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."
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