FCC Petition RM-11831 Threatens Amateur Digital Operations Like Winlink

April 5, 2019--The FCC has opened for comment RM-11831, a proposal for rule making that would do two things to the US amateur radio rules:

1) remove paragraph (c) of 97.221. This would disallow narrow-bandwidth ARQ modes of 500 Hz or less from outside the specified 97.221 sub bands for automatically controlled digital stations. This will require all US Winlink HF gateway stations, regardless of mode/technique, to only operate within these narrow sub bands.

2) modify the wording of 97.309(4) thusly:
(4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, *such as CLOVER, G-TOR, or PacTOR,* (remove *-*, add the following:) and the protocol used can be be monitored, in it's entirety, by 3rd parties, with freely available open source software, for the purpose of facilitating communications.

This effectively eliminates Pactor 2, 3, and 4 from the US amateur bands unless SCS steps up and publishes complete technical specifications, including their proprietary signal processing methods, and produces an open-source monitoring program allowing on-air eavesdropping by third parties (not likely).

The Winlink Team will have to produce monitoring software for an unconnected eavesdropper for WINMOR, ARDOP. VARA's author must do the same. The alternative is for Winlink to close shop for US licensees on HF amateur bands, or to eliminate B2F compression for messages sent by US-licensed amateurs. This will cause US users of all modes to suffer much longer transmission times by a factor of 2-10 times. Limits would not be placed on other users.

See and read the new proceeding from the link below. The 30-day comment period opened on 28 March. We have prepared a document containing useful arguments you may paraphrase for your comment filing. The formal ARSFI Motion to Dismiss RM-11831 and Petition for Rulemaking is also here for your review.

https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11831&sort=d...

Unless we receive support from users on this serious threat, Winlink may be forced to close shop on HF in the USA. US and non-US users and gateway operators are urged to educate themselves and file a comment soon!

Sincerely,

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

How ITU is strengthening Emergency Telecommunications in the Americas

ITU News Logo

March 5, 2019 -- In 2018, ITU teamed up with regional telecommunications bodies in the Americas such as la Comision Regional Tecnica de Telecommunicaciones (COMTELCA), the Inter-American Telecommunication Commission (CITEL) and the International Amateur Radio Union (IARU) to set up an alternative telecommunication system for use in times of emergencies. The system does not rely on conventional means of communication such as the Internet, but rather on amateur radio systems. The system is Winlink Global Radio Email®️. Read the entire article here.

ARSFI Board Files FCC Response to Rappaport Campaign

December 5, 2018--Today the ARSFI board filed with the FCC a comprehensive response to the online and media campaign that Theodore Rappaport has been leading to get the FCC to dismiss the pending Notice of Proposed Rule Making (Docket No. 16-239). The proposal would eliminate the current 300 baud limit on HF digital transmissions. The original ARRL proposal would replace it with a 2.8 kHz bandwidth limitation. We're in favor of the NPRM plus the ARRL's bandwidth limit (for now, please read our paper) for many reasons, mostly because the advancement of the radio art is impeded without it, but for most Winlink stakeholders it will allow Pactor 4--finally--in the USA. New, faster and better protocols will be close behind.

Rappaport is spreading unrelated emotional fire, claiming that ARC protocols and similar wide-band connected digital modes and modes that are hard, expensive (or need proprietary hardware, firmware or software) to intercept communications on-the-air need to be removed from the amateur bands. He says these modes encourage crime, terrorism and are a threat to national security. His arguments would have the FCC remove Winlink, D*Star, Fusion, and all 'connected' modes not easily intercepted on-air by unskilled operators without a proprietary component in the monitoring equipment—before addressing the 300 symbols/second NPRM. He would set amateurs back 40 years or more with respect to the radio art and digital techniques. We don't have to say how devastating the consequences would be if Winlink and all others using similar modes disappeared from the ham bands.

You can download and read the letter we wrote to FCC Chairman Ajit Pai, our response paper, and Rappaport's two recent letters to the FCC. Make your own decision, but make it an informed decision!

If you have a stake in this, we urge you to please immediately file a comment on the ECFS. It's easy: Click here. Time is of the essence. You don't have to write a masterpiece. An 'express' comment that endorses the ARSFI filing is all that's needed.

Also, spread the word. Send a link to this page to all you know who care, especially those you know in leadership positions with emergency management or government agencies, the ARRL, and organizations and agencies that have a stake in Winlink. Let them know, and ask them to take a few moments to put their opinion on the record, or simply say you agree with us with a reference to our filing.

The ARSFI Board of Directors
Winlink Development Team

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