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Not Getting It
6 December 2019 | by ARRL announced today that they have filed comments with the FCC requesting a dismissal of the Petition for Declaratory Ruling filed by New York University (NYU) regarding digital encoding and encryption. This petition basically claims that proprietary and closed protocols like PACTOR violate current FCC rules, an opinion I’ve had for several years. I think the AMBI vocoder used in D-STAR and other digital voice modes falls into the same category as well as it’s not openly documented, like the rules require. Due to the lack of documentation and openness, such encoding is de facto encryption, which is prohibited.
ARRL’s filing has me smacking my head. Rather than openly addressing the issue of protocols in amateur radio that are closed and proprietary, they attack the language proposed by the Petition. Furthermore, they pull CW into this, stating,
“The proposed prohibition arguably could include, presumably unintentionally, CW (Morse Code), which is a longstanding means of encoding transmissions. The very fact that messages sent in CW are “encoded” by any definition of the term starkly demonstrates the problem with this proposal.“
I’m not sure if ARRL is intentionally being obtuse or just doesn’t understand the crux of the issue with “un-openly” documented digital protocols. CW, while technically encoding, is 100% openly documented, and has been for a century or more. It doesn’t require proprietary hardware, software, or algorithms to decode. PACTOR until most recently could only be decrypted with proprietary hardware. AMBI and others continual to be closed protocols. That’s the problem, not semantics over the proposed language in the petition snagging CW as encoding, and encryption.
A few weeks ago I started writing comments to file with the FCC, but I quite honestly lost interest. I don’t have a horse in this race, other than wanting to see amateur radio continue on well into the future. I’m just disappointed ARRL doesn’t get what the real problem is, doesn’t make an effort to correct it, and fails to even acknowledge that closed digital protocols are antithetical to the openness and historical foundation of amateur radio.
This article originally appeared on Radio Artisan.
6 Responses to “Not Getting It”
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and 7200mhz will continue as the fcc has let ham radio go the way of cb radio 30 years ago!
That article is a hard nut to crack, Personally, I dont think these pgms/modes are closed or secret mode since its available to any ham radio op who has the $ to purchase the software programs. Some of the software has advanced ham radio to new levels, some NOT so much. However its a ?(free) market if you can buy the pgms or get a open source pgm from which to use the technology. As they say, “ya pay ya money and take ya choice” So it goes, ad infin itim.
Walt, if I develop a compression encoding scheme, use it on the air, don’t document it, and offer a decoding chip for sale for $20K, is this legal? The rules are silent on hardware and software availability, cost, reverse engineering capability, and open source alternatives, and only states amateurs “may use any technique whose technical characteristics have been documented publicly.” Arguably I could document it on the web and simply state that it’s “an algorithm for compressing and decompressing data over the air” to meet the documentation rule. Then the question shifts from legality to whether this is consistent with the tenets of amateur radio.
To illustrate my point above, I’ve created a page for a new “compression algorithm” called IINE: https://blog.radioartisan.com/iines-not-encryption/ . This is an academic exercise, but minus the exorbitant cost, this is what has been going on with proprietary digital protocols. IINE is legal as the rules are written today.
Walt, N5EQY, you have to buy the hardware too, a PACTOR modem, and Jerry, W5KAW, I think you meant 7.200 Mhz (7200 Khz), but I know exactly what you’re referring to even if it’s not on 7200 Mhz. Anthony, K3NG, if you want to see where the ARRL stands on most any issue I think all you have to do is follow the almighty dollar to see what determines their positions and decisions. Just my observations over the past 23 years and my humble opinion of course.
Cliff, I was ARRL proponent for many years. I have a life membership. I sense that the new CEO wants to do all the right things. I have been initially impressed with him. I don’t know whether he can overcome years of doing things a certain way at the League. I won’t comment on whether this comes down to the almighty dollar, but at the very least ARRL agreeing with the Petition would be an admission that the League has been asleep at the wheel on this topic with proprietary digital protocols. Some may argue it’s not the League’s responsibility. I disagree.