[aprssig] Fwd: [winlink-programs-group] We are NOT asking, we are BEGGING!

Scott Miller scott at opentrac.org
Tue Dec 11 14:15:12 EST 2018

For those (like me) who haven't heard about this before, here's 
Rappaport's filing:


The bit about these modes being a national security threat smacks of 
fearmongering (and who's going to use ham radio for nefarious purposes 
these days when commercial networks are everywhere and their use 
attracts less attention?) but I have to say I agree that proprietary 
modes go against the spirit of amateur radio.  Slapping an AMBE-2000 
codec in a radio doesn't advance the state of the art; it just makes 
hams reliant on commercial entities to provide black boxes that they're 
not allowed to even reverse engineer.

I'm not sure that hitching this wagon to the bandwidth limit NPRM is the 
way to do it, but as long as the FCC is paying attention, maybe it's 
time to take a long hard look at this issue.  If we're going to keep 
going down the path of using whatever proprietary technology is 
convenient from the commercial communications world, it's only going to 
get worse.

I've talked to lots of hams about the AMBE codec in particular (it's at 
the heart of the D-STAR voice mode) and what I've learned is that to 
many of them it's just a black box like all of the other black box ICs 
in their radio that they don't understand, and they don't seem to 
appreciate that there's a fundamental difference in that the algorithm 
that it implements is patented and strictly controlled by one company.  
Even if you do know how it works, you're not free to make your own.

Imagine if back in the 50s Motorola had come up with a novel proprietary 
modulation scheme for HF to use in their commercial rigs, kept it 
tightly controlled, and only made tamper-proof, sealed steel boxes with 
the complete circuit inside that were leased and not sold, with the 
contract forbidding any kind of analysis of its working or dissemination 
of technical details.  Would hams have accepted that?  Would we have 
continued to progress technically if we'd resigned ourselves to blindly 
using things we didn't understand and weren't allowed to look too 
closely at?  If homebrew was limited to building support circuits for 
literal black boxes?

Rather than lining DVSI's pockets for the privilege of being dependent 
on their technology, we could be funding Codec 2 development - it's 
already good enough for deployment - and reaping the benefits down the 
road.  That's what we're *supposed* to be doing as hams, building new 
things and sharing information.

The way the FCC rules restrict HF data by symbol rate is kind of dumb 
and outdated, for sure, but this NPRM seems specifically targeted at 
getting Pactor IV legalized.  As someone who makes a living designing 
and selling gadgets for hams, that seems like a pretty sweet deal - have 
the FCC rules changed specifically to permit something you developed and 
that no one else can interoperate with, and simultaneously take the wind 
out of the sails of anyone trying to get traction on a more open 
alternative.  But that's not what ham radio is supposed to be.

You want to keep getting young people interested in radio?  The SDR 
world is where that has to happen.  Open systems are how you keep costs 
down and reduce barriers to entry.  You don't learn anything from using 
secret, proprietary technology.

I've been a ham for 30 years now and people have been bitching about 
"appliance operators" for at least that long.  Maybe what we need now is 
a separate non-commercial appliance operator radio service. Slice off a 
bit of spectrum for the people who only care about having the shiniest, 
most expensive toys, and let them have reserved frequencies so they can 
have their closed nets with their friends and their private email 
services.  Charge annual license fees.  It's a win for everyone - the 
FCC gets more money, the appliance operators and empire-builders can run 
whatever commercial technology they want, SCS and DVSI and the like can 
sell more hardware, and the ham bands get rid of traffic that doesn't 
belong there.

In the meantime, I can't get behind an NPRM that's specifically targeted 
at allowing one specific proprietary mode just so we can have new toys.


On 12/11/2018 9:46 AM, Tyler Griffiths wrote:
> Tyler Griffiths
> See where I am:
> http://map.findu.com/n7uwx-12
> ---------- Forwarded message ---------
> From: *k4cjx* <k4cjx at comcast.net <mailto:k4cjx at comcast.net>>
> Date: Tue, Dec 11, 2018 at 10:33 AM
> Subject: [winlink-programs-group] We are NOT asking, we are BEGGING!
> To: Winlink Programs Group <winlink-programs-group at googlegroups.com 
> <mailto:winlink-programs-group at googlegroups.com>>
> All,
> We are under attack from those who would /misinform/ those who have 
> little knowledge of the work we are doing in the data transfer 
> community. The attack is not specifically regarding Winlink, but all 
> ARQ protocols that we use.  Scare tactics are effective regardless of 
> their connection to reality, and this is what is being done by our 
> opposition, without any semblance to reality.
> ARSFI has responded with as much truth as we can muster, including 
> technical and non-technical accusations that are aimed at ridding the 
> US ham bands of current enabling digital technologies.  The Winlink 
> Development Team through the ARSFI has done its best to provide 
> accurate information. What is needed now is either a strong 
> endorsement of our position, or something of your own making.
> PLEASE, at a minimum, sign in and at least endorse our ARSFI response. 
> When reading the material, remember that the NPRM and resulting Docket 
> only address the 300 baud symbol rate rule within the United States. 
> However, much of our response was written for the purpose of getting 
> rid of the inaccuracies that appear from those who oppose the deletion 
> of the symbol rate rule, and anything else dealing with ARQ protocols.
> You can click on https://winlink.org/FCC_Action to read Mr Rapport's 
> letters and our response to become informed.   Click here 
> https://winlink.org/content/ECFS to learn how to file a comment.
> Click here 
> https://www.fcc.gov/ecfs/search/filings?limit=100&proceedings_name=16-239&sort=date_disseminated,DESC to 
> actually file a comment.   There are plenty of good examples and it is 
> not difficult to do.   We need a large showing of support, and time is 
> limited.
> Thanks for your consideration,
> Steve, K4CJX
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