_ d _ B_ a_ c_ k_ g_ r_ o_ u_ n_ d
I most heartily applaud the Commission's move to relax
the existing rules regarding prohibited transmissions in the
Amateur Radio Service. My only concern is that the proposed
changes do not go nearly far enough.
Before the _ E_ y_ e_ b_ a_ n_ k docket in the early 1970s, the FCC
rules regarding the "business use" of amateur radio were
very simple: an amateur could not sell radio communications
services. Period. Indeed, this is the very essence of the
word "amateur", which Webster's New World Dictionary defines
as "a person who engages in some art, science, sport, etc.
for the pleasure of it rather than for money; a nonprofes-
sional; specifically an athlete who is variously forbidden
by rule to profit from athletic activity." Other parties may
make money off the Olympics, for example, but the athletes
themselves are still (nominally) amateurs.
Despite the lack of a clear and demonstrated threat,
the Commission drastically expanded the prohibitions on the
Amateur Service with the _ E_ y_ e_ b_ a_ n_ k docket. This action
occurred in a very different era. It came just before the
start of the digital revolution that put powerful new com-
puting and communications technologies into the hands of the
average person, including the average radio amateur. It was
a time when AT&T jealously guarded its monopoly on long dis-
tance telephone service against even the tiniest threat of
"competition", including, perhaps, the Amateur Radio Ser-
vice. AT&T even demanded the right to prohibit (or at least
heavily restrict) the interconnection of its network with
October 1, 1992
- 2 -
customer-provided terminal or communications equipment.
These moves eventually earned AT&T an antitrust suit
that resulted in the breakup of the Bell System, the transi-
tion to open competition in long distance telecommunica-
tions, and a complete overhaul (which is still underway) of
US telecommunications policy to promote even more competi-
tion, e.g., in local telephone service. The FCC now recog-
nizes that it is not tasked with protecting AT&T's revenues.
Yet despite the radical change in overall US telecom-
munications policy since the early 1970s, the prohibitions
of the _ E_ y_ e_ b_ a_ n_ k docket on the Amateur Service remain in
effect. Along with the recently removed requirement that
every prospective amateur pass a code test, these restric-
tions severely stunted the Amateur Service at a time when it
should have experienced dramatic, healthy growth, particu-
larly in its capability to provide public service communica-
tions.
There seem to be few limits on how broadly 97.113(a)
can be interpreted. Indeed, "armchair lawyering" has become
almost a cottage industry among hams. At times it seems that
discussing the meaning of 97.113(a) is the only permissible
use of amateur radio![1]
The current restrictions also lend themselves to selec-
tive, politically motivated enforcement, such as the
infamous citation of packet station operators for carrying
an anti-Gulf-War "900 number" message in early 1991. That
this action was indeed politically motivated is hard to deny
when one considers that no amateur was ever cited for carry-
ing health and welfare traffic on behalf of the US military
at the same time, even though this could be construed as
assisting the US military with its regular business affairs.
Such selective enforcement of a rule to stifle speech criti-
cal of the Government strikes at the heart of our First
Amendment guarantees and can never be tolerated.
_ 2. _ D_ i_ s_ c_ u_ s_ s_ i_ o_ n
Restrictions on the permissible use of Amateur Radio
should be kept to the absolute minimum required to further
the basis and purpose of the service. In other words, each
_________________________
9 [1] Earlier this year I wrote and distributed satire
ostensibly claiming that amateur radio operation with
commercially manufactured transceivers violated
97.113(a) because it promoted the regular business af-
fairs of the transceiver manufacturer, and operation
with commercial power also violated 97.113(a) because
it promoted the regular business affairs of the elec-
tric utility. Several people took me seriously.
9
October 1, 1992
- 3 -
and every prohibition must continually justify its
existence. Not only is this philosophy in harmony with the
(theoretical) traditions of American government, but it also
maximizes the return to the public from the spectrum it has
invested in the Amateur Service. I would like to analyze the
proposed new regulations in this light, and suggest addi-
tional relaxations that would not threaten the character of
the Amateur Service.
_ 2._ 1. _ 9_ 7._ 1_ 1_ 3(_ a)(_ 1)
This proposed section is sound. Indeed it is the _ o_ n_ l_ y
rule that is really needed to protect the Amateur Service.
Although it will not completely prevent every conceivable
abuse, additional restrictions are unnecessary because this
simple rule ensures that any abuses that will occur will be
self limiting. This is true because of a universal charac-
teristic of human nature: no one wants to volunteer his or
her time and the use of his or her property solely to make
money for someone else without getting _ s_ o_ m_ e_ t_ h_ i_ n_ g in return.
And to the extent that an amateur gets a non-pecuniary
return for providing communication services to others (e.g.,
access to communication links provided by others in a
cooperative network, or the sense of satisfaction that comes
from providing a public service) he will be contributing to
the basis and purpose of the Amateur Service, whether or not
some other party happens to benefit financially from the
arrangement.
Although this would be a very liberal rule, there's one
common practice that it would (and should) prohibit: the
payment of a required membership fee for access to "closed"
amateur repeater and remote base systems. Despite the
widespread nature of this practice, it is tantamount to sel-
ling amateur communication services, which is directly
counter to the basic principles of the Amateur Service. This
is _ n_ o_ t to say that the operator of a repeater should be
forced to open his machine to anyone who wants to use it. It
only says that he cannot establish a quid-pro-quo relation-
ship between the payment of a fee and access to an amateur
radio communication system.
_ 2._ 2. _ 9_ 7._ 1_ 1_ 3(_ a)(_ 2)
The prohibition on "communications in which the station
licensee or control operator has a pecuniary interest,
including communications on behalf of an employer" is vague
and overly broad. Because many amateurs (including myself)
have related professional and amateur interests, this rule
could be interpreted as prohibiting much valuable "cross
fertilization" that benefits both fields.
For example, much technology originally developed and
tested within and for the Amateur Service is eventually
October 1, 1992
- 4 -
commercialized. Examples include AMSAT's low-cost satellite
technology, TAPR's packet radio developments, and my own
TCP/IP networking software package. In my opinion, this ful-
fills the amateur mandate to advance the state of the radio
art, especially since the additional developments made pos-
sible by the proceeds from commercialization are made freely
available to amateurs. But, strictly speaking, doesn't this
practice violate the letter of the "no pecuniary interest"
prohibition? Given the history of the existing regulation,
I would not be surprised to one day find amateurs seriously
arguing that it does, regardless of any benefits to the Ama-
teur Service.
A related problem with this rule is the fact that many
amateurs like to "talk shop" over the air, not because
they're paid to do so, but because they have technical jobs
that they enjoy talking about. Significant "cross fertili-
zation" often results that benefits both the amateur's
employer and the Amateur Service.[2] Wouldn't this also be a
technical violation of the rules?
Although I don't argue with the motivation behind this
rule (no one wants to see the ham bands taken over by taxi-
cab dispatchers) I am unable to propose alternate language
that would ban only those "employer-benefiting" communica-
tions that clearly harm amateur radio. Unless the Commis-
sion can do so, I suggest removing this prohibition alto-
gether and relying entirely on the first rule (no communica-
tions for hire) to limit abuses.
_ 2._ 3. _ 9_ 7._ 1_ 1_ 3(_ a)(_ 3)
The ban on "music" is completely unnecessary. As stated
in the petitions for rule making, this rule has caused many
amateurs to believe it prohibits even the incidental back-
ground music one might hear during an autopatch call or in
"wakeup calls" during Space Shuttle missions.
It has also engendered debates over whether transfer-
ring MIDI[3] format computer files is legal. The League's
position, as stated in _ T_ h_ e _ F_ C_ C _ R_ u_ l_ e _ B_ o_ o_ k, is that it is. But
the basis for this interpretation is not at all clear. Why
should digital bits representing the notes of a musical
score be legal on the ham bands while digital bits
representing the output of a synthesizer fed the very same
MIDI score be illegal? Admittedly the MIDI score is a much
more compact representation of the same information, but if
efficiency were a consideration, one could justify outlawing
_________________________
9 [2] One of the founders of my present employer (a ra-
dio communications R&D company) is an amateur who is
fond of saying that "anything you do in ham radio
you'll probably use at work within 6 months".
9
October 1, 1992
- 5 -
many other amateur practices...
The fact of the matter is that there is no real need
for a music prohibition. Most musical recordings that an
amateur would want to deliberately transmit are protected by
copyright anyway. And given the prohibition against accept-
ing payment for amateur communication services rendered, it
seems unlikely that the average amateur would be willing to
pay copyright license fees out of his own pocket.
As a strong believer in the First Amendment, I am also
troubled by some of the other prohibitions on this section.
Prohibitions on "obscene, indecent, or profane words or
language" (whatever they are) are ill-defined and vague, and
in my opinion should be unconstitutional. This is not to
say that I defend or encourage obscenity, only that it is
futile and counterproductive for the government to attempt
to legislate common courtesy and manners. Nevertheless, I
know that this is a minority position in our increasingly
moralistic and intolerant society, so I would argue against
these restrictions from a more practical standpoint -- that
they inhibit the development of automatic store-and-forward
data networks. Intermediate stations in these networks are
unable to automatically screen the traffic they carry, and
holding the operators of these stations responsible only
serves to discourage the development of these networks. If
the Commission sees fit to retain these prohibitions, they
should be applied only to the originator of the communica-
tions. One way this might be accomplished is to insert the
word "knowingly", as in "no amateur operator shall _ k_ n_ o_ w_ i_ n_ g_ l_ y
transmit obscene, indecent or profane words or language..."
I am also moderately opposed to continuing the restric-
tion on codes and ciphers. The practical application of
codes and ciphers to real communications systems is
presently the subject of much research, development and
experimentation in the communications industry. Permitting
amateurs to use them would allow us to participate in these
efforts. I understand that codes and ciphers could be used
to conceal evidence of improper use of amateur radio, but if
the only rule is that one cannot sell amateur communications
for hire, it is not clear that one would be able to deter-
mine this solely from the content of a communication anyway.
Removing this prohibition would also eliminate a precedent
that may soon be used to help justify draconian government
restrictions on the private use of cryptography over common
carrier facilities.
9_________________________
9 [3] Musical Instrument Digital Interface. Such files
essentially encode the score of a musical piece, as op-
posed to the actual sounds that a listener would hear.
October 1, 1992
- 6 -
I presume that another reason for this prohibition was
to prevent the use of amateur radio for espionage purposes.
But there are now many other communication alternatives
available to spies that are far more reliable and secure and
convenient than amateur radio, including the use of encryp-
tion over ordinary telephone lines.
_ 2._ 4. _ 9_ 7._ 1_ 1_ 3(_ a)(_ 4)
This section is also vague and overly broad and should
be deleted. In particular, the phrase "on a regular basis"
will mean something different to everyone who reads it. As
many others will undoubtedly point out, almost any amateur
communication can in theory be handled by other radio ser-
vices. This is particularly true given new developments like
the cellular telephone.
_ 2._ 5. _ 9_ 7._ 1_ 1_ 3(_ b)
I am not convinced of the need for a specific prohibi-
tion on broadcasting since, again, I believe that a simple
prohibition against providing amateur communications for
hire would serve to limit any abuses. I would point out,
however, that there is no practical way to restrict author-
ized broadcasts such as Space Shuttle mission audio to the
exclusive use of radio amateurs, and I suspect that there
are many non-amateurs who listen to them. Given that there
are already enough amateurs to justify these broadcasts,
these additional passive listeners in no way threaten the
nature of the Amateur Service. Indeed, they probably do much
to make amateur radio visible to the public, something that
clearly benefits the service.
_ 2._ 6. _ 9_ 7._ 1_ 1_ 3(_ c,_ d)
These two exceptions to the prohibitions would be
unnecessary if only the simple "no communications for hire"
rule were adopted. Since neither the teacher demonstrating
amateur radio or the W1AW operator running code practice
would be charging anyone for an actual communications ser-
vice, irrespective of whether they are being paid a salary
for their services as an operator of an amateur station,
their activities would be permissible.
_ 2._ 7. _ 9_ 7._ 1_ 1_ 3(_ e)
This rule is also unnecessary, for the same reason that
the music prohibition is unnecessary. Many of the stations
that might be retransmitted emit either copyrighted material
(e.g., broadcast stations) or are protected from intercep-
tion by the Electronic Communications Privacy Act (e.g.,
common carrier stations). These other restrictions, along
with the ban on amateur communications and the desire to
avoid spectrum waste, would serve to limit abuses of the
October 1, 1992
- 7 -
ability to retransmit non-amateur signals.
_ 2._ 8. _ 9_ 7._ 1_ 1_ 3(_ f)
The meaning of the phrase "automatically retransmit the
radio signals" has become deeply ambiguous with the develop-
ment of digital store-and-forward (packet) radio networks.
For years amateurs have argued over whether a "digipeater"
or packet switch is a repeater within the meaning of the
Commission's rules. This is an important issue since it
determines the legality of operating a digipeater outside
the repeater sub bands.
I suggest that if the Commission retains this restric-
tion at all, it should adopt a more limited definition of
"repeater" as a station that automatically retransmits the
radio signals of other stations _ w_ i_ t_ h_ o_ u_ t _ b_ e_ i_ n_ g _ u_ n_ i_ q_ u_ e_ l_ y
_ a_ d_ d_ r_ e_ s_ s_ e_ d _ a_ n_ d _ r_ e_ q_ u_ e_ s_ t_ e_ d _ t_ o _ d_ o _ s_ o _ b_ y _ t_ h_ e _ s_ t_ a_ t_ i_ o_ n _ b_ e_ i_ n_ g
_ r_ e_ p_ e_ a_ t_ e_ d. Since a digipeater or packet switch retransmits
only those packets that contain its callsign or unique net-
work address, unintentional repeating -- the original reason
for restricting repeaters to sub bands -- is impossible.
Conventional carrier-operated repeaters would continue to be
restricted to the repeater sub bands, as would repeaters
with continuous sub-audible tone squelch access, since these
"PL" tones are not unique to each repeater.
Note that whether the repeater carries analog voice or
digital data would be irrelevant; a digital repeater that
regenerates and retransmits input bits without examining
their content would be restricted to the repeater sub bands,
while a voice repeater that requires a unique digital code
for access would not be similarly restricted.
_ 3. _ S_ u_ m_ m_ a_ r_ y _ a_ n_ d _ C_ o_ n_ c_ l_ u_ s_ i_ o_ n_ s
Again, I heartily applaud the Commission's proposal to
relax the usage prohibitions on the Amateur Radio Service,
and I encourage it to go even further than what it has pro-
posed. Significant relaxation is required if amateurs are to
further the state of the radio art and provide meaningful
services to the public. Much, if not most, of the leading-
edge developments in communication technology now involve
networks of stations that automatically relay digital com-
munications. Not only do these computer controlled stations
significantly enhance flexibility and reliability, but they
make much better use of our spectral resources. They let us
use low power transmitters on higher frequency bands so we
can intelligently route information only where we want it to
go instead of "flooding" it everywhere in a brute-force
fashion with high-powered, low frequency transmitters. If it
weren't for the present regulations, we could transparently
interconnect amateur and non-amateur facilities (e.g., the
Internet) into a powerful and flexible hybrid that would
October 1, 1992
- 8 -
substantially benefit _ b_ o_ t_ h amateurs and non-amateurs.[4]
Yet the FCC rules, mainly those having to do with
prohibited and third-party communications, keep getting in
our way because there is simply no practical way to screen
communications in an automatic station. Although some may
object that our networks are beginning to resemble those of
common carriers, the term "common carrier" is a legal con-
cept, not a technical one. By definition, a common carrier
sells its services to anyone willing to pay, and this is
specifically prohibited by the existing rules and by the new
proposed 97.113(a)(1). Regardless of the technology we use,
amateur radio is _ n_ o_ t a common carrier and it is in no danger
of becoming one as long as communications for hire continue
to be prohibited.
That a voluntary, cooperative communication network can
continue to function effectively in the absence of
government-mandated restrictions on its use is demonstrated
by the _ U_ S_ E_ N_ E_ T and _ F_ I_ D_ O_ N_ E_ T computer networks. USENET and
FIDONET are very similar in functionality to the amateur
packet radio bulletin board networks, except that because
common carrier (dialup telephone, leased line) transmission
facilities are used, the draconian "acceptable use" rules of
amateur radio do not apply. Even the Internet continues to
thrive despite its evolution into a mix of publicly- and
privately funded networks, with parts operated as commercial
service offerings and others continuing as non-profit
cooperative enterprises, some operated out of individuals'
pockets. Yet all of these networks continue to thrive, with
the more egregious abuses limited by peer pressure, self
restraint and self policing, concepts quite familiar to
radio amateurs. (In particular, USENET and FIDONET have
strong traditions against commercial exploitation, largely
because the individual operators who foot the phone bills do
not wish to support the money-making activities of others
unless there is some compensating benefit to the network as
a whole.)
I firmly believe that the same mechanisms would con-
tinue to protect amateur radio if it were deregulated. If it
is not, then the potential of amateur radio to join the
mainstream of the personal communications revolution will
remain largely unrealized.
9_________________________
9 [4] Indeed, this radio/wire Internet may eventually
be built, but under Part 15, not Part 97, because Part
15 has no content restrictions at all. And this will
have been another lost opportunity for the Amateur Ser-
vice to fulfill its mandate to advance the art of com-
munications and to serve the public.
October 1, 1992
- 9 -
Respectfully submitted,
Philip R. Karn, Jr., KA9Q
October 1, 1992
Uri Blumenthal
Actually, Phil, if you don't mind [me plagiarizing
your text] - I'll sign it and send to FCC too.
Regards,
Uri.
------------
<Disclaimer>
Dave Pascoe
I'd like to get a copy.....
--
Dave Pascoe KM3T
Internet: pas...@rocky.gte.com
GTE/MSED - Needham Heights, MA
(617) 455-5704
Paul W Schleck KD3FU
for the 1972 Eye Bank Docket was protection of the then-monopoly on
telecommunications by the Bell System, thanks for putting that in.
The part about Usenet and Fidonet being shared resources with community
guidance and self-enforcement was also right on the money.
Let's hope the FCC chooses to "do the right thing" on this issue.
--
73, Paul W. Schleck, KD3FU
Celebrating 60 years of the Univ. of Maryland ARA - W3EAX (1933-1993)
John Covington WN4BBJ
>Does anyone have the full text of PR Docket 92-136 on line somewhere?
>I'd like to get a copy.....
I think I have a copy around here that someone posted. I'll post it
in a couple of days if someone else doesn't.
By the way, the comment deadline on 92-136 was October 1st.
So if you haven't filed original comments already, they may not
read them (I think they have sometimes read late comments anyway but
not with any regularity). I filed my own comments in this matter
on the 29th and had to send them Priority mail to be sure they
arrived by the deadline.
The NPRM on Novice License testing has a comment deadline of October
9th. So if you plan to file comments on that, you need to finish
them soon and get them in the mail!
--
John Covington WN4BBJ Internet: jmco...@mosaic.uncc.edu
P.O. Box 217122 MCI Mail: JCOVINGTON 342-6957
Charlotte, NC 28221-7122 Packet Radio Mail: WN4BBJ @ N7IJI.#CLT1.NC.USA.NA
(704) 537-7653 "Kenneth, what's the frequency?" "I dunno, ask Dan"
Paul W Schleck KD3FU
>In article <1992Oct2.2...@europa.asd.contel.com> pas...@rocky.gte.com (Dave Pascoe) writes:
>>Does anyone have the full text of PR Docket 92-136 on line somewhere?
>>I'd like to get a copy.....
>I think I have a copy around here that someone posted. I'll post it
>in a couple of days if someone else doesn't.
No need to, really. It's available via anonymous FTP from
ftp.cs.buffalo.edu under /pub/ham-radio/pr_docket_92-136. My original
post had an expire time of Dec. 1 (the deadline for REPLY comments)
but I doubt most new sites will obey it... :-).
>By the way, the comment deadline on 92-136 was October 1st.
>So if you haven't filed original comments already, they may not
>read them (I think they have sometimes read late comments anyway but
>not with any regularity). I filed my own comments in this matter
>on the 29th and had to send them Priority mail to be sure they
>arrived by the deadline.
Yeah, I was a bit paranoid too and sent it Certified. I got the green
card back indicating that they received it on the 29th (my comments were
similar to Phil's, advocating the simpler test). What is potentially
interesting is that if anyone uses your comments in reply comments they
have to send you a copy. A good way to find out if you are really
listened to :-).
Paul Williamson
> I am not convinced of the need for a specific prohibi-
>tion on broadcasting since, again, I believe that a simple
>prohibition against providing amateur communications for
>hire would serve to limit any abuses.
Have you ever been involved with non-commercial (or "public") radio
broadcasting? I have. Non-commercial broadcasters are a very
enthusiastic lot. The non-comm station I was associated with started
as a bootleg AM station, then went carrier-current on campus. Their
timing was good; about that time the FCC was granting 10-watt FM
licenses with minimal paperwork. After several upgrades, that station
is now a 50,000W FM station in a major metro market (KTRU, the Rice
University radio station, in Houston).
The rules for non-commercial FM stations are only a little bit more
liberal than the rules you propose for the amateur service. They
are allowed to collect money, but are strictly limited in the kinds
of services they can supply in return. Many of these stations
operate with no monies from outside donors at all (KTRU operated
this way for several years that I know of).
There are quite a few would-be broadcasters out there who, for one
reason or another, can't get an on-air license. Here in San Diego,
for example, we have two major universities whose radio stations are
cable-only (partly because the non-comm band is cluttered up with
giant Mexican commercial stations). If it were legal to set up a
broadcast station on amateur frequencies, some of these would-be
broadcasters would do it in an instant, even if no money would ever
be forthcoming. It wouldn't be as cool as a broadcast station in the
principle broadcast bands, but amateur receivers aren't hard to come
by anymore. Of all the imagined hazards that the FCC rules are
designed to avoid, I think broadcasting is the only one that's likely
to significantly injure the amateur service.
Relaxing the prohibition on broadcasting would be even riskier in
combination with a relaxation of the rule prohibiting music. I imagine
that the no-music rule arises mainly from a desire to prevent de facto
broadcasting in the amateur bands. If both music and broadcasting
became legal, 2m might become the top-40 band.
If you grant that the FCC has a charter to restrict certain types of
operation to certain frequencies, then you should accept that it must
promulgate rules that define the nature of the various identified
radio services. There's plenty of spectrum already allocated to
broadcasting to the public. That's distinct from the amateur radio
service for good reasons, and should remain so.
73 -Paul Williamson, KB5MU
Phil Karn
>>So if you haven't filed original comments already, they may not
>>read them (I think they have sometimes read late comments anyway but
>>not with any regularity).
You can still file comments as long as you phrase them as nominal
replies to others that have already been filed. And nothing says you
have to disagree with a comment to reply to it; you are free to say
"Amen!" as well as "Bullshit!", though either type of response would
be more effective if you elaborate beyond these two words...
Phil
Phil Karn
(Paul Williamson) expresses doubts about removing the broadcasting
prohibition:
>Have you ever been involved with non-commercial (or "public") radio
>broadcasting? I have. Non-commercial broadcasters are a very
>enthusiastic lot.
Yes, I have, and yes, you're quite right. And I dare say they'd be
*far* more interesting to listen to than most existing ham QSOs. :-)
Seriously, I favor removing the broadcasting prohibition for the same
reasons I favor removing most of the other prohibitions in 97.113: to
permit hams to build new and novel forms of communication without
constantly worrying about their legality. Questions have already been
raised about whether usenet-style discussions and flames on packet,
for example, violate the no-broadcasting rule, and whether the content
of a packet bulletin is "of direct interest to radio amateurs only" to
be an allowable one-way transmission. The broadcasting prohibitions
are also susceptible to politically motivated abuse, as happened with
the now-famous "900 number" message during the Gulf War. (Even if
the business rule had not been in effect, the stations involved could
have been cited for participating in broadcasting since the message
was not directed to anyone in particular.)
> The non-comm station I was associated with started
>as a bootleg AM station, then went carrier-current on campus. Their
>timing was good; about that time the FCC was granting 10-watt FM
>licenses with minimal paperwork. After several upgrades, that station
>is now a 50,000W FM station in a major metro market (KTRU, the Rice
>University radio station, in Houston).
I don't think amateur radio has much to fear from activites like this.
First of all, very few members of the general public have receivers
capable of receiving amateur frequencies, and second, 2 KW is not very
much power by broadcast standards. Any self-respecting non-comm
operator will still want a spot in the regular broadcasting bands, or
he's going to have a pretty small audience.
Phil