[PVRCNC] FYI- please write into FCC ECFS “reply to comments” in FAVOR of NYU Petition for openness and transparency in amateur radio

[Ted N9NB]

Dear Fellow Ham and club member:

I know this is controversial, and many of you are not interested in this, or may be opposed to my or others’ views. 

Therefore, this will be my only note to the reflector on this “reply to comments” matter that is pressing at the FCC. 

As a colleague of yours and fellow ham who cares about our hobby’s future and our country’s future, I think this information bears consideration, in light of a major action in front of the FCC that has a 7 day deadline from this Monday. Feel free to delete if you have no interest in reading further.

Even if you have filed comments in the past to the FCC ECFS , and even if you did so very, very recently, this requires attention, and more specific action within the coming week.

Its coming to the end of a near 20 year effort- 7 days left- and I ask that you please consider filing “reply to comments” specifically against the ARRL, ARSFI and RRI filings all dated Dec 2, 2019, and in favor of: (1) NYU’s petition for openness and in favor of NYU’s ex parte comments dated Dec 2, 2019, (2) in support of modem expert Nelson Sollenberger who showed in his Nov. 18, 2019 report that Pactor and Winlink data modes are not properly documented, and “nearly impossible“ to intercept for meaning. Sollenberger also shows that Pactor 4 is spread spectrum, and the potential beginning of much more wideband data aggression that the ARRL, ARSFI, and RRI are likely positioning  for, and (3) in support  of the Marcus Spectrum Solutions filing of Dec. 2, 2019 in favor of NYU’s petition where Marcus explains why there is an urgent need for the FCC to address the current problem with the Part 97 rules, the effectively encrypted data, and the well- documented improper bypassing of other radio email services today.

Please - for our beloved hobby- please take a few minutes to read/scan these items, and please file some specific comments against  the ARRL, ARSFI and Radio Relay International positions of Dec 2, 2019 (and in favor of NYU, Sollenberger, Marcus and others) by using “reply to comments” simultaneously in 16-239, RM-11828, RM-11759,  RM-11831, and RM-11708. See the various public comments at:
> 
> https://www.fcc.gov/ecfs/search/filings?proceedings_name=16-239&sort=date_disseminated,DESC

> There are Only 7 days left to file “reply to comments” in favor of NYU’s openness petition, and against the ARRL, ARSFI, and RRI who are opposing the transparency and openness petition of NYU. This
> is our hobby’s last shot at defending ham radio transparency and openness for the long term- before the floodgates of digital data open up.
> 
> ARRL is currying favor to a tiny minority of hams who want to use HF ham radio for private, closed email systems, ignoring the pleas from hams and experts dating back 
> almost 2 decades - NYU explains this clearly in their ex parte filing dated Dec 2, 2019. And the ARRL and ARSFI and RRI appear poised to  soon ask the FCC for massive wideband data /and wideband spread spectrum modes for email in the ham HF allocations if NYU’s petition fails.

Some points you can make in your “reply to comments” are that ARRL, ARSFI and RRI have flawed arguments and misstatements of fact, and their positions do not represent the best interests of ham radio or the USA in their Dec 2, 2019 filings.

Specifically, you can point out that any government may choose to modify or adopt/execute different, or more stringent, language than the verbatim ITU treaty language- FCC knows this, but your comments should call the ARRL out on it. Most countries of the world do not allow ACDS systems or obscured data such as that used by Winlink to be used
in ham radio, due to 3rd party regulations and due to other government’s own interpretations of the ITU wording about “obscured transmissions” in ham radio. There has been at least one widely publicized 150-page example of massive rules violations provided to the FCC’s Enforcement Bureau - an action sent to Laura Smith at the FCC-  and many public filings to the FCC over the last 2 decades of interference and many other rule violations, as well as documented reports by technical experts that the data modes used by Winlink with dynamic compression and ARQ cannot be intercepted  over the air by others for meaning—and such dynamic compression offers very little improvement in data throughput or efficiency over open, static compression methods used by the vast other data modes that can be intercepted for meaning by others —-call these parties out on these and other facts, Please, in your “reply to comments” and spread the word please.

ARRL, ARSFI and RRI have been lobbying the FCC aggressively for wideband, effectively encrypted email and file transfer modes since the flawed ARRL Ad-Hoc HF digital committee in 2003 that railroaded the ham bands for Winlink/ARSFI while ignoring the expertise of Amtor’s inventor and the PSK31 digipan inventor,  and ignoring the widespread ham radio population in RM-11306 and more recently in RM-11708 and  WT Docket No. 16-239. 

Please write in to show the FCC that these groups are still ignoring what is in the  best interest of the amateur radio service, as they argue to defeat NYU’s much needed petition for openness to ensure our hobby can self police, is open,  and is not commercialized for private networks as technology continues to evolve. 

Please file “reply to comments” simultaneously in 16-239,  RM-11828, RM-11759, RM-11831, am
and RM-11708, speaking out against the private email aggression,  and pointing out the problem with just relying on “toothless” language of “intent” that ARRL, ARSFI/Winlink and RRI use in their Dec 2, 2019 filings to exploit the ham bands for private email networks that spur massive misuse of the ham spectrum, without the ability to self police or remain open to others. 

Please give specific reasons against their (ARRL, ARSFI, RRI) comments of Dec 2. 2019,  and please urge for  FCC to enact NYU’s declaratory ruling before doing anything else with any other rulings that would expand digital use in ham radio,  so our hobby may assure openness, self-policing abilities, and so it can grow, attract new entrants in an open/sharing manner, and prevent further abuse of the ham radio spectrum as technology continues to advance.

Note,  your comments should be unemotional, explain your credentials and any  ARRL membership/ affiliation and ham call and experience. And please specifically comment against particular items of the ARRL, ARSFI and RRI comments of Dec 2, 2019, and speak out in favor of NYU’s petition for transparency, and in favor of RM-11831 for transparency and interference protections for narrowband operations, in support of Nelson Sollenberger’s and Mike Marcus‘ and Lee McVey and Ted Rappaport’s expert opinions on these issues. Be sure to state you are against 16-239, and against RM-11828 that would allow 385,000 untrained technician class hams to have instant access to HF data and effectively encrypted email, that will not help STEM at all, but rather will harm America by further dumbing down the ham radio hobby (which has published answers for all exams) while allowing the valuable HF spectrum to be used for more private email systems that will interfere with narrowband operations and provide more users and messages that cannot be self-policed by other hams or the public. 

I am posting this publicly, one time only, since there is a vast internet smear campaign being waged right now against NYU and its petition for openness and transparency - the campaign is aimed at getting people to support the ARSFI and ARSFI/Winlink petitions 
 - here  is  just one example of what is being spread globally.
>> 
>> http://radio-relay.org/bulletin-take-action-fcc-action-pending/

The above link is quite untrue— its simply not a true or fair characterization, but is being used to incite rancor and comments into the FCC  by the minority that want to perpetuate effectively encrypted email in ham radio. We need to stand up for our hobby and spectrum at the FCC.

All that is being asked by NYU in its openness petition is for  Winlink and any other data modes in ham radio to be open and properly documented   
to allow reception by others in ham radio to ensure that everyone can “copy” the transmissions (just like all other Digital  modes such as ft-8, rtty, psk-31, Ft-4, etc.) used in ham radio do today) .

Many experts such as Nelson Sollenberger, Mike Marcus , myself, Lee McVey, and many others in the record, have shown that all WINLINK needs to do is adopt a static compression and use data modes that are properly published and documented - so others can make receiver software or hardware to copy the transmissions. A very easy fix.

In fact, modem expert  Nelson Sollenberger showed the FCC  in mid Nov 2019 that Winlink modes are not documented and are “ nearly impossible” to understand for meaning. This can be easily fixed at no loss to Winlink or any other future modes if the  FCC clarifies the rule as requested in NYU’s petition. 

Please, we need you and all you know to see this, and become active writing in support of the NYU petition for transparency and open data- please spread the word as we need people to care. 7 days left to file “reply to comments” with specific comments that tell FCC why they should be AGAINST 16-239 and AGAINST ARRL’s petition RM-11708, AGAINST ARRL’s petition RM-11828 that asks to instantly add 385,000 new HF data technicians for effectively encrypted email , and against AGAINST ARRL’s RM-11759,  which would allow for a new 50 khz allocation for wideband data while taking the 50 kHz away from  SSB. 


Please urge the FCC to first and immediately adopt NYU’s petition
for openness,  and to adopt the items  in RM-11831 BEFORE acting on 16-239 and BEFORE acting on any of the many ARRL-authored petitions for digital aggression. 

Thanks for your action on behalf of ham radio, and please spread the word! 7 days left. I promise not to send anything else on this particular action. 

Thanks for reading if you made it to this line!

73 ted N9NB 

> On Dec 4, 2019, at 2:48 PM, Ted Rappaport N9NB <tsrwvcomm at aol.com> wrote:
>>> 
>>> Important:  we need your activism for the hobby! We need support for the NYU Petition for openness and transparency.
>>>  
>>> This Nov 16 fililng by modem designer Nelson Sollenberger exposes the charade of being able to copy Winlink data – its nearly impossible to detect. Worth reading and citing! ARRL doesn’t subscribe to this and claims “nothing there to see” as does RRI and ARSFI.
>>>  
>>> https://ecfsapi.fcc.gov/file/11170346002261/FCC%20letter%20RM-11831%20WT%20Docket%20No.%2016-239%20%20Nov%2016%202019%20NRS.pdf
>>>  
>>>  
>>> Please have all your friends read the NYU and the ARRL and ARSFI and RRI and Marcus Spectrum solutions filings of this week..… find them at :
>>> https://www.fcc.gov/ecfs/search/filings?proceedings_name=16-239&sort=date_disseminated,DESC
>>>  
>>>  
>>> We need massive thoughtful “REPLY” to comments by Dec. 16.
>>>  
>>> These are really the key issues --- The ARRL is really reaching when they say 97.113(a)4 cannot be changed – that is so bogus, all countries have a right to make their own government laws tighter or different  -= -FCC knows this and ARRL must be called out on this charade! More of the same, just like when Imlay was legal head, take an optics vote 14-1 in july, print it in QST, and then argue at the FCC for something totally different with the Exec Committee in toe! ARRL Exec Committee is ignoring the July 2019 vote on item 31, and trying to “dupe” ARRL members and all of ham radio.
>>>  
>>> Word really must get out far and wide on this – look what they told the FCC when they visited in Nov.(in that same link above).
>>>  
>>> Hard to believe as ARRL lobbied for RM-11828 (385,000 instant HF technicians for digital email) and WT Docket No. 16-239 saying nothing needs to be done!!!!
>>>  
>>> The ARRL is using a fake legal argument, claiming that ITU treaty language prevents them from changing 97.113(a)4. This is a bogus argument since most countries do not use verbatim language, and are allowed to enact more stringent regulations as they desire. We need to expose their arguments and those of ARSFI and RRI for simply trying to justify their “effective encryption” email that violates other amateur radio rules and cannot be copied by others. NYU and Nelson Sollenberger have shown how the “claims” of copying over the air are very staged and cannot be done unless perfect channel conditions exist:
>>>  
>>> Please, get out the world and make clear you stand in support and ask FCC to enact the NYU Petition for Declaratory Ruling to ensure all data can be listened to for meaning. Urge for support of RM-11831, and urge denial and immediate rejection of RM-11828, RM-11759, and WT Docket No. 16-239.
>>>  
>>> Make clear that most countries in the world do not allow the 3rd party email traffic that Winlink and ARSFI and RRI are seeking, and point out that an enforcement bureau violation  (we cited in the NYU filing ) simply proves the vast violations that have been occurring on the amateur radio bands for decades, all the while that ARSFI and ARRL and RRI turn a blind eye.
>>>  
>>> Must discuss the points and the arguments and show why they are wrong! They are really wrong!
>>>  
>>>  
>>> To file a REPLY to comment: Go here:
>>>  
>>> https://www.fcc.gov/ecfs/filings
>>>  
>>> Half way down the page, there is a “Type of Filing” and pick “REPLY”
>>>  
>>> Please make your subject/title something like “Reply to comments regarding NYU, ARRL, ARSFI, RRI and against RM-11828”
>>>  
>>> Please file in these 4 proceedings at once: 16-239, RM-11828, RM-11759, RM-11831, state your qualifications up front. Please spread the word.
>>>  
>>> Your comments need to address the ARRL and ARFSI and RRI comments that are against NYU petition, WE NEED Your SUPPORT for the NYU petition for openness, give reasons (see NYU filing this week for good info), and please ALSO point out the huge problems with ARRL’s visit to FCC in Nov where they argue for “nothing there to see” in 16-239  (bogus – they claim the carefully staged tand the pitfalls and dangers in their desire to have 385,000 instant technician upgrades without knowledge or expertise to enter into the entire HF bands  - digital aggression (That is what RM-11828 is!)
>>>  
>>> This is a true HF takeover that has been going on for 2 decades being led by a few leaders at ARRL.
>>>  
>>> thanks, spread the word please! REPLY to COMMENTS are due by Dec 16, 2019. file in all 3 “16-239” “rm-11828” “rm-11759” “rm-11831”
>>>  
>>> ted
>>>  
>>>  
>>> Here is an ideal template, before the ARRl filed its comments to try and kill the NYU petition. These views can be included in your REPLY that urges support for NYU’s petition and for RM-11831, while denouncing RM-11828 and WT Docket No. 16-239.
>>>  
>>> https://ecfsapi.fcc.gov/file/11191620409997/NathanMoreschi.pdf
>>>  
>>> Please see above links, and add that you disagree with ARRL’s views and RRI/ARSFI views on the NYU petition.
>>>  
>>> We need to show they are all aligned trying to turn ham radio into a free email service,  and they are in defiance of the ARRl 14-1 vote on item 31 in the ARRL  July 2019 board meeting.
>>>  
>>> https://ecfsapi.fcc.gov/file/11191620409997/NathanMoreschi.pdf
>>>  
>>> Please get active, and spread the word, to write in to support the NYU petition and to make comments about the comments of previous filers—- we have untim Dec 16 to write into 16-239 and askfcc to disregard ARRL, ARSFI, and RRI positions and to uphold the majority of hams.
>>>  
>>> Thanks - 73- ted N9NB