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Old 15-04-2019, 19:03   #136
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Re: pactor banned from the usa?

Thank you Transmitterdan. This has been an interesting thread. Just about as fractured as the amateur community as a whole. It will be interesting to see what actually happens. Lots of smart people on this forum. Smarter than me. Thanks for your input.
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Old 15-04-2019, 23:38   #137
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Re: pactor banned from the usa?

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So it seems the sticking point of the NPRM is that in addition to publishing the specifications of a digital (RTTY) transmission standard, there must also be an open source software available that can decode the transmission into clear text (i.e. eavesdropping code).

I can see the governmentís interest in this rule. They donít want to have to write decoding software for any and all HAM data encoding schemes. I can also see why a commercial company might not like this rule.

So to the specific issue of open source software requirement I have to be slightly in favor of the NPRM. HAM radio is for the purpose of learning and experimenting. Not conducting business.

If a commercial software player wants to withdraw its product from the market because of the open source requirement that is their right. But I think the practical result would be that the open source community would fill the gap by creating software based on the published standards. Thus effectively negating the commercial companyís advantage around the world. Itís usually not a great idea to cut off your nose to spite your face. All these companies have to do is publish an eavesdropping program in source form. They apparently donít have to publish the transmission software and they donít have to provide a particularly nice user interface. Just publish something good enough to allow eavesdropping.

I donít see the reason for so much hand wringing.
Dan you said it best. Algorithm for decoding of any form of transmission used on ham bands must be made freely available to the public. It is the only way to ensure the non-profit, non-business use of the ham frequencies.
Notice I did not include sales of hardware, which of course must remain for profit in the marketplace. The NPRM will have no effect on the modem market since these, and the chips within, are protected by copyright law, and are far too complicated for any but a handful of persons to build for their own personal use.

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Old 16-04-2019, 03:58   #138
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Re: pactor banned from the usa?

Just a clarification. This is not at the NPRM (Notice of Proposed Rule Making) stage. A NPRM is the last stage before a rule is adopted. But right now it is in an earlier comment phase. The proposed rule was not written by the FCC but by an licensed amateur radio operator. So there are more stages in this process before it becomes a rule. I apologize for my earlier error saying it was an NPRM.

I suppose if the open source software required the use of proprietary modem hardware that would satisfy the intent of this proposed rule. So in that case the SCS people should not be too badly impacted.

The other part of the proposal is to limit the use of the higher occupied bandwidth modes (>500Hz) to assigned ACDS bands. A long while back the FCC allowed automatic PACTOR and other digital modes to be used on pretty much any authorized RTTY amateur band. But that was before the higher order modes such as PACTOR III were available. These higher order modes are more reliable and thus favored by many operators. The proposed reduction in spectrum for higher bandwidth ACDS usage seems problematic.

Again, none of this affects cruisers with an FCC shipís station license using type approved marine band radios. They can use SailMail as they always have.
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Old 16-04-2019, 07:24   #139
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Re: pactor banned from the usa?

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Notice I did not include sales of hardware, which of course must remain for profit in the marketplace. The NPRM will have no effect on the modem market since these, and the chips within, are protected by copyright law, and are far too complicated for any but a handful of persons to build for their own personal use.
The chip inside the PACTOR modems is an off-the-shelf DSP processor. Anyone can buy it. The complicated stuff is all in the firmware and disclosing the finer points of the adaptive filtering and the rest of the protocol would certainly make the design vulnerable to copying. As we have seen, in some countries patents and copyrights are absolutely no protection against outright copying and production.

I doubt that anyone is going to reverse-engineer or duplicate this SCS design for their own personal use, but I can easily see a foreign business having some smart DSP engineers read this desired disclosure and clone the SCS PACTOR modems. SCS already did the hard part, and there is no lack of smart engineers in China who could take it from there.
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Old 16-04-2019, 07:43   #140
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Re: pactor banned from the usa?

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The other part of the proposal is to limit the use of the higher occupied bandwidth modes (>500Hz) to assigned ACDS bands. A long while back the FCC allowed automatic PACTOR and other digital modes to be used on pretty much any authorized RTTY amateur band. But that was before the higher order modes such as PACTOR III were available. These higher order modes are more reliable and thus favored by many operators. The proposed reduction in spectrum for higher bandwidth ACDS usage seems
Yes, This seems to be a squabble over who gets to use portions of the ham bands. Nobody wants interlopers trespassing in *their* segment. And there is good reason for band management -- perhaps this needs to be resolved.

But the proposal is draping itself in the "national security" flag, imagining all the possible ways that this technology could be abused by evildoers. At the same time it fails to present any actual evidence that this is indeed a problem, and it ignores the fact that there are essentially limitless and much easier ways for bad guys to engage in clandestine communications.

This proposal basically throws against the wall whatever objections it can dream up, no matter how ill-founded or counterproductive they may be, hoping something will stick.

To give them credit, they stopped short of claiming that "PACTOR smells and its mother dresses it funny."
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Old 16-04-2019, 09:37   #141
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Re: pactor banned from the usa?

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Yes, This seems to be a squabble over who gets to use portions of the ham bands. Nobody wants interlopers trespassing in *their* segment. And there is good reason for band management -- perhaps this needs to be resolved.

But the proposal is draping itself in the "national security" flag, imagining all the possible ways that this technology could be abused by evildoers. At the same time it fails to present any actual evidence that this is indeed a problem, and it ignores the fact that there are essentially limitless and much easier ways for bad guys to engage in clandestine communications.

This proposal basically throws against the wall whatever objections it can dream up, no matter how ill-founded or counterproductive they may be, hoping something will stick.

To give them credit, they stopped short of claiming that "PACTOR smells and its mother dresses it funny."
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Old 16-04-2019, 13:08   #142
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Re: pactor banned from the usa?

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Yes, This seems to be a squabble over who gets to use portions of the ham bands. Nobody wants interlopers trespassing in *their* segment. And there is good reason for band management -- perhaps this needs to be resolved.



But the proposal is draping itself in the "national security" flag, imagining all the possible ways that this technology could be abused by evildoers. At the same time it fails to present any actual evidence that this is indeed a problem, and it ignores the fact that there are essentially limitless and much easier ways for bad guys to engage in clandestine communications.



This proposal basically throws against the wall whatever objections it can dream up, no matter how ill-founded or counterproductive they may be, hoping something will stick.



To give them credit, they stopped short of claiming that "PACTOR smells and its mother dresses it funny."
Both sides are making arguments that defy logic. But the rules are there to prevent a problem. A lot of people think that rules should only be enforced when there is a demonstrated need. Thatís not how the law works. In fact, under US law there can be problems enforcing rules ďarbitrarilyĒ. So the security issue is a bit more complex that we might wish it to be. Even if we donít know of ďevil-doersĒ using ham radio for nefarious purposes the rules exist for that reason as well as others.
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Old 17-04-2019, 08:56   #143
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Re: pactor banned from the usa?

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Just a clarification. This is not at the NPRM (Notice of Proposed Rule Making) stage. A NPRM is the last stage before a rule is adopted. But right now it is in an earlier comment phase. The proposed rule was not written by the FCC but by an licensed amateur radio operator. So there are more stages in this process before it becomes a rule. I apologize for my earlier error saying it was an NPRM.

I suppose if the open source software required the use of proprietary modem hardware that would satisfy the intent of this proposed rule. So in that case the SCS people should not be too badly impacted.

The other part of the proposal is to limit the use of the higher occupied bandwidth modes (>500Hz) to assigned ACDS bands. A long while back the FCC allowed automatic PACTOR and other digital modes to be used on pretty much any authorized RTTY amateur band. But that was before the higher order modes such as PACTOR III were available. These higher order modes are more reliable and thus favored by many operators. The proposed reduction in spectrum for higher bandwidth ACDS usage seems problematic.

Again, none of this affects cruisers with an FCC shipís station license using type approved marine band radios. They can use SailMail as they always have.

The change is intended to force ALL ACDS into the existing 2.8 kHz segments, rather than pushing for the creation of a 500 Hz ACDS segment like most of the rest of IARU Region 2 has . That as much as the rest, will reduce the effectiveness of Amateur Radio for EmComm interoperability.
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Old 17-04-2019, 12:41   #144
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Re: pactor banned from the usa?

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The change is intended to force ALL ACDS into the existing 2.8 kHz segments, rather than pushing for the creation of a 500 Hz ACDS segment like most of the rest of IARU Region 2 has . That as much as the rest, will reduce the effectiveness of Amateur Radio for EmComm interoperability.
Is it not the case that in a real emergency (ala Katrina) the FCC allows more flexible amateur spectrum for Emcomms?

I think hams are also up against the big telcos who want to be the emergency comms provider with their portable mesh cell sites. And they want to make $ on their investment. Thatís the undercurrent I read in the comments.
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Old 17-04-2019, 16:05   #145
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Re: pactor banned from the usa?

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Is it not the case that in a real emergency (ala Katrina) the FCC allows more flexible amateur spectrum for Emcomms?

I think hams are also up against the big telcos who want to be the emergency comms provider with their portable mesh cell sites. And they want to make $ on their investment. Thatís the undercurrent I read in the comments.

It's not that simple, to be honest. It's actually better from a emergency preparedness standpoint to have everything functional and usable at all times than to have to delay sending emergency traffic because some assets were unavailable and you have to update the software to be able to make use of them.
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Old 17-04-2019, 17:24   #146
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Re: pactor banned from the usa?

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It's not that simple, to be honest. It's actually better from a emergency preparedness standpoint to have everything functional and usable at all times than to have to delay sending emergency traffic because some assets were unavailable and you have to update the software to be able to make use of them.
So you are saying that hams would only use the expanded spectrum for emergency communications or training for such emergencies? If that is the case then perhaps the FCC would be willing to make such an accommodation.
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Old 17-04-2019, 18:25   #147
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Re: pactor banned from the usa?

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Old 18-04-2019, 05:35   #148
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Re: pactor banned from the usa?

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It's not that simple, to be honest. It's actually better from a emergency preparedness standpoint to have everything functional and usable at all times than to have to delay sending emergency traffic because some assets were unavailable and you have to update the software to be able to make use of them.
I fully agree with you on that.

What do you think would happen if the Winlink ACDS stations refused all encrypted messages and then, instead of keeping a log of messages, automatically posted all messages sent via Winlink on amateur frequencies to a public web site? Maybe then some of the arguments raised in the RM proposal would be punctured.
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Old 18-04-2019, 08:31   #149
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Re: pactor banned from the usa?

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I fully agree with you on that.

What do you think would happen if the Winlink ACDS stations refused all encrypted messages and then, instead of keeping a log of messages, automatically posted all messages sent via Winlink on amateur frequencies to a public web site? Maybe then some of the arguments raised in the RM proposal would be punctured.

Well, there is this now. https://winlink.org/content/us_amate...message_viewer


Unfortunately, since it's not over the air copy, the petitioner and some others still are satisfied.
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Old 18-04-2019, 10:55   #150
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Re: pactor banned from the usa?

Wow. The Winlink message viewer is very interesting. I didn't know it existed. So it is possible to view the entire message log, and each message in the system. It sure makes this look very open and entirely keeping with the intent of the current regulations. I did a quick check and found that messages easily attributed to sailors are 13 of 100 messages that I looked at. Almost all of these messages were weather related. Retransmission of weather is a specific allowable carve out in the current regulations. I found no evidence of copious use of Winlink for regular email which could be carried by commercial services (current regulations) in the 100 emails I looked at. The Winlink message viewer is a great addition.
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