Open Letter to All Digital Mode Stakeholders

I have been in Washington with other concerned hams lobbying the FCC in defense of amateur digital modes and Winlink amateur radio email against the attacks of Dr. Ted Rappaport N9NB of NYU and his team. They are relentless in their big-bucks campaign to change Part 97 digital communications rules, to cripple many digital modes, their future development, and to remove radio email from the amateur bands. It’s truly sad.

Search for the latest from them on the FCC.gov/ecfs (electronic comment filing system) under the 16-239 proceeding (the Notice of Proposed Rulemaking to remove the ancient 300 baud symbol rate from the rules). Here is a direct link: https://ecfsapi.fcc.gov/file/1101131173138/DA-19-1130A1.pdf for the FCC Public Notice and request for comment. Their full petition is at https://ecfsapi.fcc.gov/file/10242392005642/NYU%20Wireless%20Petition%20...

The ARRL has published a news article about it here:
http://www.arrl.org/news/fcc-asked-to-clarify-amateur-rules-governing-en...

NYU (Rappaport, et al) seeks a declaratory ruling that section 97.113(a)(4) of the Commission’s rules prohibits the transmission on amateur radio frequencies of “effectively encrypted or encoded messages, including messages that cannot be readily decoded over- the-air for true meaning.” If enacted, it will have immediate and far reaching effects on amateur radio’s digital future (and all future development is in the digital realm, that’s obvious). Comments are now open. I urge you and any stakeholder in a digital mode or amateur radio development to read it and comment. Please forward this information to any stakeholder or group you might think of.

The facts are these: There is no such thing as ‘effective encryption’ and dynamic compression is not encryption, yet the opposition ignores this and continues to spread false information otherwise. State-of-the-art data compression is employed in many digital signals to optimize spectral efficiency. Further, Winlink messages sent over the air can be more conveniently read by any licensed amateur for the purpose of self-policing using our online ‘Message Viewer’ linked from the main page of winlink.org. There is no 'intent to obscure meaning'. Messages can be easily read for full meaning both on-air and on-line. Making all this moot is this: Over-the-air monitoring of Winlink PACTOR 1-3 signals by third party eavesdroppers have been demonstrated and documented using free software available for download from: https://p4dragon.com/en/Downloads.html
See the video at http://www.philsherrod.com/Winlink/Winlink_monitoring2.mp4 for proof. On-air copying of other modes only requires adequate software that can be developed using publicly documented technical details of the mode in question, as was done for the PACTOR software mentioned above.

The petition should be dismissed because there is no need for the ruling demonstrated by the petitioners. The current rules are adequate to enable self-policing of digital modes on the amateur bands.

73,
Lor Kutchins, W3QA
President,
Amateur Radio Safety Foundation, Inc.
Winlink Development Team