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Digital Voice Situation in France / European Parliament Petition (Update 1)

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Please sign our European Petition for Digital Voice & Internet Access in France opened to all European Citizen witch requests French Government to respect European Directives 1999/5/CE about "essential requirements" and 2009/140/CE about "fundamentals rights", for all French Amateur Service Operators.

Update 1 (July 1st): Due to new ARCEP decision n° 2010-0537 published on June 30th, about operating rules for Amateur Services in France; we have modified our post to have the corrected links and references. This new ARCEP decision doesn't modify the European Petition for Digital Voice & Internet Access in France and complaint to French Minister of Industry.

Reasons for communication on our activity:
DR@F French Society was invited in "Friedrichschafen HAMRADIO Messe" on last Friday June 25th, by Jochen Berns DL1YBL, Thomas Beiderwieden DL3EL, and Ralf Klingler DF6RK as DARC representatives. DR@F met also Darren Storer G7LWT for RSGB, Erik Finskas OH2LAK (Finland), and was asked about the D-STAR situation in France.

Why this post in English?
Because all European countries asked us to have news on real situation for Digital Voice (D-STAR) in France, and why it's still prohibited. European Service Amateur Operators wants to use their own radio in our country. All European countries allow now Digital Voice modes as APCO25, MOTOTRBO, TETRA and D-STAR with Internet access. France is the last country in Europe to prohibit these new technologies. But if you loan frequency to ARCEP for professional use, you can access to Internet and use all Digital Voice technologies. ARCEP should treat all Radiocommunications Services in a equal manner.

Reference documents:

ARCEP's arguments against Digital Voice in France (eg. D-STAR) are:

  1. Internet : ARCEP says protocol specifications could allow Amateur Service Operators to connect their station to Internet that is against the law (art.5 of decision 2010-0537) ==> DR@F says that all stations in any modes or protocol could be connected with a simple PC with sound card. ARCEP should therefore prohibit all Amateur Services activity in France. We have shown to ARCEP in november 2009, that internet access request could be rejected, with simple filtering in system. We didn't do any connection to Internet at all, as many countries could explain today.
  2. National Security: ARCEP makes reference to "essential requirements" (art.4 topic k of decision 2010-0537) and says D-STAR is a potential national security issue (could cause riot, criminal act, and terrorism), because of internet connexions and specific software for communications to be unencrypted ==> DR@F says that European Directive 99/5/CE in reference of "essential requirements" in ARCEP decision, wasn't raised to avoid national security issue but for "radio equipment and telecommunications terminal equipment and the mutual recognition of their conformity". In the same European Directive - Annex I, Amateur Service Operators that are building their own equipment aren't regarded by this law. In the same way, D-STAR is using codes as GMSK modulation, Ethernet CCITT 802.3, CRC-CCITT, FEC G.975, and ETSI GMR1 & GMR2 for AMBE vocoder, that are fully recognized as ITU standards. In fact, there are no encryption and all standards used are in conformity with French laws.
  3. Patent: ARCEP says AMBE vocoder is using patents, licences and proprietary undisclosed specifications that are against art. 1.56 of ITU Radiocommunications Rules. DR@F says patents are everywhere (PC, Windows, DSP software in commercial radios, firmware, etc ...) and all radio using "super-heterodyne" feature should be immediately stopped with all ham-radio activities in France.

NB: If we apply arguments from ARCEP to amateur radio in France, all activities should stop immediately, because of patent of many equipments and potential connexion to Internet.

Now, ARCEP is telling us that "D-STAR and F7W emission designator are now prohibited in a sustainable manner", for all Amateur Service Operators in France. DR@F says that this decision is illegal, because it has been noticed to only few people and should be delivered as a public decision, signed by Prime Minister.

IF WE CAN'T EXPERIMENT ANYMORE, HOW WILL WE PRODUCE A OPEN SOURCE CODEC ?

DR@F sent his last complaint against ARCEP to Minister of Industry (Mr Estrosi), for illegal decision, discrimination, against human right and individual liberty and unequal treatment. We publish here the last answer of ARCEP and our complain, for all Amateur Service Operators in Europe to be aware.

We're calling all European Ham-radio societies to help us in our battle to allow all Digital Voice modes, Internet access and no restrictive experiment in France. Please put this news with picture into your website and contact us here.

Commentaires

1. Le lundi, juin 28 2010, 23:12 par Neil Bedford

Seeing as all other countries in the world have no problem with digital voice communications, including D-Star, I find it hard to believe a country can disallow its people the same opportunities as the rest of Europe.
D-Star is at the moment, ONLY voice, called DV (Digital Voice) for most users anywhere. Some do use its capabilities to use the Internet, but only remote stations and on the 1300MHz band. Most of these are in the USA too. This 'DD' Digital Data mode is for the 'elite' operators who are mainly just experimenting with its capabilities. DV only carries voice traffic and 'slow data' in the form of the operators Callsign and a few other options to authenticate the user onto the system. GPS data can also be passed, but this is already being done on analogue systems around the globe. (APRS.)

For arguments sake, if only DV is allowed, then this would stop the worry of someone connecting to the internet in an unruly fashion.
I guess that readily available mobile broadband 'dongles' are also outlawed on the mobile phone networks for the very same reason?

2. Le jeudi, juillet 1 2010, 00:52 par Pat

Morse can be used to transmit encrypted & steganographied messages. IT'S EXTREMELY DANGEROUS AND SHOULD BE FORBIDDEN ASAP.

123735, you know...

Crazy !

3. Le jeudi, juillet 1 2010, 18:20 par DF1PAW

This rotten mode should be illegal for worldwide ham radio use due to the proprietary CODEC.
It's not about the chip itself - if you call it a standard anyone should be able to implement it himself. But as the AMBE codec is completely undocumented one may refer to it as encryption ("Security through obscurity") - so does your ARCEP.

So rephrase your petition and urge DVSI to declassify the AMBE codec. Or even better: support the (recently started) development of an open vocoder and don't give a flying fuck on this proprietary DVSI crap.

vy 73 de Andreas, DF1PAW

4. Le mardi, juillet 6 2010, 00:13 par Kristoff Bonne

Hi,

One thing I do not understand.
You say in your petition "DR@F French society will present it to European Parliament in name of all people who signed it"

The EP is part of the "legislative" branch. They make laws. Questions if the descision of a regulator isin conflict with a law are for the JURIDICIAL branch, in this case the national cours in France.

If you think the regulator has incorrectly motivated its regulations, you should challenge them in court.
(of course, it's much cheaper to talk to them first. :-) )

Cheerio! Kr. Bonne.

5. Le mardi, juillet 6 2010, 15:26 par Webmaster

@Kristoff Bonne :Yes you're right. We've also launched a request French procedure.

6. Le mardi, juillet 6 2010, 15:36 par Webmaster

@DF1PAW :Tell me whitch law prohibit to use a patented software or hardware? As well, we support the actual develpment of free vocoder as CODEC2.

7. Le jeudi, juillet 8 2010, 12:01 par OE7FMI

I am not a fan of D-Star and i don´t need it.
I own a D-STAR handheld and testet long enough, and i
am not happy with some technical and organisational attributes of this "mode/system".



Anyway:

If Internet connection is prohibited in France, why Echolink-systems are set up in France ? Operations have to be shut down ?

Do France ham radio operators know, when connecting
to the DX-Cluster via Packet Radio plain AX25, they
are using a worldwide Cluster-System which is cross-connected and available from the Internet also?
Operations have to be shut down ?
Same thing with Packet BBS / FBB Mailbox Messages,
APRS IGATES listening (locally transmitting) on 144.800 and passing Data to the Internet, and some other data tunneling through the Net used for HAM radio purposes.

If equipment with potential internet connection
possibility is prohibited, all amateur operations
have to be shut down immediately, regardless if they are, or are not connected to the internet.

Therefore, the petition should be split in two/three topics:
a) Equipment with the possibility for connection to the Internet
b) Using equipment for amateur radio, that includes patents in soft-/hardware
(Windows PC for digital modes, Commercial Transceiver´s with patented SW/HW parts ...)



c) D-STAR (with the specific AMBE question)

---
If a) and/or b) are rejected, (most) ham radio operations in France have to shut down immediately from a rigid and relentless judicial point of view,
as you stated in your article.

c) If only D-STAR with closed AMBE rejected, this would not harm to france amateur radio at all (probably). Maybe CODEC2 could help to prevent.

I assume, all algorithms (Syntax and semantics) for PSK, ROS, and all the other digital shortwave modes are well documented somewhere.
If not, they would be illegal for use in ham radio in other EU countries aswell.

Sorry guys, but i deliberately asked/wrote in a maybe foolish way.A Ban of D-STAR could be argued, their other comments look like an overshoot of the runway to me.
So what is the judicial point now ?

La discussion continue ailleurs

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