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Comments still being accepted at FCC, and hamdom is silent. Hamdom will soon lose our spectrum at HF if you don't write in and let your opinion know NOW! Recently, in the flood of recent comments from those who want private email in ham radio, there have been many confessions to the FCC that Winlink/Pactor data and other ARQ transmissions cannot be intercepted by other hams over the air. These confessions make clear that there are many ongoing Part 97 violations, and show that the ARSFI-sponsored Winlink/Pactor data is used for obscuring the meaning of transmissions, which “effectively encrypts” the messages in email and file transfers over the public airwaves. These recent public comments show clearly that amateur operators, both in the US and abroad, not only transmit obscured messages, but also routinely and willfully violate Part 97 rules that prohibit the commercial bypass of satellite email providers and many other HF radio providers such as Sailmail https://sailmail.com/ (which is supported by many of the same people who are involved with ARSFI and Winlink). https://sailmail.com/?s=winlink These confessions reinforce the fact that a major national security risk exists in the US through the use of “effectively encrypted” transmissions on the amateur radio spectrum, by amateur operators themselves, and that there are many (including ARSFI and ARRL) who are willfully supporting and perpetuating the violations of US Amateur Radio Service rules. These violations, and the increased number of abuses in the amateur radio spectrum below 30 MHz, would be exacerbated greatly if either NPRM 16-239 or RM-11708 were passed, and if the ARRL’s request for expanded Technician Privileges were issued. It is my hope that anyone reading this far will continue reading, and that you will take the time to view some links, and then write your elected congressional officials, as I and many others have, to point out this national security risk and to urge that the FCC summarily dismiss and reject NPRM 16-239 and RM-11708, and to immediately seek ways to ensure that only open-source, easily decoded data signals are used in the amateur radio service. Public comments in the past few weeks reveal the serious nature of effectively encrypted, private email and file exchanges, that has and is being supported by the American Radio Relay League and the ARSFI/Winlink Development Team. There are many data users on the HF bands that are willfully using emissions that directly violate Part 97 rules, and in doing so, they sabotage the requirement of self-policing and over-the-air monitoring as required by the FCC when it created the Amateur Radio Service, and similarly violate the requirement that amateur operators never use the spectrum to routinely bypass other commercial means of communications. Please write to Congress and the FCC, and point out that all Asian countries, and most of the countries of the world, recognize these problems, and therefore have not allowed Winlink, or unspecified/undocumented/proprietary transmissions systems like Winlink/Pactor, or other unspecified, undocumented codes on the HF bands below 30 MHz, where such transmissions can easily cross borders and ocean. For responsible US national security policy, and proper conduct of the Amateur Radio Service, the FCC should fix this misuse of the spectrum, should immediately terminate the offending “effectively encrypted” ARQ transmissions being supported, developed, and licensed by ARSFI and the Winlink Development team currently, and should terminate NPRM 16-239 and RM-11708 as well as the ARRL’s request for expanded Technician Class proceeding. These activities must be stopped, and Congress and the FCC should be alerted that the FCC should immediately take up an “open source” requirement that ensures public eavesdropping for all data transmissions in amateur radio. Proof that traffic sent by Winlink with the SCS Pactor (and many other modes used by Winlink in ARQ mode) cannot be interpreted by other ham operators (in direct violation of 97.113 through the use of obscured messages, and is in direct violation of the principles and practice of the amateur radio service as specified in footnotes 18 and 19 in FCC R&O DA 13-1918), can be found in the FCC record, through testimony by myself, Lee McVay, and many others. Winlink/Pactor users, themselves, who donate $24 for a Winlink license from ARSFI, have confessed how Winlink effectively encrypts the messages/emails and files from the general eavesdropper, making it impossible for others to listen in on the frequency to determine meaning or if the transmission violates Part 97 rules (see, for example): https://www.fcc.gov/ecfs/filing/1222718116209 Furthermore, the Commission should note the many confessions of how ARSFI’s Winlink system is being used to bypass commercial email systems of the world through the use of amateur radio spectrum, in direct violation of the “no commercial bypass” requirement of Part 97.113. It is impossible to intercept these transmissions to know if other violations, or if crime or terrorism, is being conducted over the US amateur radio spectrum. These people are illegally using the amateur bands, when they could simply pay $275 for Sailmail. I suspect an audit of the users of Sailmail and ARSFI/Winlink licenses would show that some individuals often donate to both organizations, and that many users are exploiting the amateur radio spectrum to conduct business and other commercial use, in addition to violating the requirement that other frequencies, other than amateur radio frequencies, be used with Sailmail. https://www.fcc.gov/ecfs/filing/12161836317602 https://www.fcc.gov/ecfs/filing/121668558275 https://www.fcc.gov/ecfs/filing/121694680414 https://www.fcc.gov/ecfs/filing/12212160916228 The Form 990 tax form filed by the non-profit of the ARSFI corroborates the hundreds of recent brief filings at the FCC ECFS, and shows that ARFSI and Winlink advocates run a lucrative private HF email service that provided over $75,000 in revenue last year, and that there is an approximate balance of nearly $200,000. There is a definite pecuniary interest of the ARSFI group, and a financial incentive for this group of amateur operators to gain more HF spectrum for use for its commercial Sailmail activities, which surely have many of the same ”customers” as who have “donated” to ARSFI. To me, and many others, it appears there is a clear conflict of interest at ARSFI, and the ARRL appears to have been supporting ARSFI’s aggressive violations of Part 97 rules, using the cloak of “emergency communications” through its advocacy of greater bandwidth data allocations, first in RM-11306, and then in RM-11708. The use of proprietary data that cannot be intercepted by other amateur operators is a genuine national security risk that the ARRL and ARSFI/Winlink continues to promote with NPRM 16-239 and RM-11708. It has become clear in recent weeks, at the ECFS 16-239 filings, that this tiny minority may simply be looking to expand its illegal use the Part 97 Amateur radio service spectrum in order to augment its commercial email system, Sailmail – since some of the same people who are part of the Winlink development team also likely run/operate/sell/manage software for the purpose of commercial private HF email, as seen here: https://sailmail.com/ The FCC should shut down this undocumented, unspecified proprietary coded data on the HF bands in ham radio, and must not pass NPRM 16-239 or RM-11708. The general amateur radio population has largely ignored the attempted takeover of the amateur radio spectrum by ARSFI, but I urge all of the hams in this country, and around the world, to review some of the hundreds of public comments in the past few weeks. To see how vocal the ARSFI and sailing vessel crow is, please review these comments: https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11708 <https://www.fcc.gov/ecfs/search/filings?proceedings_name=RM-11708&sort=date_disseminated,DESC> &sort=date_disseminated,DESC And then ask yourself, is this what amateur radio is supposed to be – See this New York Times Article, describing the commercial Sailmail system: https://www.nytimes.com/2001/11/22/technology/radio-e-mail-connects-ships-to-shore.html Nov 22, 2001 - According to Steve Waterman, who operates two stations from his home in ... nothing to do with them,'' said Vic Poor, a Globe consultant and investor. Mr. Poor, a former cruising sailor, developed the first Winlink system before ... If you are against this use of the HF spectrum, and believe that Part 97 rules should be respected, please write congress immediately to stop this use of HF spectrum which jeopardizes our nation’s safety and our hobby, and please let your opinion be known at the FCC using the “filing instructions” found at http://www.wirelessgirl.net/ Please file FCC comments and write congress --- This email has been checked for viruses by AVG. https://www.avg.com
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