"First, there is a clear entanglement with the "Open Source" movement by Bruce Perens, K6BP, and his associates who for the past two decades have been at odds with the use of AMBE codec voice compression which is a patented and proprietary method owned by DVSI. The Commission made it clear in 1995 that if methods were available to monitor this - then it can be used on the amateur bands. Today it is in use on P25, D-Star, Fusion, and other modes - Bruce and his colleagues continue to seek the banning of it's use - which would be at great detriment to the Amateur Community." The AMBE issue has been held on as a strawman by those who wish to throw out the baby with the bathwater. This has actually been addressed, even by Rappaport. I disagree with that portion of the petition (the open source requirement). Even Rappaport disagrees with a strict open source requirement. However the rest including monitorability are good things to have. " Another claim associated with the RM-11831 is the issue of various digital modes. The claim is that ARQ and compression techniques are encryption." They are not encryption in a strict sense. However, I would challenge you, even with an SCS modem to tune into a random signal (on 40 meters for example) and decode an entire message. You cannot do it. ARSFI has admitted that it is difficult. SCS has even said that it is difficult. Effectively, the message is obscured from public view without $20,000 of equipment. This is why ARSFI has created the online message viewer which isn't even fully open to the public. Even our own ARES teams are boasting that they have "privacy" on these email systems and can pass sensitive medical data under HIPAA rules (which actually do not apply to ARES). There is at the very least much less privacy than any other amateur traffic. This goes against the very spirit of the amateur radio service whereby all radio amateurs should be able to decode and read all traffic on the bands. You can do it with CW, SSB, AM, FM, DMR, DSTAR, MT-63, PSK31, JT65, FT8, RTTY and every other mode. You cannot do it with Pactor and Winlink. It is necessary to have that open decoding for self-policing and also learning about various uses of our spectrum by new amateurs. "Privacy" absolutely does not belong on the amateur bands. "From my perspective the only frustrated transparency is being exploited by an apparent majority of the ARRL Directors to promote N9NB's agenda without discussion with our members or discussion within the ARRL Board. To this end, the promoters of this derisive agenda have been VERY effective. " You could not be more wrong. Discussion of this has been taking place in the executive committee. I have been doing my independent technical investigation. You can in fact do the same legwork as I did, talking with ARSFI and also Rappaport, Kolarik and others. They would be more than happy to hear from you. Reach out. I can give you names and email addresses. Nothing is stopping you. There has also been a diversity of opinion on this issue, and not a wholesale blind allegiance to one side. We are looking for compromise, and not winner-takes-all. The EC has requested a 90 day pause on WT Docket 16-239 to further study the issue by meeting with both parties. This is essential rather than ARRL being a rubber stamp to the desires of any one party. An effect of this is that I was told that a report will be presented at the July board meeting. The full board will have the ability to discuss this issue and vote on it. Let me also say that many weak signal, CW and traffic handling operators have put up for YEARS with interference from automatic digital stations that have been popping up seemingly everywhere in the HF bands. I personally have had PSK31 and JT65 QSOs blown out by email robots that relentlessly hammer away until they win. Affected operators have pleaded with the ARRL to do something. They felt largely ignored. We had one petition, RM-11306 back in the 2000s that would have even put wideband digital traffic in the PHONE bands, a concept known as regulation by bandwidth. Something happened and the ARRL pulled it back. There was massive uproar against it. One only has to look at the list of frequencies used by the Winlink system. A staggering amount of bandwidth is used, all the way in the phone bands. It is pretty bad in other countries from what I was told. Thankfully we've had a backstop to that here. https://www.winlink.org/RMSChannels There is middle ground, and I'd urge you to wait and see what the EC will have at the July meeting. The goal should be to provide a means to enhance our digital capability while not completely blowing out all other traffic and users of the HF bands. Ensuring that we do both will ensure that all of our members are served, not just a select few. Ria N2RJ On Tue, 11 Jun 2019 at 10:54, Kermit Carlson <w9xa@yahoo.com> wrote:
Hello Ria,
The impetus of RM-11831 is directed at several portions of the amateur community and not just the few improper operations of WInLink gateways.
First, there is a clear entanglement with the "Open Source" movement by Bruce Perens, K6BP, and his associates who for the past two decades have been at odds with the use of AMBE codec voice compression which is a patented and proprietary method owned by DVSI. The Commission made it clear in 1995 that if methods were available to monitor this - then it can be used on the amateur bands. Today it is in use on P25, D-Star, Fusion, and other modes - Bruce and his colleagues continue to seek the banning of it's use - which would be at great detriment to the Amateur Community.
Another claim associated with the RM-11831 is the issue of various digital modes. The claim is that ARQ and compression techniques are encryption. This has already been settled, it is NOT encryption. The interpretive rule amendment published by the Commission in 1995, FCC DA-2106. Specifically at #3. the FCC stated that;
3. The primary purpose of CLOVER, G–TOR, and PacTOR is to facilitate communications using already authorized digital codes, emission types, and frequency bands. The technical characteristics of CLOVER, G– TOR, and PacTOR have been documented publicly for use by amateur operators, and commercial products are readily available that facilitate the transmission and reception of communications incorporating these codes. [See Technical Descriptions CLOVER, G–TOR, PACTOR, published by the American Radio Relay League, Inc. (1995).] Including CLOVER, G– TOR, and PacTOR in the rules will not conflict with our objective of preventing the use of codes or ciphers intended to obscure the meaning of the communication. [The HF bands are widely used for international communications. Number 2732 § 2.(1) of Article 32 Section I of the International Telecommunications Union Radio Regulations requires that transmissions between amateur stations of different countries by made in plain language. Section 97.113(a)(4) of the Commission’s Rules, 47 CFR§ 97.113(a)(4), therefore, prohibits amateur stations from transmitting messages in codes or ciphers intended to obscure the meaning thereof.] We agree, therefore, that it would be helpful to the amateur service community for the rules to specifically authorize amateur stations to tra nsmit messages and data using these and similar digital codes. Accordingly, we are amending Section 97.309(a) to clarify the rules as requested by the ARRL." The technical descriptions of course are available http://www.arrl.org/technical-characteristics
I do note that there was a sub-committee of the ARRL EC which was to have created a white paper stating the ARRL position. This was to have been completed at the beging of this month in advance of a meeting between Lor Kutchins, W3QA, of ARSFI and Ted Rappaport, N9NB. I understand that it now appears that any such meeting, if it does occur, would not have Ted at the table, but rather a proxy.
I agree the League should always try to act as a moderating neutral force when there are splits within our community, but when was it decided that the League would completely withdraw from the position of being a strong proponent for the reasonable promotion of the techinical digital advances ? When was it decided that the League would only be a referee in this discussion that seeks to label error correction and ARQ as "effective encryption" ?
The subterfuge of claims by Ted Rappaport, N9NB and his associates include but are not limited to several incorrect assertions;
that compression, ARQ and error correction/checking are encryption;
that HF digital traffic has created a national security vulnerability that is currently being exploited;
that the detriment "effective encryption" to STEM;
that new HF privileges for technicians is being promoted by the ARRL to create more automatic HF Digital private traffic;
that the ARRL request for an expansion of HF operating privileges for Technicians is related to helping create more private HF Digital traffic;
that present existing (and permitted) forms of digital are being done to frustrate transparency
all of this is nothing but completely ineffable twaddle.
From my perspective the only frustrated transparency is being exploited by an apparent majority of the ARRL Directors to promote N9NB's agenda without discussion with our members or discussion within the ARRL Board. To this end, the promoters of this derisive agenda have been VERY effective.
We do need to respect and protect the previously decided precedence that allowed the expansion of Digital past the 5-level Baudot codes and the standard FSK/AFSK teleprinter transmission methods. The declarative ruling in 1995 started the digital mode expansion we must never pull back.
Out here in the Central Division, the mis-information and outrageous claims has started to create the UN-mistakable signs of a new schism within the amateur community. The most troubling device present in the discourse is that the the polarity of comments leave no place for a reasonable centrist position.
Simply put - let us correct the behavior of the bad actors and move forward as more than referees in a bad fight.
Respectfully,
73, Kermit W9XA
On Tuesday, June 11, 2019, 8:12:54 AM CDT, rjairam@gmail.com <rjairam@gmail.com> wrote:
Director Carlson,
Mr. Silver’s letter illustrates quite clearly why the ARRL has not commented on this petition.
There are several inaccuracies I’ve noticed just from casual glance and several things that I’ve discovered in my discussions with several parties in the HF digital space including ARSFI and Mr. Kolarik, the author of RM-11831.
Of these include diligent monitoring by ARSFI. This has certainly not been the case. ARSFI has changed its stance from saying that messages would be revealed only if there is “good cause” to making a message viewer available to the public. In doing so, many violations of amateur service rules were revealed, including commercial traffic (that extends well beyond the pizza rule), foul language and sexually explicit content. All of these hide behind the mask of compression and ARQ.
Therefore I would absolutely not support the ARRL commenting, and especially opposing this petition until we can get a clear view of the entire situation. For this to happen we need to thoroughly investigate, something which I’ve personally been doing with Director Hopengarten and other members of the EC. I took this initiative because I was being asked to by some of my division members and other ARRL members.
I do have some issues with the petition itself (such as the open source requirement) but it has some points that have merit and have brought this debate front and center. I cannot and will not turn a blind eye to what has been going on.
Ria N2RJ
On Tue, Jun 11, 2019 at 8:39 AM Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> wrote:
Hello ALL -
Several of my fellow Central Division members have noted the lack of an ARRL comment on RM-11831 and the similar resounding silence about the Symbol Rate proceedings. I was under the impression that a white paper describing the League position would be completed at the beginning of this month, in time for a meeting that appears will never happen.
In all of my time on the Board I have never seen such a complete lack of response to important issues on the FCC Docket which is at the focus of the ARRL membership's attention.
For the purpose of discussion I have attached a comment in PDF below my signature line from a local ARRL member that I obtained from the FCC Comments link; https://ecfsapi.fcc.gov/file/1042806152070/Comments%20on%20RM-11831.pdf
73, Kermit Carlson W9XA
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