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Old 09-04-2019, 07:43   #46
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Re: pactor banned from the usa?

https://winlink.org/sites/default/fi...overletter.pdf

==================================

Chairman Ajit Pai
Federal Communications Commission 445 12th Street, SW
Washington, DC 20554
December 5, 2018
Subject: ex parte Comments on Docket 16-239 (Amateur Radio Symbol Rate NPRM)
Dear Chairman Pai:
6143 Anchor Lane, Rockledge, FL 32955
I am writing on behalf of the Board of Directors of the Amateur Radio Safety Foundation, Inc. We govern the non-profit organization that supports the Winlink Global Radio Emailģ system. We are deeply concerned that the Commission may succumb to an internet and social media campaign led by Theodore Rappaport, resulting in a multitude of comments that echo false and misleading technical points, driven by highly emotional arguments about “national security, crime and terrorism.” Though these arguments have really little to do with the Docket No. 16-239 proceeding, they energize Rappaport's followers and amplify their story. The consequences of granting their requests are severe.
Rappaport has urged you in his letter of last November 15, to defer action on the NPRM in Docket No. 16-239 until the proponents address key issues relating to both homeland security and the future of self-monitoring in the Amateur Radio Service. We have prepared such a response (attached).
Rappaport and those he has inspired to comment also urge the Commission to disallow from the amateur bands advanced digital modes and protocols that are impractical, proprietary, or prohibitively expensive to intercept by a third party. To literally do so would have damaging consequences, including a significant economic impact on a number of small and medium entities in the amateur radio marketplace. It would remove many popular products and services from the amateur bands including Winlink, D*Star data, Fusion, HF- ALE, AMTOR, Clover, ARC-type and digital voice modes that use proprietary codecs or firmware, and others that are hard for a layman to intercept without the use of proprietary hardware, firmware or software.
DHS NCC SHARES, FEMA, MARS, and a myriad of state and local civil authorities, and NGO critical infrastructure partners rely upon licensed amateur radio operators as experts in operations and HF knowledge and as stewards of their stations. If the Commission cuts off amateurs from hard-to-monitor data protocols, they starve the federal government from its operating resources for SHARES, and many, many more programs at various levels of government. These entities have a large investment in their digital stations. Such an action would directly attack two of the Commission's purposes for the amateur radio service: “to expand the existing reservoir of trained operators,” (in fact it would shrink the reservoir), and “...to enhance the value of the service, particularly with respect to emergency communications.” (ß 97.1(b) and (d))
Emissions using advanced digital techniques are difficult, but not impossible to intercept for a knowledgeable, resourceful and skilled developer. As these techniques evolve to be more sophisticated and efficient, they also become more challenging to monitor, especially for a layman. This has been the trend with all ARC (or connected) digital communications over time. As amateurs continue to contribute to the radio art, it is reasonable to expect the trend to continue. To guard the potential for abuse and threats to the nation, the Commission already has safeguards in place (ß 97.305(b)(3) for example). In electronic systems like Winlink near-real-time monitoring can take place off-the-air more effectively, for both discovery and enforcement. Rappaport and his supporters demand the on-air kind of monitoring of content that was sufficient for analog and simple digital modes of the past. They are not sufficient for the future. To the Commission's credit, they have already accommodated the need.
In our attachment we show that within a system like Winlink, our numerous, interested and knowledgeable participants—with the help of smart automation—are doing a better job of monitoring and inspecting hard-to-intercept transmissions than if less knowledgeable operators participated on-air. Over 2500 active, experienced and licensed Winlink sysops inspect their station's daily traffic, and they outnumber the ARRL's volunteer monitors plus they exclusively focus upon the digital band segments we use. Further, administrators and sysops employ powerful tools to search and sort thousands of messages for inspection. All communications are logged in detail and messages are archived, and available to the FCC and anyone else on request. Similar logging and archiving are generally employed by other digital systems we're aware of.
It should be noted that within Winlink, station IDs, message and transaction information are always sent in clear text and can be intercepted easily by laymen on-air using the same equipment and software the sender and receiver use.

Theodore Rappaport and the opponents he informs offer an emotional, layman's conjecture in their assertions that hard-to-monitor, advanced digital protocols used in the amateur radio service will encourage crime, terrorism, and are a threat to national security. They clearly do not know or appreciate what monitoring and inspection routinely occurs, and are thus not qualified to judge. Rappaport himself has never held a Winlink account or ever used one to learn, or rationally evaluate it. He has never participated in the monitoring of Winlink messages. The same is true for almost all the commenters he has inspired.
Rappaport is the source for many distortions of fact on the record. Our attachment also responds to the most egregious untruths. We urge you to study them. These distortions are repeated across the proceeding's comments and should be disregarded and not allowed to color a rational decision-making process on Docket No. 16-239.
The ARSFI board of Directors unanimously support the Commission's proposal in Docket No. 16-239. Our comments to this effect are summarized with support in the attached document.
I and the entire Board remain at your service should any questions arise. Sincerely,
Loring A. Kutchins, W3QA
President
Amateur Radio Safety Foundation, Inc.
Cc: Eric Burger Eric.Burger@fcc.gov
Lisa Fowlkes Lisa.Fowlkes@fcc.gov
Ajit Pai Ajit.Pai@fcc.gov
Rachael Bender Rachael.Bender@fcc.gov Zenji Nakazawa Zenji.Nakazawa@fcc.gov Michael Wilhelm Michael.Wilhelm@fcc.gov Curt Bartholomew Curt.Bartholomew@fcc.gov Erin McGrath Erin.McGrath@fcc.gov
Brendan Carr Brendan.Carr@fcc.gov
Jessica Rosenworcel Jessica.Rosenworcel@fcc.gov Julius Knapp Julius.Knapp@fcc.gov
Ronald Repasi Ronald.Repasi@fcc.gov
Rosemary Harold Rosemary.Harold@fcc.gov Bruce Jacobs Bruce.Jacobs@fcc.gov
Laura Smith Laura.Smith@fcc.gov
Donald Stockdale Donald.Stockdale@fcc.gov Roger Noel (Roger.Noel@fcc.gov)
Scot Stone Scot.Stone@fcc.gov
Attachments:
Comments in Support and Rebuttal of Opponent's Arguments by the Board of Directors of the Amateur Radio Safety Foundation, Inc. (ARSFI_Comments.pdf)
Letter from Theodore Rappaport to Chairman Ajit Pai, November 15, 2018 (Rappaport1.pdf) Letter from Theodore Rappaport to the Commissioners, November 10, 2018 (Rappaport2.pdf)
ECFS – Docket No. 16-239, 17-344, RM-11708, RM-11759
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Old 09-04-2019, 08:17   #47
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Re: pactor banned from the usa?

Winlink is a business and seems to be arguing that the FCC should not interfere in its business model. That usually wonít fly as a reason to reject an NPRM.

This is an interesting saga. I plan to discuss this topic with some of the US most knowledgeable HAMs later today as we are all together by coincidence.
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Old 09-04-2019, 10:37   #48
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Re: pactor banned from the usa?

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Winlink is a business ...
They may be a business, but nothing like the ARRL which is trying to control all aspects of Amateur Radio. Now there is a business model to envy.
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Old 09-04-2019, 14:35   #49
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Re: pactor banned from the usa?

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Originally Posted by transmitterdan View Post
Winlink is a business and seems to be arguing that the FCC should not interfere in its business model. That usually wonít fly as a reason to reject an NPRM.

This is an interesting saga. I plan to discuss this topic with some of the US most knowledgeable HAMs later today as we are all together by coincidence.
So what is Winlinks business model? Sounds more like a volunteer non'profit. The only interaction I've had with them was a free account and there's no advertising.
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Old 09-04-2019, 15:38   #50
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Re: pactor banned from the usa?

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Winlink is a business and seems to be arguing that the FCC should not interfere in its business model. That usually wonít fly as a reason to reject an NPRM.

This is an interesting saga. I plan to discuss this topic with some of the US most knowledgeable HAMs later today as we are all together by coincidence.
Winlink's business model is to provide a free service to connect ham radio operators to the interent, funded by donations of time and money, and is a non profit. These ham radio operators then use this service when there is no alternative, and assist in emergency communications.

And yes, the Winlink organization is arguing the FCC should not shut down this valuable service. The FCC makes these decisions all the time. In fact, their charter is to determine the best use of limited spectrum. The arguments made by the Winlink Organization are absolutely valid and central to the FCC in making their determination.
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Old 09-04-2019, 16:29   #51
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Re: pactor banned from the usa?

dan-
"Since amateur radio cannot be used for business purposes there should be no need for encryption or other means of securing the communications."
Not quite that simple. You may remember that after Katrina, there was some use of ham radio tying into the internet via WEP-protected routers. Which brought up the perennial arguments about hams and encryption. (Of course these days WEP is easily defeated, but it was not so easy then.) The FCC's comments at the time were that the health and welfare traffic should reasonably be protected, and that as long as the WEP passwords had previously been "published" in some manner (like mailing them to the FCC) then the encryption could stand.
This is no new issue. And in fact, hams are still allowed to use codes online. Common case in point, any major marathon with ham stations will use open code such as "Water station five needs more blue gatorade" meaning, WS5 needs the police.
There is a real need for compromise and "reasonable" code talking. But Pactor got started, as I recall, as a radio tool for NATO and military use, so the need for built-in encryption comes from an entirely different audience than ham radio. Which is why the vast majority of Pactor users also can and will ante up and pay prices that hams can't afford.
Hams have a lot of options. This may be an issue that demands a larger and more open discussion, but even if it goes through unopposed, it won't be the end of the world. Yet Another New Digital Mode has been the norm for many years now.
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Old 09-04-2019, 19:03   #52
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Re: pactor banned from the usa?

So I was able to discuss this with several knowledgeable people today but for valid reasons they canít be seen as taking sides. But man did I get an ear full from an FCC friend. The crux of the discussion has lead me to agree with hellosailor. There are valid arguments on both sides. So my advice to those that oppose this NPRM is this:

If you donít want to see more of this type of action get serious about self policing. Donít allow rules to be skirted unchallenged. The FCC does not have resources enough and they depend on the HAM community to discipline its own. They arenít going to get more resources either so itís up to HAMs to preserve the privilege. No one else is going to do it for you. The paraphrased comment I got was ďthe FCC is not your mother, HAMs need to deal with their ownĒ.

For boaters, I think you should seriously consider doing your boating email through marine SSB and something like SailMail. I have come to the view that getting GRIB files using HAM radio isnít really kosher. Thatís not what HAM radio is for IMO. Itís for learning, experimenting and serious life threatening emergencies. It isnít meant as a daily lifeline to the non-HAM world. I realize some will question this last bit. Thatís ok there are arguments on both sides. But if boaters keep tying up lots of spectral & time resources there could be more dire consequences down the road.

Finally, if you are compelled to file comments I applaud that. Make sure your comments are factual, accurate and not personal. Inaccurate reasoning and personal attacks donít carry much weight in Washington, DC.
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Old 10-04-2019, 03:33   #53
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Re: pactor banned from the usa?

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So I was able to discuss this with several knowledgeable people today but for valid reasons they canít be seen as taking sides. But man did I get an ear full from an FCC friend. The crux of the discussion has lead me to agree with hellosailor. There are valid arguments on both sides. So my advice to those that oppose this NPRM is this:

If you donít want to see more of this type of action get serious about self policing. Donít allow rules to be skirted unchallenged. The FCC does not have resources enough and they depend on the HAM community to discipline its own. They arenít going to get more resources either so itís up to HAMs to preserve the privilege. No one else is going to do it for you. The paraphrased comment I got was ďthe FCC is not your mother, HAMs need to deal with their ownĒ.

For boaters, I think you should seriously consider doing your boating email through marine SSB and something like SailMail. I have come to the view that getting GRIB files using HAM radio isnít really kosher. Thatís not what HAM radio is for IMO. Itís for learning, experimenting and serious life threatening emergencies. It isnít meant as a daily lifeline to the non-HAM world. I realize some will question this last bit. Thatís ok there are arguments on both sides. But if boaters keep tying up lots of spectral & time resources there could be more dire consequences down the road.

Finally, if you are compelled to file comments I applaud that. Make sure your comments are factual, accurate and not personal. Inaccurate reasoning and personal attacks donít carry much weight in Washington, DC.
So, Ham radio communications is only for experimenting, learning, and serious life threatening emergencies. Where is that written in any regulations?

Under those guidelines, most of the Ham traffic I listen to, voice or otherwise would be unlawful. Clubs providing communications coordination for events would only be able to help in cases where either the police or emergency care was needed. Typically Ham volunteers for events do far more. Further, there are plenty of alternative land based wireless communications methods, like cell phones and 911. Hams are attempting to provide a public service.

I find no difference between Hams providing safety and security communications for and event and offshore sailors needing Grib files for weather. I assure you, we are not getting Grib files to find out if we need an umbrella today. We need weather information for the safety of the voyage. I get some weather through the marine bands, and I get some from Winlink. Winlink is not my primary source, just one of many. Could I get Gribs through SailMail, or any number of satellite systems, yes. Just as an event committee could use alternates to Ham volunteers.

No sailors that I know think of Ham, and Winlink as their daily lifeline to the world. It's just too slow and clunky compared to numerous other options. Cell towers are almost everywhere, and that is what everyone uses when close to land. Out at sea, beyond the range of cell towers, Ham and Winlink become important for filing position reports and getting Grib files. Could we use SailMail or satellite, sure. However, there is no requirement in any regulations requiring Hams to use other communicaations mediums instead of Ham, when available. Most sailors spend 95% of their time close to land, and use the cell phone system. Once again, sailors do not think of Winlink as their lifeline to the world.

As for tying up bandwidth and time, my position report, and Grib files take up about 3 minutes a day with a Winlink station, a few times per month. Also, not that many sailors cross oceans, and not very many have Ham licenses, and many are switching to satellite. So, we aught to be encouraging Ham use, if there are going to be any Ham operators left, not placing additional restrictions.
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Old 10-04-2019, 06:25   #54
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Re: pactor banned from the usa?

The purpose of amateur radio in the US is clearly spelled out in the FCC regulations part 97 paragraph 97.1. The types of transmissions allowed are in 97.111 and not allowed in 97.113. See: https://www.ecfr.gov/cgi-bin/text-id....5.97&rgn=div5

Please donít misunderstand what I said. My brief summary of the purpose of amateur radio should not be construed narrower than the actual rules as written.

Amateur radio is an important service. I agree 100% that more regulations are not helpful in advancing amateur radio nor do they seem necessary. Hams need to do more to self police else more regulations seem likely.
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Old 10-04-2019, 07:05   #55
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Re: pactor banned from the usa?

This is a tough problem to solve.

I understand the point of amateur radio. In return for use of several parts of the RF spectrum for communications and experimentation, the hams agree not to use bands allocated to amateur use for private undecipherable communications, which would be the gateway for all sorts of commercial exploitation and worse.

I sympathize with the developers of the proprietary compression algorithm - everyone's gotta eat - but if a "compression" scheme can't be deciphered without a proprietary "uncompressor", it is for all intents encrypted, and shouldn't be on ham bands.

What's really required is for some RF spectrum to be allocated to or shared with the services like Winmail. That's what people should really be asking the FCC and other radio bodies for, to make that allocation. Encroaching on ham frequencies with proprietary schemes is doing an end-run.
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Old 10-04-2019, 07:19   #56
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Re: pactor banned from the usa?

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The purpose of amateur radio in the US is clearly spelled out in the FCC regulations part 97 paragraph 97.1. The types of transmissions allowed are in 97.111 and not allowed in 97.113. See: https://www.ecfr.gov/cgi-bin/text-id....5.97&rgn=div5

Please donít misunderstand what I said. My brief summary of the purpose of amateur radio should not be construed narrower than the actual rules as written.

Amateur radio is an important service. I agree 100% that more regulations are not helpful in advancing amateur radio nor do they seem necessary. Hams need to do more to self police else more regulations seem likely.
Thanks for the rules reference. I looked at those paragraphs and they are most helpful. Section 97.111 says:

(a) An amateur station may transmit the following types of two-way communications:

(1) Transmissions necessary to exchange messages with other stations in the amateur service.

This means it's OK to communicate with other hams. There are other sections which talk about communications with non HAMS, which is not pertinent here.

Section 97.113 talks about prohibited communications. Much as we were taught when getting our license, no commercial or broadcast activities allowed. There are many subsections with specifics, but that is the overall idea. The are no restrictions saying we can only talk about ham radio stuff or emergencies.

There is one interesting exception regarding weather, which is as follows:

(c) No station shall retransmit programs or signals emanating from any type of radio station other than an amateur station, except propagation and weather forecast information intended for use by the general public and originated from United States Government stations.

Thus, the regulations specifically call out that weather information provided by the government maybe retransmitted, meaning Grib files. It's OK for sailors to request Grib files.

As for self policing, I agree completely.

Getting back to the original point of limiting encoded digital transmissions, I believe the Winlink organization is doing a fine job. Any message going through their system is decoded and stored by the System Operators. The government , if they wished, could get any and all messages that have gone though the System. This is the only type of communications I am aware of where the government needs no warrant, and no court order to look at the communications of it's citizens. This is the bargain we strike with the government to get our licenses.

The local WestMarine store indicates they have not sold an SSB in 8 years. They have sold lots of Iridium GO, and Garmin Inreach units. An SSB costs between $4k and $5k to install on a boat. A GO cost $700, and an Inreach costs $400. The cost difference buys a lot of satellite airtime. The issue is not too many marine users, but the number of users selecting other options.
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Old 10-04-2019, 08:15   #57
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Re: pactor banned from the usa?

It is ok to rebroadcast weather information. Thatís not the same thing as downloading it for personal use. Itís a fine point I agree. But there is also the further restriction that amateur radio should not be used when there is a reasonable alternative. For getting personal weather gribs there are multiple alternatives to acquire them. The most obvious is a regular licensed HF ship station. Also, as you point out satellite modems are available too.
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Old 10-04-2019, 08:25   #58
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Re: pactor banned from the usa?

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What's really required is for some RF spectrum to be allocated to or shared with the services like Winmail. That's what people should really be asking the FCC and other radio bodies for, to make that allocation. Encroaching on ham frequencies with proprietary schemes is doing an end-run.

There is already spectrum allocated for this in the marine HF bands. Any licensed ship station can use these frequencies. And encryption with modern proprietary coding schemes such as Pactor 3/4 are allowed. You can also conduct business via short emails. It requires payment to a commercial entity. That last bit is part of the debate. People donít like paying for something they can get for free.
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Old 10-04-2019, 08:31   #59
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Re: pactor banned from the usa?

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It is ok to rebroadcast weather information. Thatís not the same thing as downloading it for personal use. Itís a fine point I agree. But there is also the further restriction that amateur radio should not be used when there is a reasonable alternative. For getting personal weather gribs there are multiple alternatives to acquire them. The most obvious is a regular licensed HF ship station. Also, as you point out satellite modems are available too.
The section pertaining to weather is not talking about broadcasting, but retransmitting. If you can't 'download' or listen to it from a transmitting station, what is the point?

Where does it say amateur radio should not be used when there is a reasonable alternative? By that logic, amateurs should pick up the phone instead of the radio.
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Old 10-04-2019, 09:02   #60
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Re: pactor banned from the usa?

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There is already spectrum allocated for this in the marine HF bands. Any licensed ship station can use these frequencies. And encryption with modern proprietary coding schemes such as Pactor 3/4 are allowed. You can also conduct business via short emails. It requires payment to a commercial entity. That last bit is part of the debate. People donít like paying for something they can get for free.
Getting Gribs on marine bands is limited to SailMail. SailMail has many stations worldwide, but not nearly as many stations as Winlink. Given the poor propagation, it is not always possible to reach a SailMail station, where there are usually multiple Winlink stations in range.

Not having up to date weather at sea is scary.

Once again, the Winlink System Operators keep all messages in an unencoded format.
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