Rappaport Suggests National Security Risks with Amateur Radio Violations
Wednesday, November 21, 2018 | Comments

A wireless expert says the FCC is putting national security at risk by not enforcing amateur radio rules.

The FCC’s notice of proposed rulemaking (NPRM) 16-239 attempts to remove a limit on the baud rate of high-frequency (HF) shortwave transmissions. In an ex parte filing, Theodore Rappaport, Ph.D, told the FCC’s chief technology officer (CTO) Eric Burger the FCC should first address ongoing rule violations to proper usage of the amateur radio service — specifically, the use of obscured, private messaging, which is forbidden in Part 97 rules and creates national security concerns, as well as other violations.

“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,” Rappaport’s filing said.

Rappaport is the founding director of NYU WIRELESS, a professor at New York University (NYU) in three different schools and a leading expert in 5G technology.

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.

“In my personal conversations with FBI and FCC officials, they admit they also are unable to readily decode these types of transmissions,” Rappaport said. “In my discussions with vendors of amateur radio equipment, they tell me that they are concerned about purchases of amateur radio equipment by criminal cartels, and that they believe it is happening daily.”

Rappaport urged the FCC to recognize the danger of NPRM 16-239 and address Part 97 rules to remove this type of obscured communication and other ongoing violations, before it enacts NPRM 16-239.

Rappaport copied Sens. Mark Warner and Tim Kaine, along with Rep. Morgan Griffith on the FCC filing.

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On 12/6/18, Lee Inman K0QED said:
Yesterday the Amateur Radio Safety Foundation Inc. (ARSFI) board (https://arsfi.org) filed with the FCC a comprehensive response to the online and media campaign that Theodore Rappaport has been leading to get the FCC to dismiss the pending notice of proposed rulemaking Docket No. 16-239. The proposal would eliminate the current 300 baud limit on HF digital transmissions and replace it with a 2.8 kHz bandwidth limitation. We are in favor of this for many reasons mostly because the advancement of the radio art is impeded without it but for most Winlink stakeholders it will allow Pactor 4 — finally — in the USA.

There has been a concerted emotional campaign led by Ted Rappaport that has stampeded many to make negative comments on this in an attempt to block this important step forward.

I encourage everyone to click on this link https://winlink.org/FCC_Action and to read what Rappaport sent the FCC and our response to his claims and to make your own informed decision about this important issue.

If you have a stake in this, we urge you to please immediately file a comment on the FCC's ECFS.

On 11/29/18, Skip Cameron W5GAI said:
Part 97 and the amateur radio service is built on being able to monitor all transmissions including emergency or data. Emergency use as a means to justify obscured nondecipherable messages is improper and degrades the whole purpose and intent of ham radio. The FCC ruled several years ago that encrypted or obscured data is not allowed even for emergency or medical needs. Use a commercial service if you want private messaging.

On 11/28/18, Louis House said:
As has been proven many times over, digital data transmissions used by amateur radio operators during emergencies is a strong asset to the governing entities at every level in our country.
It is my position that digital data transmissions are vital to the community during any disasters when governing entities lose normal communications systems and licensed trained amateur radio operators volunteer to fill that need in services to our communities and our country.

On 11/28/18, Jim Warakois said:
Since any amateur operator interested in receiving the digital modes has only to obtain appropriate amateur radio equipment, why can't the FCC and monitoring entities do the same?

On 11/26/18, John N. Hudson III said:
There are many levels of discussions on the subject at hand. I've read comments questioning why radio amateurs would need to send e-mails over ham radio. The answer too can be addressed several ways but from my perspective I'll respond by saying that during emergencies and disasters where infrastructures are impaired, damaged or destroyed, amateur radio operators using digital communications that include an array of software using ARQ on various spectrum and systems from HF, VHF, UHF and microwave frequencies can be used to supplement or meet communications needs to coordinate, communicate and respond to events when all else fails or no infrastructure exists.

On 11/26/18, Electro said:
Would this impact Icom's D-Star as well?

On 11/25/18, A Cynic said:
But surely criminal cartels' use of innovative technology adds diversity in spectrum applications — a critical government policy goal.

On 11/24/18, john said:
Because someone spying is certainly going to follow the rules.
Oh crap, I can't send those secret messages because it's against the law.
On top of that I have to turn in my 20 round clips because I live in California.
I might as well go home.

On 11/24/18, Jeff Blaine said:
I think with a third terminal unit you can't read the traffic between the Winmail box and the other end. That's the problem because you can't identify the senders so the self-policing thing is out the window with the transactions being essentially hidden from view.

On 11/24/18, MARK PARMLEY said:
That big ole thing they call the internet is being used all the time by terrorists and criminals. Find the bad guys and hold them accountable without putting the brakes on us hams. SMH

On 11/24/18, Ron Kolarik said:
Reply to RC Anderson comment:

Mr. Anderson states that the modes he mentioned can be decoded by anyone with the proper software, which is partially correct without naming the product. The truth of the matter is those modes when used in Automatic Repeat Request (ARQ) mode with added compression cannot be decoded by third parties. Perhaps Mr. Anderson should do some research on ARQ or provide the name of the software that has the capability; none exists that I'm aware of.

Mr. Anderson further states WT 16-239 does not pose a national security risk. If allowed to pass in its current form, the very narrow amateur allocations on HF could be overrun with unidentifiable undecodable signals for unknown purposes. Bad actors would find it easy to hide in the amateur bands where there's little to no interest to monitor by the FCC. Amateurs are expected to be self-policing — impossible if the transmission can't be decoded.

Mr. Anderson would do well to read the WT 16-239 submission from Hans-Peter Helfert SCS where he posts contradictory statements on Pactor 3 and 4. In one sentence he says Pactor-3 and Pactor-4 are well-documented protocols, and in another "Offering complete insight to our technologies also means releasing corporate secrets." Can a viable decoder be produced from information SCS has released?

This is far from being an effort to divide the country over amateur radio. Dr. Rappaport raises some legitimate questions and concerns that try to prevent amateur radio from being turned into an undecipherable mess.

On 11/24/18, Ron Kolarik said:
Reply to Jeremy Allen:

No one has been able to explain why email over the HF amateur radio bands is valid or necessary when other services are available for the purpose. The claimed need for emergency communications doesn't explain the over 50,000 email messages that flow over the amateur bands monthly during normal conditions. It's clearly a bypass of commercial services, which is a violation of the rules governing amateur radio. There is also documented widespread abuse of the system — pirated calls, business use, etc.

On 11/23/18, Masher said:
I really miss the days when this publication was MOBILE RADIO TECHNOLOGY and not a political lobbyist magazine.

As is typical of many government lobbyists, Mr. Rappaport is just looking for a scapegoat bogeyman so he can steal some free spectrum from them.

Editor's Note: This magazine was formerly RadioResource Magazine. It is now called MissionCritical Communications.


On 11/23/18, Janis Carson said:
The time for misinformation about whether an SCS Pactor 4 modem can decode FEC but cannot decode ARQ is over. Myths vs. facts. It is not a technique whose technical characteristics have been documented publicly or specified Part 97.309 a 4. The newer Pactor 2, 3, 4 versions are NOT specifically listed, are proprietary, unspecified and should not have been legally considered or added by default without public documentation simply because an earlier version was listed. The FCC policy is clear: "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."
https://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db0918/DA-13-1918A1.pdf

Any citizen can get the facts on existing problems by googling drug cartel radio network. Bad actors use our technology against us. If amateur radio operators cannot self monitor and the FCC is unable to do so, just who is responsible to do it and where are the tools and manpower? While use of Pactor 4 or other data modes can be valuable for emergency communications, ordering boat parts or repairs posting to a blog or Facebook is a commercial activity that has no place in the amateur spectrum. Note some people have an income from Facebook posts and blogs besides the obvious purchases. The use of this type of transmission must be limited to what is being advertised legitimate emergency communications under the supervision of RACES or ARES for instance.

Free email is not an enumerated purpose of amateur radio in Part 97.1, and its proliferation now threatens access to the entire DATA segments of the HF spectrum for legitimate narrowband uses such as FT8. Part 97.113 5 prohibits communications on a regular basis which could reasonably be furnished alternatively through other radio services. Part 97.115 b 1 The control operator is present at the control point and is continuously monitoring and supervising the third party's participation. Winlink does not authenticate or provide immediate disconnection of shore-based unlicensed internet users who may not know FCC rules about content. Part 97.219 d 1. Winlink permanently occupies a channel for email connections in violation of 97.101 b. No frequency will be assigned for the exclusive use of any station. Techniques OK for VHF do not apply to HF. Now 16-239 spreads this use of this assigned channel unlimited bandwidth proprietary commercial content, which cannot be monitored outside the Automatic ACDS HF segments.

Before the FCC approves expansion of this they need to take a long hard look at its history and the rules. If the FCC decides to subsidize free email for underserved users, it should do so in the commercial spectrum for methods like Sailmail. Do we really want more of this in the amateur bands? https://ecfsapi.fcc.gov/file/7521315143.pdf


On 11/23/18, Gordon Ball said:
You might like to visit my web page at QRZ.com
My call is VE3CSH.

On 11/22/18, RC Anderson said:
Dr. Rapaport has completely lied to the FCC in this filing on several points.

First, PACTOR, WINMOR, ARDOP and similar modes are not violations of Part 97 of the FCC rules because they CAN be decoded by anyone listening to the transmission with an amateur radio connected to a computer running the right software. Amateur radio operators and news agencies do it all the time.

Second, "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." This is just a flat out lie that has been used in several forms to try to turn people against PACTOR. The PACTOR modes actually use a smaller RF footprint than many other popular digital modes employed today like MT63, 2K 2XPSK 1000 and 2XPSK 100R. With the increased speed of PACTOR 3 and 4, the transmissions are also completed faster, freeing up the airwaves faster than other modes.

Third, Dr. Rappaport mentions vendors of amateur radio equipment being concerned about purchases of radio equipment by criminal cartels. He specifically used the term cartels instead of organizations to play on fears of people from recent news articles of the U.S. southern border.

In his FCC filing, he also states that SCS has not released the information about PACTOR to the FCC, which makes it illegal to use the PACTOR modes. This again is completely false as SCS released all of the information to the FCC over 20 years ago and the information is freely available online.

This is NOT a national security concern, although making believe that it is creates headlines that I believe are being used in an attempt to divide the country against amateur radio operators.

On 11/22/18, Jeremy Allen said:
Dr. Rappaport fails to address the fact that these modems are readily available and used on both the international and domestic market, and most amateur radios can be easily modified in minutes to transmit across the HF spectrum. On top of this, criminal elements can buy and use encryption on the software level to augment their secrecy. None of this will be prevented or mitigated by limiting through regulation alone the baud rate of HF transmissions in a single HF radio service. This is just a new angle of attack against amateurs using their equipment to pass email over HF.

On 11/22/18, Steven Fleckenstein said:
It is my understanding that Winlink HF digital radio transmissions are compressed but not encrypted.

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