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[aprssig] APRS on expedition, but non ham?

Ray McKnight shortsheep at worldnet.att.net
Mon Nov 1 19:06:02 UTC 2004

I know that "immediately" was in .109 at least until very recently.
So this section must have been revised within the last year or two.
Just to save face, I'll look at my copies on one of the other machines
That should have still have them stored somewhere.

Regarding the control operator issue, there are those like yourself
Who do not believe that turning a transmitter off is necessarily a
Function restricted only to a control operator.  I disagree, and there
Are others on this SIG who have expressed agreement, that ANY control
Of the transmitter requires a control operator.  Some folks seem to
Trivialize the responsibility of the control operator, especially for
Equipment operating under automatic control.  But the regulations do
Not imply that the primary station licensee has immunity or is less
Responsible for compliance with Part 97 when station control is delegated.
There was a time when such delegation was required (or at least it was
strongly recommended, as well as good practice for the licensee to also
maintain a copy of the control operator's license) to be in writing unless
The licensee was immediately available (as in physically present, but not 
In direct control themselves).  Example, repeater control operators should
Have been appointed in writing, with contact information.  Don't forget that
Any infractions committed by the control operator don't fall on them, but
On the station licensee.  When repeaters were first becoming popular, this
issue was a huge deal for many clubs, and they were careful in the selection
of control operators to insure that the system was vigilantly monitored to
avoid improper transmissions or malfunction.  I realize that traditional FM
voice repeaters are typically operated under remote control, not
automatically, but the parallels in interpretation of the responsibilities
control operator and station licensee are the same.  Just because the
station is operating under automatic control, and control has been delegated
to someone else, shouldn't blur the lines.  Again, I believe that turning a
transmitter off requires control operator intervention, and cell or
satellite phones as the control link may serve to accomplish this, relying
on a non-Amateur on the other end doesn't relive final responsibility of
compliance with Part 97.  If the transmitter cannot be turned off, whether
it be a technical issue, physical access issue, or just plain "I'm too busy,
lazy, or stupid" issue, the regulatory burden still falls upon the licensee,
and I personally wouldn't want to give the FCC some lame excuse like "the
dog sled was running away and the guide couldn't catch them for 3 days".

We should also examine the whole purpose of the control operator, which is
to prevent unauthorized transmission and interference.  It goes far beyond
the simple issue of the need to push the off button on a tracker.

But I do feel there needs to be some leniency based upon the type of
operations.  For instance, placing a tracker on an unmanned  balloon, which
is a short-lived event and not having a control link.  There certainly is
the possibility for it to malfunction, but the duration of the event
provides a fail-safe mechanism to cease operations within a timely fashion
The balloon returns to the ground in a few hours and can be shut off, the
malfunctioning tracker even providing a means to locate itself, but
interference minimalized due to it laying on the ground or in a tree, at
very low altitude).  But events which span many days or weeks, certainly
should have more stringent control safeguards to prevent extended
interference or improper transmission. Consider the potential interference
from a malfunctioning tracker in a RV on a cross-country trip, how many
square miles will it eventually impact, how many other stations will it be
in proximity to?)

When I was studying for my Novice, the teachers spent a LOT of time on the
subject of control operator and the responsibilities of the station
licensee.  It's the entire basis for the Amateur Service being a
self-regulating entity.  If you feel that any control of the transmitter
requires a control operator, then certainly a non-Amateur cannot perform
that function.  Some people don't feel that way.  It's your license, do what
you feel is right for you.

-----Original Message-----
From: aprssig-bounces at lists.tapr.org [mailto:aprssig-bounces at lists.tapr.org]
On Behalf Of Steve Dimse
Sent: Monday, November 01, 2004 05:29
To: TAPR APRS Mailing List
Subject: RE: [aprssig] APRS on expedition, but non ham?

On 10/31/04 at 11:42 PM Ray McKnight <shortsheep at worldnet.att.net> sent:

>First, I disagree completely.
>You have conveniently omitted one critical word found 
>in the regs:  IMMEDIATELY.  Yes, please take your own advice 
>And go back and carefully read the section on automated control.

The joys of modern technology...searching the regs reveals only two places
part 97 where "IMMEDIATELY" appears, both are in the section regarding
Examiners. Here is 97.109 (d):

(d) When a station is being automatically controlled, the   control operator
need not be at the control point. Only   stations specifically designated
elsewhere in this Part may   be automatically controlled. Automatic control
cease   upon notification by an EIC that the station is transmitting
improperly or causing harmful interference to other   stations. Automatic
control prior approval of the EIC.   

Besides, even if the requirement was immediate, I could pick up the phone
call this expedition's satellite phone faster than I could use the remote
features of a KPC-3 to disable a tracker next door.

>Another key issue that's been debated on the SIG many times is
>The role of the control operator.  The fact is that the duties of a control
>operator historically have never been able to be delegated, EXCEPT to
>Another LICENSED HAM with the class of license suitable for the 
>Frequency and type of emission being used.  

Turning a radio OFF is not delegating control op responsibility, and the FCC
clearly allows automatic control with the operator not at the control point.

Steve K4HG

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