Here is the reply from Chuck Skolaut at the ARRL.... looks like we'll have to
get an official FCC ruling on it.
George, KA3HSW
-----Forwarded Message-----
>From: "Skolaut, Chuck K0BOG" <cskolaut@arrl.org>
>Sent: Jan 10, 2008 3:45 PM
>To: ka3hsw@earthlink.net
>Subject: FW: FW: [illinoisdigitalham] ALE Sounding. What is it and how does it
>work?
>
>
>George,
>
>This really is a rules interpretation that will have to come from the official
>source - the FCC. Any opinion on our part would likely tend to confuse the
>issue.
>
>73,
>
>Chuck Skolaut, KÃBOG
>Field & Regulatory Correspondent
>ARRL - The national association for Amateur Radio
>860 594 0239
>cskolaut@arrl.org
>
>
>
>
>-----Original Message-----
>From: George Henry [mailto:ka3hsw@earthlink.net]
>Sent: Wednesday, January 09, 2008 5:28 PM
>To: Skolaut, Chuck K0BOG
>Subject: Re: FW: [illinoisdigitalham] ALE Sounding. What is it and how does it
>work?
>
>Understood. I was asking for your opinion, as someone knowledgeable in
>regulatory matters, as to whether these specific transmissions met the
>criteria to be permissible or not. Ms. Crystal is claiming that they do,
>while I do not see any way that they fit the list you give below, nor any
>other permissible one-way transmission listed anywhere else in Part 97.
>
>
>George Henry, KA3HSW
>
>
>
>-----Original Message-----
>>From: "Skolaut, Chuck K0BOG" <cskolaut@arrl.org>
>>Sent: Jan 9, 2008 3:52 PM
>>To: ka3hsw@earthlink.net
>>Subject: FW: [illinoisdigitalham] ALE Sounding. What is it and how does it
>>work?
>>
>>
>>George,
>>
>>Regarding one way transmissions, Part 97.111(b) permits the following:
>>
>>
>>
>>(1) Brief transmissions necessary to make adjustments to the station;
>>
>>(2) Brief transmissions necessary to establishing two-way
>>communications with other stations;
>>
>>(3) Telecommand;
>>
>>(4) Transmissions necessary to providing emergency communications;
>>
>>(5) Transmissions necessary to assisting persons learning, or improving
>>proficiency in, the international Morse code;
>>
>>(6) Transmissions necessary to disseminate information bulletins;
>>
>>(7) Transmissions of telemetry.
>>
>>73,
>>
>>Chuck Skolaut, KÃBOG
>>Field & Regulatory Correspondent
>>ARRL - The national association for Amateur Radio 860 594 0239
>>cskolaut@arrl.org
>>
>>
>>-----Original Message-----
>>From: George Henry [mailto:ka3hsw@earthlink.net]
>>Sent: Wednesday, January 09, 2008 10:57 AM
>>To: k0bog@arrl.net
>>Subject: Fw: [illinoisdigitalham] ALE Sounding. What is it and how does it
>>work?
>>
>>
>>Chuck:
>>
>>The following is, in my opinion, a rather creative explanation of ALE
>>(Automatic Link Establishment) "sounding" by Bonnie Crystal, KQ6XA, in
>>response to my posting the opinion that these "soundings" were illegal
>>automated beaconing by ALE stations.
>>
>>I would appreciate your opinion on this. I have inserted comments below
>>where I feel her explanation runs afoul of Part 97.
>>
>>
>>
>>Thank you.
>>
>>George Henry, KA3HSW
>>ARRL 0001155357
>>
>>
>>-----Forwarded Message-----
>>>From: expeditionradio <expeditionradio@yahoo.com>
>>>Sent: Jan 8, 2008 5:34 PM
>>>To: illinoisdigitalham@yahoogroups.com
>>>Subject: [illinoisdigitalham] ALE Sounding. What is it and how does it work?
>>>
>>>Here is some info about ALE sounding and how it works.
>>>
>>>What is an ALE sounding?
>>>In ham radio, ALE sounding is simply a station ID.
>>>Only the callsign is sent, example "This is AA1BB".
>>>Sounding is ALE jargon for "Station ID".
>>>
>>
>>Sure sounds like a beacon to me....
>>
>>
>>>What is the purpose of ALE sounding?
>>>The ID is transmitted for the purpose of establishing and maintaining
>>>communications with other stations and to meet the station
>>>identification requirements of ham radio rules and regulations.
>>>Sounding may also be part of a selective calling process.
>>>
>>
>>
>>
>>1) Simply putting your callsign out there on an automated messaging system
>>does not appear to be a "transmission necessary for establishing two-way
>>communications" if there is no intent to establish such two-way
>>communications AT THAT MOMENT. I maintain that the sole purpose of an ALE
>>sounding is to establish a "heard" list at other stations for possible FUTURE
>>connections. While it may FACILITATE establishing two-way communications at
>>some future time, it is definitely not NECESSARY for doing so. 2) If
>>two-way communications are NOT in progress, there is no station
>>identification requirement to be met. Ergo, the station ID is simply a
>>beacon transmission. 3) Sounding as "part of a selective calling process"
>>is illogical: if you are calling someone, you send a connect request to that
>>station. If they are calling you, they send a connect request. Sounding is
>>in no way "necessary" to that process.
>>
>>
>>>How does ALE fit in the various ham radio rules?
>>>How ALE sounding is applied to the different rules of various
>>>countries depends upon that country. Under USA's FCC rules, ALE
>>>sounding is a station ID and a communication.
>>>
>>
>>
>>It is a station ID when none is required, and definitely NOT a
>>"communication" if there is no intended recipient. Isn't this EXACTLY why
>>the Commission ruled that repeaters may not transmit regular ID's
>>irrespective of usage?
>>
>>
>>>ALE sounding is not "beaconing".
>>>ALE stations are not sending one-way transmissions like a beacon does.
>>>All the ALE stations are transmitting and receiving communications
>>>with all the other ALE stations in communication with each other.
>>>
>>
>>
>>This simply defies all logic... the soundings are most definitely one-way
>>transmissions. There is no response to a sounding, and therefore no two-way
>>communications, unless another station is holding traffic for the station
>>that transmits the sounding.
>
>
>
>>
>>
>>>What frequencies are soundings used by hams?
>>>In ham-friendly ALE, part of the guidelines for repetitive soundings
>>>is to transmit on "pilot channels".
>>>Pilot channels are ALE jargon for a designated calling frequency,
>>>usually only one channel per band. The pilot channels are within a
>>>segment of the HF bands that are designated for automatic operation by
>>>the national bandplans or the IARU Region bandplans, depending upon
>>>which applies.
>>>
>>>Ham Radio ALE Pilot Channel Frequencies
>>>
>>>Freq kHz SSB INTERNATIONAL REGION - AREA 3596.0 USB NORTH AMERICA -
>>>SOUTH AMERICA 3617.0 USB EUROPE-AFRICA-RUSSIA-MIDEAST 3626.0 USB ASIA
>>>- AUS - NZ - PACIFIC
>>>7040.5 USB EUROPE-AFRICA-RUSSIA-MIDEAST-S.AMERICA
>>>7102.0 USB NORTH AMERICA - PACIFIC - ATLANTIC
>>>7185.5 USB AUSTRALIA
>>>10145.5 USB GLOBAL
>>>14109.5 USB GLOBAL
>>>18106.0 USB GLOBAL
>>>18117.5 USB EUROPE-AFRICA-RUSSIA-MIDEAST 21096.0 USB GLOBAL 21116.0
>>>USB EUROPE-AFRICA-RUSSIA-MIDEAST 24926.0 USB GLOBAL 28146.0 USB GLOBAL
>>>28312.5 USB EUROPE-AFRICA-RUSSIA-MIDEAST
>>>
>>>Amateur Radio Global High Frequency Network (HFN) The Amateur Radio
>>>Global ALE High Frequency Network is a group of volunteer operators
>>>who have automatically controlled data stations on the ALE Pilot
>>>Channels.
>>>These are known as HFN Pilot Stations, and they provide interconnect
>>>texting services and HF-to-HF Relay services.
>>>The long term objective is to be interoperable with as many different
>>>types of systems as possible. The primary purpose of the HFN is to
>>>provide emergency and disaster relief 24/7/365 communications. When
>>>not in use for the primary purpose, hams may access any of the HFN
>>>stations for normal use. Another secondary aspect of the HFN stations
>>>is that they provide a continuous feed to the internet, reporting all
>>>other ALE stations they receive. This includes soundings and all other
>>>types of ALE calls. These reports get logged into a permanent
>>>database, and are visible on "ALE Channel ZERO".
>>>http://hflink.net/qso
>>>
>>
>>Please do take a look at the "ALE Activity Now" display on that website, and
>>tell me how all those "station ID" transmissions can be considered anything
>>other than automatic beacons.
>>
>>
>>>Many other ham radio ALE operators are transmitting soundings on the
>>>ALE pilot channels. The more operators who are active on ALE, the
>>>better everyone is able to connect with each other.
>>>
>>
>>
>>Huh????? The fact that "everybody is doing it" somehow make it okay to do???
>>
>>
>>
>>>The Ham Radio ALE Guidelines are included below in this message. You
>>>can get more info about ALE and sounding on the web at:
>>>http://www.hflink.com/sounding/
>>>
>>>73---Bonnie KQ6XA
>>>
>>>HAM RADIO SOUNDING INFORMATION
>>>
>>>What is Sounding?
>>>In Amateur Radio ALE, a sounding is simply a 10 second ALE
>>>transmission of your callsign (station identification). A sounding is
>>>different from a beacon because the ALE station uses 2 way
>>>communications; and the ALE sounding transmission is part of a
>>>selective calling process for calling and actively maintaining
>>>communication with other stations in the global ham radio ALE net and
>>>individually.
>>>
>>
>>
>>Again, this explanation simply defies logic. There is no two-way
>>communication involved in sounding
>>
>>
>>
>>>Why are Soundings Used?
>>>The reception and communication through soundings enables other ALE
>>>stations to know which frequencies or bands your station is active on.
>>>When you first turn on your transceiver, you can send some soundings
>>>so that other stations will copy your transmissions, and then may
>>>selectively call you on the best channel, using the minimum number of
>>>call attempts. The scanning ALE receiver listens to the soundings of
>>>other stations each time they are heard and stores them in memory with
>>>channels and times.
>>>
>>
>>
>>If done manually to poll for any held traffic, I would agree that this would
>>be legal. However, when done automatically and at regular intervals, it
>>would appear to be a prohibited one-way transmission.
>>
>>
>>>How Are Soundings Transmitted?
>>>Soundings can be manually transmitted, or set by the operator to
>>>transmit repetitive soundings every hour. Usually, if repetitive
>>>soundings are set, when the ALE controller or radio is first turned on
>>>then there is a delay of a few minutes before the first soundings are
>>>transmitted.
>>>
>>>Ham-Friendly ALE Soundings
>>>In the ham radio ALE network, there are Pilot Stations in different
>>>areas of the world that send soundings 24/7. This system transmits
>>>sounding only on the Pilot Channels in the automatic station
>>>sub-bands, and this strategy forms part of the basis of ham-friendly ALE.
>>>
>>>ALE Sounding Guidelines for Amateur Radio
>>>
>>>1. As an Amateur Radio Operator, you are responsible for all
>>>transmissions of your station.
>>>
>>>2. Before sending soundings, or any transmission, listen carefully to
>>>all your transmitting channels with your receiver. Avoid interference.
>>>
>>>3. Sounding is not CQ. If you want to call CQ, use the HFL or QRZ netcall.
>>>
>>
>>***********************************************************************
>>*****************************************
>>This statement alone would appear to negate all of Bonnie's other
>>arguments... if it's not a CQ, and it doesn't appear to meet the definition
>>of any of the other permitted one-way transmissions, it's illegal.
>>***********************************************************************
>>*****************************************
>>
>>>4. Manual or attended soundings may be transmitted on any ALE channel.
>>>
>>>5. For repetitive sounding, program your ALE to sound only on the
>>>designated Pilot Channels marked PILOT in the Amateur Radio ALE
>>>Channel List, for your IARU/ITU Region, and within your license. There
>>>is one Pilot Channel per ham band in each Region.
>>>
>>>6. Program your ALE controller to use TWS Sound if possible. Using TWS
>>>Sound increases the efficiency of ALE nets. Please DO NOT use This Is
>>>Sound (TIS) on the ham bands.
>>>
>>>7. The optimum duration of a sounding transmission is approximately 10
>>>to 15 seconds. Test and verify your sounding transmission duration
>>>with your watch. A sounding transmission should NEVER be longer than
>>>30 seconds!
>>>
>>>8. The optimum repetitive sounding on a channel is about once every 60
>>>minutes. Please DO NOT sound repetitively on a channel more than 2
>>>times per hour.
>>>
>>>9. The optimum scan rate is 1 or 2 channels per second. If you scan
>>>more than 10 channels, use 2 channels per second.
>>>
>>>10. Check your transmitter operation and antenna system SWR regularly
>>>on every channel in your scan group!
>>>
>>>11. Take care in programming your ALE controller (software) and
>>>transceiver. Test it carefully and verify it for proper operation on a
>>>dummy load before connecting your antenna.
>>>
>>>12. Use the Polite or Voice Detect or Busy Detect feature of your ALE.
>>>
>>>
>>
>>
>>
>
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