[SixClub] ARRL needs to wake up ......

jim kd6ppn at peganet.com
Wed Oct 25 07:46:31 EDT 2006


yes , i've followed any links i can find and still come up with basicly 
nothing.    starts of as being "perfectly" suited for 2.4 ghz and then some 
how it is tested on 50 mhz!!!  they also have plans for hf usage too!! 
seems like "they" have gotten many rules "bent" in order to jam this stuff 
down our throats.i know this is a long read, but, the devil is in the 
details. i have asked the ARRL why all the links on this subject don't work, 
why does the committee reports refer to attachments and why the attachments 
listed in the reports are not available, so far no answer.  somehow , i 
think that some one is going to make some $$$ on the patented  (and sole 
source) hardware  that is required.
SECURITY & DATA INTEGRITY

ON A

MODERN AMATEUR RADIO NETWORK

By

Paul I. Toth - NA4AR

Emergency Communications Specialist

ARRL HSMM Working Group

Amended 6/29/2004


EXECUTIVE SUMMARY

This document has been prepared by the ARRL High Speed Multimedia & 
Networking Working Group (HSMM) to highlight a growing need for regulatory 
change governing high speed, wireless data stations operating in the Amateur 
Radio Service. The HSMM respectfully requests the support of the ARRL Board 
of Directors for development and filing of a Notice of Proposed Rulemaking 
(NPRM) permitting the use of encryption and strong security protocols on 
domestic transmissions above 50 MHz.

Part 97 has, for decades, required that all Amateur Radio Service 
communications be conducted "in the clear". ITU regulations and treaties, to 
which the United States is a signatory, prohibited the use of ciphers and 
schemes designed to conceal the meaning of transmitted communications. 
However, an amendment made to Article 25.2A (1A) at the 2003 World radio 
Conference no longer specifically prohibits the use of encryption and other 
strong security measures on transmissions between Amateur Radio stations 
within the same jurisdiction.

Several recent events are driving the need for stronger station access and 
content security. These include:


    1.. . The need to prevent access to Amateur Radio stations by millions 
of unlicensed commercial and non-commercial users operating under Part 15 of 
the FCC's rules.


    2.. . The need for Amateur Radio operators providing emergency 
communications services to observe significant changes in security and 
privacy regulations.


    3.. . The continuing threat to Homeland Security since the 9/11 Attacks 
have caused numerous Federal, State and local agencies to mandating more 
secure communications.

Amateur Radio Service has shared spectrum in harmony with other FCC licensed 
radio services, primarily non-commercial government operators. However, 
commercial, for profit traffic and messages that are prohibited under Part 
97, are now routinely transmitted by millions of unlicensed businesses and 
individuals on bands previously allocated for non-commercial use. Unlike 
Part 97 operators, these non-licensed users are free to employ strong 
industry-standard security protocols to prohibit unauthorized access and to 
protect the integrity of the transmitted content.

The availability of these unlicensed devices, coupled with an armada of 
sophisticated software tools has severely compromised Amateur Radio 
operations on numerous bands. Most notable are bands above 902 MHz, 
including those allocations where the Amateur Radio Service is designated 
the Primary Service. At the same time, Hams are prohibited from securing 
their transmitters, the computers and other technology connected to the 
transmitters and the information those systems store from unwanted 
intruders. It could be said that this has left licensed Amateur Radio 
operators swimming totally unprotected amongst a sea of hungry sharks.

This new landscape seriously compromises the relevance of Amateur Radio 
communications in our Twenty-first Century society. As laws governing 
society and


information mandate more privacy and security, the Amateur Radio Service 
finds itself hamstrung by outdated and outmoded regulations. The existing 
regulations are in direct conflict with policy changes and regulations now 
being used by many disaster responses organizations previously served well 
by Amateur Radio Service licensees. The events of 9/11 have changed the 
landscape for all communications, particularly emergency and 
disaster-related transmissions. Without the legal authority to employ strong 
security protocols, the Amateur Radio Service will be out in the cold, 
unable to serve and fulfill one of our prime mandates. These prohibitions 
will also serve to stifle continuing technological innovation, a cornerstone 
of Amateur Radio.

The HSMM Working Group believes a solution to this dilemma is achievable. 
Changes to international regulations governing Amateur Radio communications 
permit the local governing authority, the FCC, to legalize the use of 
encryption and strong security protocols on domestic transmissions. Further, 
the FCC has publicly stated that a policy allowing it to easily monitor 
Amateur Radio Service transmissions is no longer enforced on frequencies 
above 50 MHz.

Thus, he HSMM Working Group respectfully asks the ARRL Board of Directors 
for their support of this needed regulatory change and urges the Board to 
support the development and filing of a Notice of Proposed Rulemaking (NPRM) 
permitting the use of encyption and strong security protocols on domestic 
transmissions above 50 MHz.

r

KEY POINTS

The HSMM Working Group was established by the ARRL Board of Directors to 
further develop high-speed digital operations under Part 97. Our work has 
focused on several key areas, including:


    1.. . FREQUENCY ALLOCATIONS best suited for Broadband Operations

Amateur radio has several allocations above 420 MHz that are well suited for 
broadband digital operations. These include: 420-450 MHz, 902-928 MHz, 
1240-1300 MHz, 2390-2450 MHz, 3300-3500 MHz, 5650-5925 MHz, and 10.0-10.5 
GHz

. BAND SHARING with Other LICENSED Services

Several of the bands denoted above are shared with non-commercial licensed 
radio services, primarily the Federal government. While the opportunity for 
interference exists, we do not see this as a major issue.

. BAND SHARING with UNLICENSED Operators

In recent years, the FCC has encouraged unlicensed commercial and 
non-commercial utilization of these bands. In fact, WRC-03 made a global, 
PRIMARY allocation of 5150-5350 MHz and 5470-5725 MHz for "wireless access 
systems, including RLANS". The development and mass marketing of low cost, 
low power Part 15 transmitters has resulted in millions of these devices 
operating on the 902-928 MHz, 2400-2450 MHz and 5650-5925 MHz bands. This 
significantly increases the probability of illegal use of unsecured Amateur 
Radio transmitters by Part 15 operators and other security breaches that can 
lead to loss of data and the compromising of attached ancillary systems.

. STATION SECURITY

Part 97 requires Amateur Radio Service licensees to prevent unlicensed 
operators from access to their stations. However, Part 97 prohibits 
licensees from using the industry-standard 802.1x and other security 
measures found on low cost 802.11(a)(b)(g) transceivers. This leaves 
licensed stations open to unwanted and illegal access by unlicensed 
operators, many transmitting commercial content, jeopardizing the licensee's 
privileges.

. DATA INTEGRITY

Part 97 prohibits the use of ciphers and symbols to hide the meaning of 
transmitted message content. The continuing threat to Homeland Security 
following 9/11 coupled with the enactment of stringent privacy policies and 
laws, like HIPAA, prevent Amateur Radio operators from providing needs 
communications services to many disaster responses agencies and 
organizations previously served. This new landscape seriously compromises 
the relevance of "open" Amateur Radio communications in our 
information-driven 21st Century society. This will have a chilling impact on 
the recruitment of new licensees, on


    1..

future innovation and discovery in the wireless realm and on the ability of 
the Amateur Radio Service to provide emergency communications services as 
needed.

The submission and enactment of a Notice of Proposed Rulemaking (NPRM) 
permitting the use of strong security and content encryption will enable 
Amateur Radio operators to abide by existing regulations prohibiting 
unlicensed use of station facilities. It will, further, re-affirm the 
Amateur Radio Service as a relevant and responsive part of the domestic 
communications fabric.


THE CHALLENGES

If someone requested a diagram of a "traditional" Amateur Radio 
communications system, it would probably look like the diagram below. One 
operator, using a Morse Code keyer or a microphone sends a message on some 
assigned frequency to another operator who receives the message with a 
similar radio equipped with a speaker.

It has been seventy years since the Congress and the Communications Act of 
1934 formalized the Amateur Radio Service. While this basic communications 
model is still a valid representation of how Radio Amateurs can communicate, 
the Federal Communications Commission and advancements in communications 
technology now enable us to communicate in many other ways.

For example, the advent of the personal computer in the 1980's led to Packet 
Radio, where a computer connected to a Terminal Node Controller and a radio 
allowed operators to send text to one another, keyboard to keyboard in real 
time or by transferring files located on a disk.

The security of the information and the computer technology connected to the 
Amateur Radio transceiver was not in question because of the relative 
simplicity of the systems and the lack of connectivity to other computers.

The invention of Ethernet, a technology now widely used to link computers 
and other information devices together in a network, further expanded our 
ability to communicate over wired media with these devices. Computer 
networks are now common- place in business and in many homes.

More recently, in the mid-1990s, an Information Revolution was fueled when 
computers of various shapes, sizes, Operating Systems and purposes connected 
to the Internet. A creation of DARPA in the late 1960s, the Internet had 
been used primarily for research by various


colleges and universities as well as by the Federal government. The 
commercialization of the Internet at the end of the Twentieth Century was 
responsible for an exponential proliferation of digital information systems, 
capable of reaching halfway around the world and providing access to 
information in milliseconds. Schools, hospitals, businesses large and small 
and millions of home worldwide are now linked together via the Internet. The 
potential for significant benefit from this degree of connectedness is 
almost boundless; however, the potential for great harm from providing 
access to malicious individuals is also increased.

As computers got smaller, faster, capable of processing many different kinds 
of information, a growing clamor arose for low cost, unlicensed wireless 
connectivity. The groundwork for this use of the radio spectrum had been 
laid by the FCC with the allocation of several unlicensed bands under Part 
15. Most of the early Part 15 broadband devices were slow and expensive. But 
with demand in the marketplace exploding, coupled with the legalization of 
DSSS and OFDN, low cost Part 15 devices became plentiful.

Part 15 transceivers operate with low power output and other restrictions 
that limit their overall range. Manufacturer adoption of several IEEE 
standards, including 802.11(a)(b)(g) has empowered millions of unlicensed 
individuals, businesses and government organizations to get on the air. In 
some cases, remote offices are now connected to the main office using these 
radio transceivers, eliminating costly data circuits leased from the local 
phone company. Much of this activity uses spectrum that overlays the Amateur 
Radio Service allocations at 902 MHz, 2.4 GHz and 5.7 GHz. Further systems 
may include the use of Part 15 frequencies that reside within the Amateur 
Radio Service bands between 1240 MHz-1300 MHz and 3300 MHz-3500 MHz.

Amateur Radio operators have successfully shared spectrum with other 
licensed, non-commercial Radio Service users, including the government. 
These other stations operate within rules that mirror Part 97. Stations are 
required to identify themselves. Their operating modes are defined and 
emissions quantified.

The impact of the FCC's decision to permit unlicensed, broadband radio 
transceivers to operate under Part 15 on frequencies shared with the Amateur 
Radio Service has dramatically changed the landscape for Part 97 users. Part 
15 hotspots (Wireless Access Points) are commonplace. Signal saturation from 
unlicensed users is an increasing problem, particularly in large urban 
areas.

Part 15 rules lack compatibility with Part 97 in a number of other 
significant ways. Part 15 rules do not require station identification. Part 
15 operators are free to convey commercial traffic in which they have a 
pecuniary interest. There are no prohibitions on the use of encryption and 
other security measures to protect the many computers, disk drives and 
information stores connected to these radios. These strong security tools 
can also be freely used (and are commonplace) to secure the authentication 
process as authorized users attempt to gain wireless access to the 
information resources, including the Internet, connected to these Part 15 
transceivers.


A typical Part 15 wireless network, operating with IEEE standard 802.11a/b/g 
radio technology may look like this.

It is a common and best industry practice for User Authentication and 
passwords to be transmitted using strong security protocols. It is also a 
common and best industry practice for messages and other data to be 
"tunneled" using Virtual Private Networking, sets of protocols that 
purposely make it extremely difficult for data theft by radio signal 
interception to be successful. As you can easily see, this is significantly 
more complex that the Communications Model shown at the beginning of the 
document.

If Radio Amateurs are to exercise the operating privileges they have been 
granted on several assigned bands now openly used by non-licensed Part 15 
operators, we, too, will need the freedom to utilize the same security tools 
and protocols to keep these unlicensed users from access our stations. 
Computer programs, like NetStumbler, permit anyone with a WLAN transceiver 
to eavesdrop and intercept broadband data signals and decipher their 
content. This has led to numerous computers and networks attached to these 
wireless transceivers being breached, compromised and ransacked. Several 
State and Federal courts have ruled it is the responsibility of the wireless 
transceiver operator to prevent would be intruders from breaching these 
transceivers and the information resources attached to them. Without the use 
of Authentication servers and protocols, firewalls, Virtual Private 
Networks, Secure Socket Layers and other Information Management tools, these 
radio transceivers and the other technology and data connected to them are 
indefensible to attack.


REMEDIES

Radio Amateurs are REQUIRED to SECURE their transmitters and prevent access 
from anyone not holding a valid Technician Class or higher Amateur Radio 
license [97.5(a)]. Because the industry standard tools needed to accomplish 
this are prohibited under Part 97, this requirement has created a virtual 
impossibility.

Further, laws and regulations governing information security and release 
have changed dramatically as concern over personal privacy has increased. 
The HIPAA laws and private and governmental Privacy Policies have raised the 
bar on the transmission of many kinds of information and personal data. This 
severely limits the ability to the 21st century Radio Amateur to provide 
critical, relevant communications service and conduits during and after real 
emergencies.

IEEE standard 802.1x exists to provide a roadmap and standard for station 
authentication and access to broadband, wireless data systems. Other 
industry-standard protocols, including but not limited to WEP, EAP and LEAP 
are commonly used outside the Amateur Radio Service to provide secure 
station and user authentication.

Licensees in the Amateur Radio Service need to be free to utilize these and 
other industry-standard security and authentication tools to protect the 
integrity of their stations, particularly on bands shared with Part 15 
operators. Amateur Radio Service licensees should also be allowed to protect 
the security and the integrity of the information their stations are 
conveying. Use of PPTP, Secure Socket Layer (SSL), Secure Shell (SSH), 
Virtual Private Networking and other standard protocols and tools are 
routinely used to convey information in a secure manner on wired and 
wireless links. Amateur Radio operators should be permitted to use these 
tools as they represent "good engineering practices" in modern data and 
information management. Information conveyed in the clear is no longer an 
option for many essential service providers who rely on Amateur Radio 
operators when normal communications systems are not available.

These measures will enable Amateur Radio Service licensees to successfully 
co-exist with operators governed by other rules and operate in accordance 
within other Part 97's specifications, resulting in a minimum of 
interference and security concerns. They will allow the development of 
Amateur Radio infrastructure capable of yielding new, innovative 
capabilities and methods, proving out those capabilities and methods under a 
variety of operating conditions, allowing licensees to communicate in ways 
never before possible. This will lay a solid foundation for Amateur Radio 
Service licensees nationwide to use our assigned spectrum and license 
privileges to provide essential, relevant emergency communications services 
to our communities when they need us the most.

The popularization of the Internet has fueled an information-driven society. 
Add to this a policy of spectrum sharing and the events of 9/11/2001. The 
realities of the 21st Century present a difficult and challenging operating 
landscape for the Amateur Radio Service. It is time to modernize Part 97 to 
reflect these changes. This will allow U.S. Radio Amateurs to continue a 
proud tradition of innovation and service when it is needed most.


ACKNOWLEDGMENTS

This document was developed with significant input and expertise from 
members of the HSMM Working Group, including:

John Champa-K8OCL

Gerry Greager-N5JXS

Walt Dubose-K5YFW

Dave Anderson-KG4YZY

Dave Stubbs-VA3BHF

Ron Olexa - KA3JIJ

Joe Cupano-NE2Z

Jeff King - WB8WKA

Carl R. Stevenson-WK3C

Howard Huntington-K9KM

----- Original Message ----- 
From: "KC2FTN in N.Y." <kc2ftn at hotmail.com>
To: <sixclub at mailman.qth.net>
Sent: Tuesday, October 24, 2006 7:32 PM
Subject: Re: [SixClub] ARRL needs to wake up ......


> Thanks Bruce... I've added the link to Hamwave as well.  It's at:
> http://www.hamwave.com/cgi-bin/index.cgi?action=forum&board=ragchew&op=display&num=466&start=0#0
>
>
>
>
>
>
>
>
>>From: bruce mallon <wa4gch at yahoo.com>
>>Reply-To: World Wide Six Meter Club <sixclub at mailman.qth.net>
>>To: World Wide Six Meter Club <sixclub at mailman.qth.net>
>>Subject: Re: [SixClub] ARRL needs to wake up ......
>>Date: Tue, 24 Oct 2006 06:44:14 -0700 (PDT)
>>
>>
>>http://www.arrl.org/news/stories/2005/04/13/1/
>>
>>They increased it to 200 khz when they thought it was
>>a done deal ......
>>
>>The FCC has shot it down ( FOR NOW )
>>
>>BUT THEY WILL NOT GIVE UP ..... ALSO the permit may
>>have expired It looks like they had to renew it again
>>no one is talking ..... ARRL it it's best ......
>>
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