[arrl-odv:21833] Encryption of Amateur Radio communications; RM-11699; As-filed Comments of ARRL

Greetings. With appreciation to the Executive Committee for its quick work in approving the policy and the attached filing, and to Dave Sumner and Bruce Frahm for helpful edits, here are the comments filed just now in response to the Petition for Rule Making of Mr. Don Rolph, AB1PH of Massachusetts. The Petition proposed to permit encryption of certain Amateur Radio communications. Based on the memo on this subject that Mr. Sumner and I prepared for the EC that was circulated to all of you last week, these comments, by order of the Executive Committee, oppose that Petition as being unnecessary. That said, we have tried to be solicitous of Mr. Rolph, who made his argument concisely and in good faith. We have also endeavored to leave the door open to permitting encryption at a later date should the facts warrant such. In our view as of right now, they do not. There are more than 200 comments filed on this Petition and the Executive Committee determined that divergence from our normal policy to not file on bare petitions (save for those which impact spectrum allocations) was justified in this instance, so that ARRL could exercise some leadership on this somewhat controversial issue. That said, most comments on file support the argument that ARRL has espoused here. These comments are now public information or will be in a couple of hours, so distribution of these comments is fine. Thanks also to Tom Frenaye who brought this issue to the attention of the EC in the first place. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG
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Chris Imlay