According to an article on the website Mission Critical Communications, a noted amateur radio operator and electrical engineering professor, Theodore Rappaport, N9NB, thinks that “the FCC is putting national security at risk by not enforcing amateur radio rules.” In a filing on the Notice of Proposed Rulemaking (NPRM) 16-239, which would remove baud rate limits for digital modes on the HF bands, Rappaport says that the FCC should first address ongoing amateur radio rule violations, specifically, the use of obscured, private messaging, as they create national security concerns.
N9NB writes, “If allowed, NPRM 16-239 would perpetuate the current violations and would authorize obscured transmissions of unlimited bandwidth over the global airwaves, further increasing the danger to our national security, since these transmissions cannot be intercepted or eavesdropped by other amateur radio operators or the FCC.”
The article also notes:
The filing said public records clearly show how the evolution of undocumented, proprietary transmission technologies such as PACTOR and Winlink, ARDOP, Winmor, STANAG and other HF transmission schemes that use controlling software have created a national security problem in the amateur radio service. Third parties, including other ham radio operators or the FCC listening stations, cannot intercept and decode over-the-air transmissions when used in the popular automated repeat request (ARQ) mode.
There’s a heated debate about this over on Hackaday, but there the debate seems to be centered on the proprietary (or not) nature of PACTOR. There’s also been some discussion of this issue on the CWOps mailing list. There, the discussion seems to be centered on the possibility of all these unattended, automatic, wide-bandwidth digital stations being unleashed on and taking over the CW portion of the bands. And for what purpose? So, some boaters can send email.
I think that some of these concerns have some merit. If these transmission really can’t be monitored, then they could be put to nefarious use. But, if there was any evidence of that happening, I’m sure that the FCC and other agencies could quickly obtain that capability.
I’m also not too keen on unattended digital stations taking over the CW bands. Call me naive, but I don’t really see that happening. Much of the band is going unused, and certainly there s room for more digital communications. And, if it does prove to be a problem. we could petition for the rules to be changed again.
Having said that, there is some merit in allowing wider bandwidth digital communications. Much of the emergency communications provided by amateur radio operators in the wake of Hurricane Maria in Puerto Rico last year was conducted using WinLink.
What do you think? Should I be up in arms about this? Is this actually going to kill ham radio, or is it much ado about nothing?
Ed K8CSBV says
After watching “Pine Gap” on Netflix, I say this is crazy…good show, but they intercept anything they want to, if they need to.
AJ3DI says
much ado about nothing,
EXCEPT progress…..
and
advancement of the radio arts.
Ron says
Advancing the radio arts with 10 year old digital modes and a network architecture
straight out of the 1980’s is sure progress…..
Joshua | DC7IA | KK4RVI says
If you want to transport hidden information you could just use the Signal messenger.
Why bother sending it using amateur radio?
Janis Carson AB2RA says
When Steve Waterman (of Winlink) says on page 4 of his Puerto Rico proceeding: ““For example, how much high-speed data at 2.4 KHz (Pactor 3) can be sent and received on the 40 Meter Part 97 spectrum totaling an allowable 5 KHz total? But what about about two, three or a hundred such stations all operating simultaneously?” I take him at his word. He intends to install one hundred 2.4 KHz email store and forward stations on 80, 40, 20, and other bands. Do the math.
https://ecfsapi.fcc.gov/file/10123298305905/%2017-344.pdf
The ARRL petition asked for 2.8 KHz, and the FCC’s 16-239 gave them “unlimited band width”. These store and forward stations occupy a channel, assigned for their own use, just like any VHF repeater, in violation of:
“97.101 General standards. (a) In all respects not specifically covered by FCC Rules each amateur station must be operated in accordance with good engineering and good amateur practice. (b) No frequency will be assigned for the exclusive use of any station.”
Techniques that work OK on VHF don’t work on HF; that’s why no voice repeaters are allowed below 29.5 MHz.
There is no realistic method to decode the body of an email or an attachment sent in this fashion, which contrary to FCC policy: “To ensure that the amateur service remains a non-commercial service and self-regulates, amateur stations must be capable of understanding the communications of other amateur stations.”
http://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0918/DA-13-1918A1.pdf
Significantly, this quote is from a Report & Order dismissing RM-11699, which the same Waterman comments seek to resurrect. The Winlink website has a lot of information for blue water sailors. The Seven Seas Cruising Association has filed comments. All of us support legitimate emergency communications. But is it the responsibility of the rest of us to subsidize free email for 12,000 sailors by donating all of our HF DATA segments? Walk from your boat slip downtown with a tin cup and a hand lettered cardboard sign to get coins from commuters to pay your $20 Sailmail monthly fees. Give me a break. FT8 is progress. So is Codec 2 digital voice. Both are open source and decodable. The ARRL threw you all under the bus, so it could promote this. It will not easily be undone if 16-239 passes.
Lauren Libby W0LD says
If the digital modes are not transparent to other amateur operators or FCC monitors then they could pose a risk.
Steve~W8SFC says
I speak from what I know, and the truth is with the number of methods and processes being used in communications on RF it is extremely difficult to detect, decode and determine the content of an individual message that has been encrypted from the massive total amount of traffic within the spectrum that amateur radio is only a part of.
For relatively little investment it has become possible to inject a transmission directed at a specific target receiver at a specified time by automated means just about anywhere within the RF spectrum, so why would amateur radio be left out by those with nefarious intent? The whole purpose of the NSA is to monitor such radio traffic across the entire known RF spectrum, and it takes billions of dollars in facilities equipment and personnel to get the job done, and still they can’t be certain of intercepting and decrypting every conceivable message and then analyzing it to determine what action if any is prudent or necessary prior to the expiration date of the information. From that standpoint I can understand the concern, but as a practical matter, since satellite and other microwave and ULF signals are so difficult and or expensive to use, only international government entities can work in that arena. Most of this if not all of this activity is not done in the amateur radio bands, mainly because of the ease of interception; if a guy in his spare room with an HF rig, a PC and an antenna can accidentally tune in one of the digital mode messages that are sent in rapid bursts, and that when processed for audio sounds like a warble or a growling noise that takes less than a second or two to transmit, why would someone with sinister intent use that part of RF to conduct their business? Some one is bound to record such a signal and with all the interest in digital modes today, there isn’t much chance of your secret staying secret for long. That is why state actors don’t use the shortwave part of RF much anymore. They have all gone with much higher or extremely low frequencies that cost a lot more to access in personnel, equipment and computing power (the reason super computers were invented).
I think that there is a possibility for terrorists to use the amateur band, but they have more discrete means available today in cellphone technology that has a very low threshold of operator skills to use, and they have been known to employ more low tech means such as couriers. As far as I know there has not been a recorded instance of international terrorists using ham radio.
Of course if this has happened that would be classified and need to know – and the subject of another Jack Ryan novel by Tom Clancy.
Is this a threat to amateur radio? That question lies in the decisions FCC and other government agencies make. I don’t think that amateur radio is jeopardized by this because of the reliance of all levels of government on amateur radio operations assistance with emergency and disaster response communications. As long as we have the numbers in the ranks of licensed amateur radio operators I think it only serves the government to continue supporting amateur radio and not restrict access.
73!
Brennan Price N4QX says
Those who actually work in the national security field are more than capable of deciphering anything that we can imagine sending on any mode we can imagine using. Does anyone actually believe the government doesn’t have a few thousand Pactor 4 modems in operation?
This type of claptrap only feeds into some skeptical countries’ lack of support of amateur radio, on the grounds it can be used for people against government interests. This is true about anything that emits RF, sends signals down copper or fiber, or even a printing press. I’ve fought that war. It’s hard enough without friendly fire.
Lee McVey, W6EM says
I do, for one, doubt that the feds have a few thousand P4 SCS modems. If they did, they would have acknowledged, by now, their abilities to do so. “Unofficial” comments from FCC and federal law enforcement have stated that they cannot decode PacTors 2, 3 or 4. SCS offered examples of very high priced software that supposedly could. But, only available to the likes of NSA, CIA, etc., for prices approaching $20K. Even if those agencies could use he software, could they afford the resources to monitor and decode Winlink emails flying back and forth all over the place?
As for SCS modem users generally, even their modem instructions effectively say that once stations are using ARQ, almost impossible for a third party to make any sense of message content or attachments. Not at all like X.25, which can be effectively monitored.
Brennan Price N4QX says
“There, the discussion seems to be centered on the possibility of all these unattended, automatic, wide-bandwidth digital stations being unleashed on and taking over the CW portion of the bands. And for what purpose? So, some boaters can send email.”
Automatically controlled digital stations of the bandwdths we’re talking about are confined to portions of the bands that have been identified in the regulations for decades.
Come on, Dan. Not everyone knows better, but you do.
Dan KB6NU says
What portions? Part 97.305 says that RTTY and data transmissions are allowed from 7.000 to 7.100 MHz.
Brennan Price N4QX says
47 CFR 97.221.
Janis Carson AB2RA says
Dan is correct. ARRL’s petition and FCC 16-239 will allow wide band automated email store and forward stations ANYWHERE in the HF “data” segments. This will exterminate FT8 and narrow band (500 Hz) human to human modes. The FCC NPRM says:
“While we tentatively conclude that a specific bandwidth limitation for RTTY and data emissions in the MF/HF bands is not necessary.”
Dr. Rappaport reported his observations of a possible problem. See something, say something. He is not motivated by monetary gain. Some of his detractors are. Amateur radio was shut down in WW1 and WW2 for security issues. It only takes one incident for that to happen again. Amateur radio MUST continue to be self monitoring to prevent nefarious and commercial content. If all transmissions can be freely decoded, the size of the haystack is much smaller; the needle of illegal content is easier to find and eliminate.
The FCC recently prohibited the sale or importation of Chinese transceivers which could be programmed to transmit on public service frequencies, exposing them to risk of interference or false and deceptive signals. This is another example of the FCC proactively preventing bad outcomes with prudent regulations.
The FCC now needs to revisit the “ordering pizza on the 2 meter auto patch rule” since it has escalated beyond reasonable legal uses of amateur radio. It should take action to reject 16-239 as written, and do major revisions to regulate “by band segment” instead of ineffective “by band width”. The FCC should also quickly begin a Rule Making for a petition to ensure signals can be decoded off air and prevent automatic operations outside the ACDS segments, as Dr. Rappaport has recommended. The legitimate needs of emergency communications can be served by this, and a fair debate about the size of the ACDS segments could follow. By eliminating the commercial misuse of amateur radio, the size of those ACDS segments would not be all of the spectrum for free HF email for consumers that does not meet 97.1 goals.
Brennan Price N4QX says
“Dan is correct. ARRL’s petition and FCC 16-239 will allow wide band automated email store and forward stations ANYWHERE in the HF “data” segments. ”
Balderdash, batsqueeze, and rot. The plain language of 97.221 limits the bands in which automatic transmissions of more than 500 kHz bandwidth to certain segments.
Janis Carson AB2RA says
If N4QX doesn’t believe me, he should believe Steve Waterman (of Winlink) who says on page 4 of his Puerto Rico proceeding: ““For example, how much high-speed data at 2.4 KHz (Pactor 3) can be sent and received on the 40 Meter Part 97 spectrum totaling an allowable 5 KHz total? But what about about two, three or a hundred such stations all operating simultaneously?”
https://ecfsapi.fcc.gov/file/10123298305905/%2017-344.pdf
ARRL and Winlink and its supporters want 240 KHz. Nobody is against emergency communications having the tools it needs to accomplish their mission. That activity does not require the amount of spectrum in 16-239. Free HF email for yachts is the reason that SSCA and others are pushing this.
Brennan Price N4QX says
ARRL wants no such thing and has asked for no such thing. No changes to Section 97.221 were sought in the petition or are under consideration in Docket No. 16-239.
It’s not a matter of not believing you; it’s a matter of you being willfully wrong.
Janis Carson says
The extensive quotes below are rebuttal to the accusation of rot. The wording in the official documents is circular, but read the FCC filing instead of blindly listening to talking points or ARRL FAQ. Please inform yourself on the issues if you are going to make these claims. 16-239 says:
“Consequently, we propose to remove the baud rate limits in
Section 97.307(f). (Which says)
97.307 Emission standards.
(f) The following standards and limitations apply to transmissions on the frequencies specified in §97.305(c) of this part.
97.305 Authorized emission types.
(c) A station may transmit the following emission types on the frequencies indicated, as authorized to the control operator, subject to the standards specified in §97.307(f) of this part.
97.307 Emission standards.
(f) The following standards and limitations apply to transmissions on the frequencies specified in §97.305(c) of this part.
(3) Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The symbol rate must not exceed 300 bauds, or for frequency-shift keying, the frequency shift between mark and space must not exceed 1 kHz. (Applies to HF up to 15 meters)
(4) Only a RTTY or data emission using a specified digital code listed in §97.309(a) of this part may be transmitted. The symbol rate must not exceed 1200 bauds, or for frequency-shift keying, the frequency shift between mark and space must not exceed 1 kHz.
(Applies to 10 meters only)
The above 97.307(f) standards apply to the table of amateur frequencies, as shown in the right hand margin.
The 300 baud frequencies in the chart they apply to are the
ENTIRE DATA SEGMENT. The FCC decided to go further than the ARRL request of 2.8 KHz to unlimited band width everywhere. This is exactly as the ARRL petition requested in their petition. “Specifically, ARRL proposes to delete all references to symbol rate from Section 97.307(f) of the Commission’s rules; to create a conforming amendment to Section 97.305(c) of the rules; and to establish a bandwidth limit of 2.8 kilohertz for Amateur data emissions below 29.7 MHz.”
In the APPENDIX, they delete paragraph 4 above applying to 10 meters, and replace paragraph 3 wording with “The authorized band width is 2.8 KHz.”
THERE IS NO REFERENCE WHATSOEVER IN THE FCC 16-239 OR THE ARRL PETITION TO CONFINE THOSE CHANGES TO ONLY 97.221 FREQUENCIES.
16-239 and RM-11708 effectively abolish 97.221. The other mistake they make is they left 20 KHz for VHF and 100 KHz for UHF, while deleting band width specs for HF. The entire DATA segment could be taken by a SINGLE SIGNAL under 16-239. If the FCC retreats to the 2.8 KHz, Waterman will still put 100 signals on 40 meters, so do the math. Either way, the amateur community that uses FT8 or narrow band modes is officially screwed.
http://wireless-girl.com/ARRL_RM11708FAQ.html
Brennan Price N4QX says
Outside of the 97.221 segments, wide bandwidth data transmissions cannot be automatic. That’s true now, and it will be true if the NPRM is adopted as either the ARRL or FCC has proposed. Claims that *automatic* wideband transmissions would be allowed throughout the data segments are simply false.
Brennan Price N4QX says
“Waterman will still put 100 signals on 40 meters, so do the math.”
That would be an enforcement problem. We’re it to happen, I’d be in line to complain.
Rules are made presuming compliance, and that’s a good thing for amateur radio. “Don’t allow someone to do this because s/he will be a bad actor” is applicable to anybody and any activity in the whole of amateur radio. You give that argument credit, and you strengthen it for spectrum seekers to use it against us.
Fear of corner enforcement cases is no reason to maintain a rule that is several generations removed from the state of the art.
Anonymous says
Brennan, honestly – are you being serious?
https://www.arrl.org/files/file/Public%20Service/ARRLmouUSPS.pdf
Amd look at this- below- just out a few hours ago- it is ALL ABOUT free private HF EMAIL for boaters, many unlicensed or merchant marines, or government entities paying “donations” for the Winlink s/w on the backs of hams and the ham radio HF spectrum, but Winlink and ARSFI don’t ever admit it, as they hide under “emcomm” guise. Look at the ARSFI form 990 and the $200K cash hoard and $100k revenues last year from “donations” for their free private email service.
Hams should urgently write congress about this illegal use of ham spectrum, that cannot be decoded over the air, and which is improperly being used to conduct business and to bypass other means of commercial email on the high seas. Many violations of FCC Part 97! occur daily. Dr. Rappaport showed these to the FCC in Sept. 2016 when he visited them, and things have only gotten worse.
More nasty attacks to and desire for free wideband email sure to come on the FCC website in the coming week, put out by the boater networks. See below.
https://winlink.org/FCC_Action
Anyone with a Pactor modem in Winlink knows they cannot intercept another Winlonk/ Pactor transmission in ARQ. It’s their claim to fame for Sailmail which they also want to run for free in the ham bands- sadly with the help of ARRL.
ARSFI and Winlink and ARRL officers know this but won’t admit it (although there are admissions in the SCS filing and ARSFI filing recently at the FCC if you read really close)….so we must demonstrate this problem to FCC and to congress– ARRL is not our friend here and is aiding the HF spectrum takeover by private email servers . That is also what the technician claaa upgrade RM-11759 is all about-an effort to gain more internet email repeaters that are obscured, not monitored, for free email. A real security concern.
Everyone who cares about ham radio, its future, and our national security should write congress and let them know this is happening and that NPRM 16-239 and RM-11708 would only perpetuate problems that need to be stopped. ARRL’s executive committee is paging this hard. Congress needs to step in and stop it- FCC will listen to congress over the ARRL.
See:
https://forums.qrz.com/index.php?threads/suppressed-report-becomes-public.50388/
See:
https://winlink.org/FCC_Action
Look at this call to arms by Winlink at the FCC- hey are flooding the box to win the HF spectrum for private email- making it difficult to find Illegal activities or crime.
——– Forwarded Message ——–
Subject: [winlink-programs-group] Re: We are NOT asking, we are BEGGING!
Date: Sat, 22 Dec 2018 10:08:42 -0800 (PST)
From:
Reply-To: [email protected]
To: Winlink Programs Group
I have also posted this request on a few non-US sailing forum, hopefully more people will contribute to endorse the ARSFI position
Janis Carson says
Given your legal degree and long service to amateur radio, I tentatively accept your analysis of 97.221 as true. Thank you for explaining it simply.
Having to be Erin Brockovitch of late, I considered 97.221 a “Zombie clause” that the FCC overlooked in their lopsided treatment of “unlimited band width” on HF. ARSFI indicated it
considered 16-239 a “temporary” step with more changes to follow soon. This is consistent with past behavior.
http://www.zerobeat.net/bandplan-dissent.html
I solicit your legal opinion on the following questions about 16-239, which are framed simply to avoid the kind of subtly misleading politician answers I expect from others.
1. Y/N will it be legal for the INTERROGATING STATION to transmit at 2.8 KHz TO the connected AUTOMATIC station?
2. Y/N will it be legal for a non “automatic” station to transmit 2.8 KHz data outside the ACDS segments for any purpose, like sending files?
3. If it is true that only 500 Hz band width is allowed outside the ACDS segments for automatic operation, then 100 email store and forward stations occupies 50 KHz of the 40 meter DATA segment, with channels “assigned for the exclusive use of one station”. Region 3 (Asia) only has 100 KHz total 40 meter band (DATA and VOICE). Please explain why setting aside 50 KHz of the 40 meters world wide HF band for the exclusive use of free private HF email with “assigned channels” on a 24/7/365 schedule is a good idea. Do not reference transitory emergency communications, since most will agree that is desirable, if effective.
4. Given the recent 16-239 comments of James Osborne, Ed Kelly, Jutta Sauber, Eric Shrader, Heiko Sauber, Roberto Ritossa, and others stating their daily use of Winlink for their communications regularly during voyages, and the FCC rule, “Prohibited 97.113(5) Communications, on a regular basis, which could reasonably be furnished alternatively through other radio services”, like $275 a year for Sailmail, please educate me on this.
https://sailmail.com/cost-and-application-process/
What part of “communications on a regular basis” does not apply to these people?
5. Without any practical means to to display the undecodable content of private emails sent via HF radio, is the amateur service self monitoring according to past FCC policy (RM-11699)?
6. Given the closure of many FCC Enforcement Bureau offices, how do you recommend the FCC and others provide sufficient enforcement and monitoring?
I am listening.
Steve says
If I might, rather than dig into the regulatory minutiae, just my experience as a sailor..
The last time I did a major passage was back in 2005, single-handing my 20′ boat from NY to Bermuda and back. I didn’t have my ham ticket then, so I used Sailmail, which was expensive but small bucks compared to the five grand or so it cost me to install my marine HF rig. I will tell you that most sailors on a budget rely on marine VHF at sea and do their emailing by cell phone when in port. Those few who have the means use satellite coms for phone and digital communication at sea. Very few use HF, or did then. It may be cheap communication, but the initial expense is high and the learning curve is steep, especially for non-hams. Even now I don’t hear a lot of Pactor on the bands. What am I missing?
Note that Sailmail resides on marine HF bands, not the amateur service.
I have used Winlink in more recent years and it’s a real asset to sailors who are licensed hams. What I gather from this conversation is that some private (unlicensed) traffic is getting past the vetting that Winlink does (?). Anyone could hijack an amateur call for the purpose, I suppose, long as it’s general class or better, and it’s unlikely that the actual license holder would ever know. Perhaps it would be helpful if Winlink used a snail mail verification using the licensee’s registered address.
It just seems that there’s an attitude running through this thread that the blue water sailing community, some of whom are hams, are eating up great gobs of HF spectrum for their fancy expensive yachts. From my experience, that image is far from reality.
Steve AC2EL
Janis Carson AB2RA says
It would be helpful for all in this thread l to read Lor’s (ARSFI) comments included in this filing, to see his private thoughts on the use of amateur HF and Winlink for yachts.
https://ecfsapi.fcc.gov/file/101311670501116/FINAL%20REPLY%202019%20%2016-239.pdf
His own words are more effective than mine in describing the problem of keeping the benefits of emergency communications without abuse by others.
Janis AB2RA
N4AOX says
Straight out of the socialist, fascist handbook. Of course anything to do with communication by the sheeple must be regulated. I am sure Brennan and Clapper agree with this position. Management of MSNBC has declared that it is their policy to be responsible and regulate content and dissemination of information. CIA, FBI, NSA, etc. has hired Snopes and SPLC to regulate “quality” of content. Happy days are here again!