[GreenKeys] Comments Provided to the FCC in support of George Hutchison's Widecast RTTY Broadcasting Project

[Roy Norris]

August 24, 2003





Federal Communications Commission
445 12th  Street, SW
Washington, DC 20554

Re:   Comment on RM-10765 and Proceeding PRM03ET

Petition For Rulemaking To Establish, Administer, and Regulate The Homeland 
Public Press And Information Widecast Service



Dear Sir or Madam:

I respectfully submit the following comments in support of Proceeding 
PRM03ET and RM-10765.

Background
Radio Teletype as a means of communication served as the primary means for 
disseminating news and weather information throughout the world for a 
period of over 60 years.  It further served as a primary means of 
communication for our Military during two world wars and the Korean and 
Vietnam conflicts.  It's long running success was due to its robustness as 
a means of communication, and, unlike radio transmissions of voice, Morse 
code, or video, it inherently produces a permanent written record of the 
information transmitted.

Today, the Internet and high speed secure data networks have largely 
replaced Radio Teletype.  While these newer communications vehicles offer 
much higher speeds and bandwidth, they are vulnerable to outage due to 
power failures and security compromises of the Internet, and fail to offer 
the key advantages provided by radio Teletype: 1) robustness of the 
communications mode and 2) an inherent written record provided of the 
information communicated.

Public Security Considerations in a Regional or National Emergency
In the post 9/11 domestic security environment, there exists a need for 
multiple robust forms of communications of news, weather, and Department of 
Homeland Security alert status and advisories to the public at 
large.  Multiple channels are desirable because such infrastructure 
channels as the Internet, and traditional AM/FM radio broadcasts and TV can 
be compromised by major regional power outages as occasioned by inclement 
weather or as was recently shown, through a failure of the power grid over 
a large portion of the contiguous United States.
With traditional AM/FM radio broadcasts or television, an individual must 
be present and tuned in at the time the information is transmitted in order 
to hear what is broadcast by voice or image, or use automated recording 
equipment such as a video tape recorder.  The Internet requires the user to 
have computer equipment, a modem, and access to a functioning telephone 
line, TV cable, or home satellite receiver, and a functioning Internet 
provider as a portal to the network.  Furthermore, AM/FM broadcast radio, 
television, and the Internet are all dependent on the normal functioning of 
the electrical power grid.  Many communications infrastructure facilities 
do not have back-up electrical power generators for use in the event of a 
large-scale electrical power failure.

In the event of a National Emergency coupled with a wide spread electrical 
power outage, many of the sources, as well as transmitting and receiving 
devices, for news and weather information become unavailable.  Thus radio 
and television broadcast stations may not be able to obtain up to date 
news, weather, and Department of Homeland Security alerts and advisory 
information from their primary sources during such an emergency.

Radio Teletype Widecast transmissions on the high frequency radio band (2 
to 30 MHz) have the ability to provide a backup means for disseminating 
news, weather, emergency information, and Department of Homeland Security 
alerts and advisories, throughout the United States from a small number of 
transmitting stations.  Radio Teletype Widecast service can provide this 
information throughout the United States on a continuous basis without 
depending on the country's traditional infrastructure including the 
electrical power grid, the Internet, the telephone system, and the 
thousands of individual AM/FM Broadcast and TV stations in the US.

Traditional AM/FM radio broadcast stations and television stations depend, 
themselves, on the Internet and the telephone system for their news, 
weather, and emergency information sources. In a national emergency or 
large regional power outage, many of these stations would not have access 
to news or emergency information.  However, one single Widecast station 
anywhere in the United States with access to news and Homeland Security 
alert status and advisories can feed all other Widecast stations through 
its radio Teletype transmissions.

Simple Equipment for Reception
Today, the reception of radio Teletype signals by the general public no 
longer requires expensive, heavy, and complex specialized equipment.  Any 
personal computer or lap top computer with a sound card can receive radio 
Teletype signals using free and widely available software and a short wave 
radio receiver.  Short wave radio receivers are now available in the form 
of a moderate cost computer card that plugs into any personal or laptop 
computer.  Further, low cost, battery operated short wave receivers are 
widely available.  Suitably equipped, any laptop computer becomes a 
portable, battery operated, radio Teletype reception system.

Additionally, many ham radio operators, short-wave radio enthusiasts, and 
Teletype enthusiasts have existing and fully operational radio Teletype 
equipment in their possession at the present time.  As demonstrated by the 
survey that accompanied the Petition for Rulemaking as an appendix, there 
were a large number of individuals who regularly copied the experimental 
Widecast service during the 2-year term of its Experimental License from 
the FCC.

In the event of a National Emergency accompanied by a wide spread power 
outage or compromise of the Internet, radio Teletype transmissions provided 
by the Homeland Public Press and Widecast Information Service could provide 
an important source for news and emergency information while other means of 
dissemination  of news, weather, and Department of Homeland Security alert 
status and advisories were unavailable or inoperable.


Current Printed News for the Blind
Blind people today depend primarily on AM/FM radio broadcasts and 
Television for news and weather.  Unfortunately, this requires the 
individual to be present and tuned in to receive this information.  Also, 
if something is missed or misunderstood, there is no copy available for 
review.  Radio Teletype transmission can be printed using a Braille printer 
thus creating a permanent record of the information which can be read or 
re-read at ones leisure.  The Homeland Public Press and Widecast 
Information Service would provide a practical and inexpensive way for blind 
people in the US to receive regular, up to date, current news and weather 
information in a printed format on a daily basis; a virtual newspaper for 
the blind.

Due to the fact that the average number of blind people within the 
listening range of the typical AM/FM broadcast station is small, it would 
be impractical to offer such a service on a local basis.  However 
considering the national audience that could be reached by the Homeland 
Public Press and Widecast Information Service transmitting on HF radio 
frequencies, provision of printed news and information service for the 
blind is immanently practical.

Since many Internet web pages for news and information contain a great deal 
of graphical content, they are not generally suitable for printing with a 
Braille printer.  The "text only" nature of the radio Teletype used by the 
Homeland Public Press and Widecast Information Service makes it ideal for 
printing on a Braille printer.


News and Information Service for Off Shore Fishing Vessels and Pleasure Craft
When an off shore fishing vessel or pleasure craft is out of range of local 
AM/FM broadcast radio and television, there is no current means provided 
for the reception of alert status and advisories provided by the Department 
of Homeland Security, even though such information could be critical for a 
vessel planning to enter a US port.  The Homeland Public Press and Widecast 
Information Service would provide a practical and inexpensive method for 
off shore vessels to obtain this important information, news, as well as an 
alternate source of weather data and storm warnings.

News and Information Service for Recreational Vehicles, Motor Homes, and 
Long Haul Trucks
By their very nature, vehicles such as recreational vehicles, motor homes, 
and long haul trucks spend a great deal of their time in motion where the 
only access to news, weather, and emergency information is through radio or 
television.  No permanent record or printed copy is generated for reading 
or available for consumption at a time other than at the time it was 
broadcast.  The Homeland Public Press and Widecast Information Service 
would provide for reception of printed news media, weather, and emergency 
information in moving vehicles on a national basis by tuning to one of 
several standard HF frequencies while underway.

Summary
In summary, the proposed Homeland Public Press and Widecast Service 
provides for a host of needs not presently being met by the standard 
communications methodologies currently in use today.  In a period where the 
transmission of emergency information to the public at large may save lives 
and prevent injury from causes as varied as terrorist attack or off shore 
hurricanes, the proposed Homeland Public Press and Widecast Service would 
provide an alternative communication channel capable of reaching the public 
on a national basis from only a few transmitting stations which are not 
dependant on the proper functioning of large scale infrastructure such as 
the electrical power grid, national telephone system, and Internet.  As 
such, the Homeland Public Press and Widecast Service would be a vital 
element in our overall security and communications apparatus that would 
insure the ongoing provision of news, weather, and emergency information 
when other more infrastructure dependent communications channels were 
unavailable.  I respectfully ask for the Commission's full support and 
approval of this important new service and support to our Homeland security.





Sincerely,

Roy H. Norris