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#1
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On 1/24/2013 1:58 PM, Tom Horne wrote:
Jerry It seems I have a reel talent for being unclear in how I ask questions. I wish that I could turn that into a job skill like the people who right crossword puzzles but I digress. When I said Ad Hoc EOCs I was referring to the ones in the city halls of the existing small cities in the county. They don't have dedicated spaces for an EOC but they set one up in a meeting or conference room when they have something serious going down. The idea would be to set up a few wifi capable links on taller buildings that could be linked to some central high spot and from there to the county's purpose built EOC. Prince Georges county ARES is looking at installing a High Speed Multi Media Mesh (HSMM-MESHâ„¢) Net between their county's hospitals. We have Used HSMM-Mesh at one public service event already and it worked well there. So those of us who have already deployed it successfully in a field deployed application were interested in seeing if it could be used to cover these longer distances effectively. If it were possible to run Web EOC on the links that would be sufficient. We are not trying to restore Facebook connectivity to the people at Temporary shelter locations but rather to put some readily predictable places in touch with the EOC. Since that could be done with automatic control under part 97 of the rules we would not need an operator at the served locations. As for testing we could put LAN routers at one or more of the nodes to allow appropriate local use of the WAN the links would provide which would provide the kind of continuous use and testing that you are talking about. We would have to have a way to shut down the LAN routers when the links were needed for emergency management support. -- Tom W3TDH Tom, Yes, I understood what you meant when you talked about "ad hoc EOC's". But why do you think they are "ad hoc"? Perhaps because they don't have the room for an EOC - which also means they don't have room for the equipment. That's why hams bring equipment into these ad hoc EOC's. As for the mesh network between hospitals. You need to be careful. For instance, NO medical information can be transmitted in the clear (HIPAA regulations have severe penalties for doing so) - which eliminates ham radio for transmitting this information (encryption not allowed). As for "automatic control" - this refers to control for licensed amateur stations. It does NOT include allowing unlicensed operators to control ham transmitters. You will still need a control operator to key the transmitter - which means either someone on site or someone who can otherwise tell when the transmitter needs to be keyed. I have to agree with Fred here. If you want to promote such a system, you should be looking at commercial technology. -- ================== Remove the "x" from my email address Jerry Stuckle JDS Computer Training Corp. ================== |
#2
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On Sat, 26 Jan 2013 20:36:49 EST, Jerry Stuckle
wrote: As for "automatic control" - this refers to control for licensed amateur stations. It does NOT include allowing unlicensed operators to control ham transmitters. You will still need a control operator to key the transmitter - which means either someone on site or someone who can otherwise tell when the transmitter needs to be keyed. A non-ham can key (or the digital equivalent) a ham transmitter as long as the control operator is "on duty and in control" to borrow, a phrase from the radio broadcast services rules. We interpret that to mean "in the room and aware of what's happening". 73 de K2ASP - Phil Kane ARRL Volunteer Counsel |
#3
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In article ,
Jerry Stuckle wrote: As for the mesh network between hospitals. You need to be careful. For instance, NO medical information can be transmitted in the clear (HIPAA regulations have severe penalties for doing so) - which eliminates ham radio for transmitting this information (encryption not allowed). Whoa, that is an ultra Broad Statement, and not supported by Part 97 Rules. There was published a very compelling White Paper on Part 97 Encryption Policy last Fall, that has generated some interest. I sent a copy to a few "Friends" at FCC HQ, from the Old Days, and got some very interesting replies, that though UnOfficial, tend to lead me to believe that the White Paper is Spot On.... Maybe Phil, could expound on the issue, a bit more as He was, is, a Comms Lawyer, previously with the Commission. What say Phil, would you like to climb out on this limb? -- Bruce in Alaska add path before the @ for email |
#4
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On Sun, 27 Jan 2013 13:52:20 EST, Bruce Gordon
wrote: Maybe Phil, could expound on the issue, a bit more as He was, is, a Comms Lawyer, previously with the Commission. What say Phil, would you like to climb out on this limb? Stand by on that..... 73 de K2ASP - Phil Kane From a Clearing in the Silicon Forest Beaverton (Washington County) Oregon |
#5
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On 1/27/2013 1:52 PM, Bruce Gordon wrote:
In article , Jerry Stuckle wrote: As for the mesh network between hospitals. You need to be careful. For instance, NO medical information can be transmitted in the clear (HIPAA regulations have severe penalties for doing so) - which eliminates ham radio for transmitting this information (encryption not allowed). Whoa, that is an ultra Broad Statement, and not supported by Part 97 Rules. There was published a very compelling White Paper on Part 97 Encryption Policy last Fall, that has generated some interest. I sent a copy to a few "Friends" at FCC HQ, from the Old Days, and got some very interesting replies, that though UnOfficial, tend to lead me to believe that the White Paper is Spot On.... Maybe Phil, could expound on the issue, a bit more as He was, is, a Comms Lawyer, previously with the Commission. What say Phil, would you like to climb out on this limb? FCC Rules, Part 97.113 (Prohibited Transmissions)): (4) Music using a phone emission except as specifically provided elsewhere in this section; communications intended to facilitate a criminal act; messages encoded for the purpose of obscuring their meaning, except as otherwise provided herein; obscene or indecent words or language; or false or deceptive messages, signals or identification. There is no exception for transmission of medical or emergency data. Doesn't seem that it could be any clearer. White papers don't override the rules and regs. -- ================== Remove the "x" from my email address Jerry Stuckle JDS Computer Training Corp. ================== |
#6
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On 1/27/2013 1:38 PM, Phil Kane wrote:
On Sat, 26 Jan 2013 20:36:49 EST, Jerry Stuckle wrote: As for "automatic control" - this refers to control for licensed amateur stations. It does NOT include allowing unlicensed operators to control ham transmitters. You will still need a control operator to key the transmitter - which means either someone on site or someone who can otherwise tell when the transmitter needs to be keyed. A non-ham can key (or the digital equivalent) a ham transmitter as long as the control operator is "on duty and in control" to borrow, a phrase from the radio broadcast services rules. We interpret that to mean "in the room and aware of what's happening". 73 de K2ASP - Phil Kane ARRL Volunteer Counsel Sorry, Phil, but what you interpret doesn't count. It's what the FCC interprets. However, I do agree with you that AS LONG AS A LICENSED HAM IS IN CONTROL. This can mean "in the room and aware of what's happening", as long as he can terminate the transmission (i.e. pull the power switch). Plus, if you were to read the whole thread, the comment was that there would not have to be a ham at the location - which does match your interpretation. -- ================== Remove the "x" from my email address Jerry Stuckle JDS Computer Training Corp. ================== |
#7
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On Sun, 27 Jan 2013 20:14:35 EST, Jerry Stuckle
wrote: There is no exception for transmission of medical or emergency data. Doesn't seem that it could be any clearer. White papers don't override the rules and regs. "White papers" when issued by the FCC explain how they intend to apply/interpret/enforce the rules, and are persuasive authority in cases of litigation thereof. Sometimes they make it easier, sometimes they make it more stringent than "black letter" rules. We use a ton of those in procedural cases of waiver requests. 73 de K2ASP - Phil Kane ARRL Volunteer Counsel |
#8
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On 1/27/2013 7:14 PM, Jerry Stuckle wrote:
There is no exception for transmission of medical or emergency data. http://www.hhs.gov/ocr/privacy/hipaa/faq/safeguards/197.html Specifically: For example, the Privacy Rule does not require the following types of structural or systems changes: Encryption of wireless or other emergency medical radio communications which can be intercepted by scanners. Jeff-1.0 wa6fwi |
#9
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On Sun, 27 Jan 2013 20:14:50 EST, Jerry Stuckle
wrote: A non-ham can key (or the digital equivalent) a ham transmitter as long as the control operator is "on duty and in control" to borrow, a phrase from the radio broadcast services rules. We interpret that to mean "in the room and aware of what's happening". Sorry, Phil, but what you interpret doesn't count. It's what the FCC interprets. Sorry, Jerry, my error. I should have said "what the FCC has ruled and expects those of us in the communications legal community to spread the word when necessary". Quite often FCC rule interpretations are buried in case decisions and advice letters. Then again, when I was on the enforcement staff of the FCC I was one of the people who helped formulate that specific interpretation so I do have a "we" investment. 73 de K2ASP - Phil Kane ARRL Volunteer Counsel |
#10
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On 1/28/2013 1:15 AM, Phil Kane wrote:
On Sun, 27 Jan 2013 20:14:50 EST, Jerry Stuckle wrote: A non-ham can key (or the digital equivalent) a ham transmitter as long as the control operator is "on duty and in control" to borrow, a phrase from the radio broadcast services rules. We interpret that to mean "in the room and aware of what's happening". Sorry, Phil, but what you interpret doesn't count. It's what the FCC interprets. Sorry, Jerry, my error. I should have said "what the FCC has ruled and expects those of us in the communications legal community to spread the word when necessary". Quite often FCC rule interpretations are buried in case decisions and advice letters. Then again, when I was on the enforcement staff of the FCC I was one of the people who helped formulate that specific interpretation so I do have a "we" investment. 73 de K2ASP - Phil Kane ARRL Volunteer Counsel Phil, A white paper is not the law. For Amateurs, that is Part 97. Your interpretation is pretty meaningless. That may be how you think the FCC is going to enforce the law today - but that's only for today. A change in FCC staff, administration, etc. can (and in the government, often does) change that. Heck - even pressure from Congress or other agencies like the TSA can change that. It's happened with other agencies all too often. The only rules that count are Part 97. -- ================== Remove the "x" from my email address Jerry Stuckle JDS Computer Training Corp. ================== |
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