Last Updated: 12/03/2018
There is considerable ongoing chatter out there regarding the FCC NPRM Docket 16-239 and some questions regarding Pactor 4 and B2 compression legality. The recent “Rappaport Suggests National Security Risks with Amateur Radio Violations” article in Mission Critical Communications has prompted more attention even if some of it is laughable.
It looks like the FCC recently asked some interesting questions in a good read here (PDF). Peter (DL6MAA) did a good job of answering their request and made some noteworthy points. Still this seems to have alarmed some Pactor folks about the future of Pactor 3 and 4. IMHO don’t be alarmed, this looks like the FCC is just doing some fact gathering versus accepting the FUD out there at face value. That is a good thing.
It is also interesting what the FCC didn’t ask about.
Short version of this rant for those worried about Pactor or Winlink being banned? Don’t worry, no matter how much certain folks may dislike it, neither Pactor or Winlink are going away. Pactor 1-4 protocols are documented. Pactor 1-4 connections can be monitored. Compression of data on a link does not equal encryption. I suspect the FCC will soon “explain” this to certain crowd once they sort through all the FUD and get the facts sorted out. Plus there is nothing stopping the FCC from “adjusting” the rules to deal with gray areas.
Moving on to the long version….okay very long version 😉
Note that this post started out as commentary on a handful of common questions, myths, misrepresentations, and an occasional good question, etc etc regarding this NPRM. It has grown into a mini novel that I keep adding to it as time allows. Yes it could be written and organized better. I don’t proclaim to be a great writer and frankly you’re getting exactly what you paid for 😉 Take a patience pill and deal with it or move on.
Also note that I am not a lawyer nor do I play one on TV.
Since so much uninformed commentary surrounds this NPRM, here are a few pieces of mandatory reading. Mandatory reading if you wish to be informed enough to have a useful opinion versus just adding to the noise floor:
The ARRL’s original petition for rule making is here. This is what started the process along several years back. They fixed a mistake in the original filing with an errata here. You have to read and understand both of these filings. Too many latched onto that mistake (fixed) and it’s behind a lot of the unproductive garbage in the NPRM comments.
Then ARRL CEO David Sumner’s “It Seems To Us” column in the Sept 2013 QST Magazine.
The NPRM itself is here.
DL6MAA’s (SCS engineer) response to the FCC is here.
Read the official filings, not copies posted elsewhere. Go to the official source, get the full context, and think for yourself versus letting the alarmists push your buttons.
The Pactor 2 Protocol document (8 page PDF) here.
The Pactor 3 Protocol document (11 page PDF) here. Good read for a digital ham.
The Pactor 4 Protocol document (42 page PDF) here. Another good read for a digital ham.
FACT: The Pactor modes (1-4) can be monitored by anyone with an appropriate receiver and modem. There is also software available for monitoring Pactor. I’m not aware of anything stopping folks from writing more robust monitoring tools. The protocol’s technical characteristics are documented.
KEY POINT: Where so many tend to get off track here is associating the B2F transfer protocol used by Winlink and other message forwarding systems as a part of Pactor. It is not part of Pactor, it is used by some applications that run on top of Pactor, HF Packet, Robust Packet, VHF/UHF Packet, and a growing list of soundcard modem based modes.
From the FCC letter to SCS it appears they are just doing due diligence on a mode they have recently issued temporary waivers for. The focus appears to be on confirming compliance with this portion of rule 97.309(a):
“(4) An amateur station transmitting a RTTY or data emission using a digital code specified in this paragraph may use any technique whose technical characteristics have been documented publicly, such as CLOVER, G-TOR, or PacTOR, for the purpose of facilitating communications.”
SCS provided links to detailed documentation that should more than suffice. While not specifically required here, Pactor 1, 2, 3, and 4 all have full official ITU emission designators of 304HF1B, 375HJ2D, 2K20J2D, 2K40J2D respectively.
Remember the matter before them only involves dropping the symbol rate restrictions. Claims of Pactor 3 and 4 legality came up and they decided to look into them since Pactor 4 is a current rule impacted mode that the FCC has issued several emergency waivers for.
Thus far (maybe I missed it) the FCC doesn’t seem concerned at all about B2F compression used in many digital applications, but that is subject to change. Part of me would like to see them issue an opinion on this and put a good chunk of the anti-Winlink drama to rest.
For some of you….be careful what you wish for.
Many feel the Winlink links on HF are encrypted or an attempt to intentionally obscure the meaning of a message. They are not encrypted nor secure from monitoring. They just use a documented protocol for compressing data being sent over a link for purposes of transfer integrity, small attachments, and a significant reduction in airtime used.
Details of the B2F protocol and compression used are publicly documented. The VB source code used by Winlink itself is available here for free. LZH has been around for ages and for the Linux folks the source and utilities are easy to find.
I would suggest those essentially wanting the FCC to ban encoding and compression of digital data on the ham spectrum to stop and do some research. Research just how far and wide such techniques are commonly used for legit and beneficial purposes. Picture the future of the digital side of our hobby without that. Unless you are a die hard analog only op this could easily backfire on you.
Yes the automated digital stations can be annoying and cause unintentional QRM. Dude, I get it. I operate APRS up in the top end of the 30m band and it gets ugly in there at times. With the solar cycle being where it is the lower bands have become even more congested. It is what it is.
Should we maybe create some structure to where the Winlink gateways should congregate versus being spread out all over the place akin to how the HF APRS folks stay up in the top khz of 30m? IMHO yes but that is a bandplan issue, not a mode legality issue.
Our HF bands are shared spectrum and yes even the automated stations suffer from QRM. Our HF bands are not a perfect world for a hobby like amateur radio and neither you, I, the ARRL, or the FCC can make them perfect. Try more tolerance, understanding, and keeping a bottle of Patience Pills handy.
If the amateur radio hobby is stressing you out then maybe you need a new hobby? Give fishing a try 😉 I’m with Mr. Foreman except I’d add camping to the mix. Riding into the backcountry to camp next to a stream or lake to get some fishing in = my happy place.
“Anytime I can sneak in a moment to fish and ride horses, I’m a happy camper!”
What is behind this latest dramafest?
Now let’s not kid ourselves here, a review of the filed comments reveal this drama is filled with Winlink/Pactor hate. That coming from a guy who is not exactly the biggest fan of Winlink. I have warmed to it somewhat lately, but I still have some abuse, security (spoofing, viruses, etc), and management concerns with it. That is an issue with the application(s) involved, not the particular digital mode in use under that application.
One of my ham mentors was fond of that saying along the lines of “ham radio is just a reflection of our society. As such we can’t be surprised by what we see and hear.” My gosh how true is that today. Some fair questions can be asked here, some changes are needed, but some just can’t put the bucket of mud down and be adults.
This drama is really nothing new as this has flared up several times over the years. Sadly few seem to be able to separate Pactor 3/4 from Winlink and could wind up with some some dangerous precedents that could easily bite their own backsides.
I have always enforced an unwritten rule that the KYPN blog stays focused on ham radio, especially packet radio, and far away from politics, religion, and guns. Three often controversial topics that lately drive so much of our national conversation to unhealthy levels. So forgive me here but a lot of this latest NPRM debate I see playing out reminds me of the “gun debate” in our country. Lots of emotion, FUD, ignorance on multiple levels, absolutism, well intended folks simply not understanding all the angles of what they are commenting upon, lots of money (both sides), and endless politics/agendas. Too often it is all about “beating the other side at any cost” versus being reasonable adults open to both sides of things. Welcome to modern America, SMH RME LOL.
PS – For the record I’m Pro-2A akin to Justice Scalia and Sheriff Ozzie. Scalia in terms of the 2nd Amendment IS an individual right to keep (own, possess) and bear (use/carry), but it is NOT a blank check..there have to be some rules/limits. A Sheriff Ozzie Knezovic in that we dearly need to stop the political nonsense and have a civil discussion about the mental health, cultural, and parenting aspects behind the problem versus solely focusing on inanimate objects. Folks we have kids killing kids. Let that sink in.
Okay, I’ve climbed out far enough on that particular limb, back to ham radio.
Do we really need to make these rule changes?
Yes and it should of been done years ago.
It is obvious that the current regulation by symbol rate is obsolete. The growing list of Pactor 4 waivers from the FCC for recent major disaster operations clearly illustrates the problem with the current rules.
Remember Pactor 4 requires no more bandwidth than Pactor 3. The current rules prohibit Pactor 4 due to it exceeding the allowed 300 baud symbol rate limitation, not because it’s some spectrum devouring monster. It runs at 1800 baud symbol rate which makes it illegal on U.S. amateur bands while legal most everywhere else.
Our current “regulate by symbol rate” approach needs to be changed to reflect modern communication techniques and modes. This change will bring the U.S. rules more inline with those in other countries, remember HF signals don’t stop at borders. It will allow more experimentation and development towards other higher performance and more spectrum efficient modes/modems. This will also help facilitate more efficient message transfers with modes like Pactor 4 that are well suited to EmComm needs.
We can debate how to get there in terms of the actual language of the rule changes, but advanced high performance modes like Pactor 4 need to be legal on the U.S. ham bands.
Jeff there is more to the hobby than just EmComm.
Yes I get that the hobby is not solely about EmComm. Yet many non-EmComm hams would be wise to remember that we don’t get to keep our very valuable (increasingly so) spectrum just for contesting and DXing. No that is not a dissing of those activities as I enjoy both, just stating a fact.
Is there some good that can come out of this latest NPRM mess?
Sure there is. There are some fair questions to be asked and some rule changes need to be fleshed out. Sadly a lot of what is currently playing out here is not the way to go about it. Certain hams need be ashamed of themselves. I can only picture the eye rolling and facial expressions at the FCC as they read through some of the filed comments.
I actually think there are some things here that an official ruling/opinion from the FCC would be healthy for the hobby. Example? Does the common and decades long standing practice of using documented compression techniques on digital links equate to “intentional obscuring of message content” and thus a violation of rule 97.113? As a long time packet/digital radio op I’d love to see this officially dealt with one way or the other.
Remember you will not find the word encryption in the Part 97 rules. There is nothing in the rules mandating everything be clear text. The relevant phrase here is “messages encoded for the purpose of obscuring their meaning.” How will the FCC will apply that to simply just “encoding” data flows with documented compression techniques commonly used for legitimate communications for purposes of transfer integrity, attachment capabilities, and significant reduction in airtime used, etc?
Heck if you want reduced congestion on the HF bands then you should be demanding that those transfers be done using compression techniques. Do you want that 10 minute connection to now take 20 to 30 minutes? I didn’t think so.
Is this NPRM dangerous to the hobby’s future?
I feel reasonably confident that the FCC will be able to dig out the relevant facts from under all the drama here. From there it should not be hard for them to clear both Pactor 4 (plus similar modes) and open/documented compression techniques for use on our bands via some well thought out rule changes/tweaks and formal opinions. That is if they even look at the compression topic. Good FCC rulings/opinions here will be healthy for the digital side of the hobby, not the end of it.
I doubt this will go the way some people think it will and they might as well get used to hearing more Pactor 4 on the U.S. airwaves. Pst…it’s already in legal use in other countries. HF signals ignore lines on a map so you’re already hearing it on the bands. It’s both sad and odd that this needed rule change has created so much drama. Oh well, welcome to modern America where everything has to be high drama and a crisis. LOL
Pactor 4 is being used that elsewhere?
Actually Pactor 4 looks to be very popular across the globe…..except the USA.
Note: Some will notice the low traffic counts for every other HF mode (ARDOP, Robust Packet, VARA) and assume they are hardly used which is not true. Remember this represents “reported” traffic and will be connection data from Tri-Mode (HF) and RMS Packet (V/UHF) gateways. Tri-Mode tends to be gateways running the Pactor and WINMOR modes. The other HF modes tend to be found on BPQ32 gateways which do not report traffic counts. Thus traffic count data for those modes is so far off it is useless. That said, still a lot of P4 message traffic on the Tri-Mode gateways.
Is there risk in asking the FCC to get involved?
Yes, of course. I would again remind some of these hams of that wise old ham radio saying along the lines of “Let us self-police our hobby and think twice before we ask the FCC to rule on something. We could wind up with a ruling that no one likes.”
The “National Security” implications?
Oh give me a freaking break….
Allow Tommy Less Jones to mimic my expression after reading some of this ignorance of existing terrorist and drug cartel communication networks.
As someone with a LE background, has read a few EPIC bulletins in his day, and has been through some SIGINT training I can assure you of the following. If the terrorists or drug cartels want secure communications they either already have or can have them via a wide variety of tools. If any ham gear or modes are in use then that is only out of simple convenience and not because it was the only option available.
These folks are criminals that couldn’t give a rip about our precious FCC Part 97 rules or any changes we might make to them. Heck I can think of several ways for a cartel or terrorist network to use legit looking or sounding communications, in the clear, on ham/CB/LMR/Maritime spectrum to send “coded” messages that you wouldn’t give a second thought to.
Never mind all the better, faster, more secure methods these criminals already have available to them…..and are actively using.
But Jeff the FCC says they can’t monitor these new fangled digital modes?
First, note that I have that T.L. Jones expression back on my face.
Second, so you really believe that they can’t monitor them if they wanted to? If not, then they could not just pick up the phone to Ft Meade or Langley and get whatever tool they need? Do you expect them to fully detail all their monitoring capabilities to us?
Folks if a new or existing ham radio digital mode creates a serious National Security risk then we might as well cancel the entire amateur radio service. The very essence of ham radio is developing new and creative ways to pass communications along. It is called advancing the art of radio communication and it is one of the primary reasons why the Amateur Radio Service (ARS) exists to begin with.
Folks we hams are not special, but we are part of a unique radio service. We will always be coming up with new voice and digital modes. Yes the FCC may not be instantly keeping up with all of them, but that’s not our fault. That’s not the fault of Winlink. That’s not the fault of SCS. Not the fault of the Pactor folks.
Frankly it’s not the fault of the FCC either. They have limited resources and a budget that they have to operate within. News Flash for some of you….as long as we (hams) stay reasonably within our lane they are not overly worried about what goes on in the ham spectrum. They have other higher priorities and problems to deal with.
The rules governing the ARS have to be limited and flexible for the service to thrive and advance the radio art as we progress into an increasingly digital future.
Transparency of ham radio communications?
Now this is a part of this drama worthy of some discussion. I do feel that our generally self-policing hobby requires reasonably open communications on our airwaves. Where we all will likely never 100% agree is the definition of “reasonably open” LOL.
So Jeff you must be against Pactor 4 and similar modes? Nope, you can monitor those communications if you buy the appropriate hardware and/or software. No different than if say you wanted to monitor Yaesu’s FUSION, D-Star, HSMM, and whatever the latest DD/DV mode of the year is.
Just because you can’t monitor a mode as easily as you would like or for free does not mean it is encryption or “intent to obscure the meaning of a message.” I think even the FCC will agree with that last sentence.
I think where we start getting into murky waters ripe for abuse is with the applications we run over various digital modes, not the modes themselves. When you drill down into what is behind so much of the drama in this debate it is obvious that Winlink is where most of it is focused.
There is no doubt that the Winlink system has been used for sending/receiving content in violation of the FCC rules. BTW so has AM, SSB, FM, CW, and the latest DV/DD modes. The Winlink leadership is aware of it otherwise gateway sysops would not of received the following message from them back in April 2015:
Date: 2015/04/29 From: W3QA Source: WEBMAIL Subject: Sysop Reminder --SPECIAL MESSAGE-- All WInlink Sysops, As a Winlink gateway station sysop and licensed operator you must monitor the traffic moving through your station. By monitoring, you can manage messages your users might create that violate the terms of your license. We have noted illegal content rising in recent weeks, especially for US licensees, where business content that benefits a licensed amateur, profane language, and certain third-party messages are violations of FCC rules. Please refresh yourself on your license's transmission content rules. In case you didn't know, you have access to a sysop-only web app that lets you view and manage the messages posted or delivered through your station. Here's how to access it: Log into the Winlink web site at http://www.winlink.org using the callsign of your gateway station. Click "My account" and log in. If you have never done this before, obtain your password as described on the login page. Once you are logged in click on the link "Sysop Message Monitor". This will list all current messages flowing through your station. If you find you have received or sent messages with prohibited Message content, follow the suggested actions on the app page. You can review all Sysop Guidelines at: http://www.winlink.org/content/join_sysop_team_sysop_guidelines Thanks for your generous participation and contributions to the global Winlink system! Lor W3QA For the Winlink Development Team 73 de w3qa Winlink Team
Demanding a mode be banned or an entire system be shut down or crippled because it has been abused is not the correct answer. Those of us that can take a breath and put on the hat labeled “adult” will simply ask a few questions.
- How widespread is this abuse?
- What was the intent of the offending operator?
- Was it flagrant abuse, accidental, or just a misunderstanding of the rules?
- How was the abuse detected?
- Is this widespread or very limited in nature?
- Was reasonable corrective action taken upon detection of the problem?
The above is not dissing or blaming the WDT folks anymore than we should blame Edwin Armstrong for the embarrassing Festival de Violations mess on a certain 2m FM frequency in Los Angeles.
The Winlink admins became aware of a problem and took actions. The Winlink system now provides a way for gateway sysops to review recent messages flowing over their gateway. While I feel this needs to be taken further, it is a good start. A good start that addressed one of my biggest long standing objections to adding a RMS to our local node stack….Control Op visibility into the content flowing over the gateway.
Banning Pactor 3, Pactor 4 or [insert your most disliked digital message transfer mode here] would do far more harm than good. It is not about the mode, but misuse of the applications running on top of it. Deal with the misuse not the mode.
So Jeff you are saying you had no way to monitor for violations on your gateway?
Not true, it just wasn’t convenient enough for our particular setup. I manage a lot of infrastructure and only have X amount of time to do it all. I’m not retired so tools that make my life easier are welcome and play heavily into my decision making. Those running around with buckets of mud to sling at anything Winlink can spin that however they wish.
I could direct everything into the BPQ32 BBS for manual review. I could also manually capture frames (PortMon, Terminal logs, RX-only modem, etc), sequence the payloads, combine them, then decompress them for review. Those were just not real convenient for a Sysop with numerous other priorities and limited admin time. Plus our gateway is at a remote tower site…not like the radio and modems are downstairs in my hamshack.
The new Sysop Message Manager tool made things convenient enough that I was comfortable with adding the RMS application to the existing node/BBS stack. The ability to log in from anywhere and review gateway activity is very handy for someone that is often on the road more than home.
PS – I’ve yet to see a single message on my gateway that would get within a mile of dancing into the gray area of 97.113. This year’s activity could be summed up as a little AuxComm traffic for our 4th of July Riverfest, several messages from a weekly ARES Winlink & ICS training net, test messages, and lots of messages from where I used the system to test new SCS modem firmware for our Tracker DSP TNCs. All legit uses of our spectrum and well within the spirit of the ARS rules.
But Jeff what about WINMOR, VARA, ARDOP etc etc?
I don’t use those modes on my gateway. I prefer hardware modems for a variety of reasons.
Yes we can discuss that some of the newer ARQ soundcard modes/modems need to be much better documented. One could also argue that before they are legal for use on the ham bands they should be required to provide an interface (KISS, HOSTMODE ?) to allow for monitoring and the collection of monitored frames off the air like hardware modems do.
But Jeff it’s too difficult for me to capture a Winlink session and decompress the message from it.
May I suggest some of you take all this time and energy you spend bitchin’ and moaning about Winlink and invest it into a modem and a book on Perl or VB .NET. Get off your backside, study up, write come code/scripts. If the need here is even only a fraction of what is proclaimed I sense an opportunity for you to learn something new, contribute something to the hobby, and even make some money if you wish. Triple win!
The link and compression protocol used on Winlink connections is well documented and publicly available. The VB source for the LZH compression is freely available here. You will also find a link there to a page containing full details on the B2F protocol. No “secret recipe” used in the making of a B2F compressed message and the Winlink session.
Step out of your comfort zone and learn something useful. That’s what the hobby is about….not having everything handed to you 100% plug-n-play on a silver platter.
PS – 97.1(d) says “trained operators” not “appliance operators.” Appliance ops are a dime a dozen.
Jeff the B2F compression keeps us from even identifying the stations involved.
False. Monitoring the channel you can see considerable identifying information in the clear during session startup, message proposals, and signoff. Here’s a snippet from a terminal monitoring a 10m RP connection into our local gateway from my mobile earlier:
Since this is a packet mode connection the AX25 protocol means every single frame transmitted has identifying information clearly visible. If you monitor that and can’t figure out the callsign of both stations involved then I’m thinking you need to turn in your “ham card” LOL
Yes a Pactor link is going to look different (it’s not AX25), but the session startup and shutdown is still easy copy for anyone with the appropriate modem.
Winlink and its B2F compression has many legitimate and valuable uses on the ham radio spectrum. It can also facilitate abuse of our spectrum on an internet email connected system like Winlink. As such I propose the following compromise solution:
- All Winlink message traffic flowing in or out of an RF gateway operating on ham spectrum shall be captured and archived by the CMS system. A good foundation for this is already in place. Telnet and MARS traffic exempted.
- This archive shall be publicly available on the main Winlink website.
- This archive shall include all non-exempted RF message traffic for at least one year.
- This archive shall be searchable by keywords, callsign, QRG, and/or date/time range.
- Gateway Sysops shall have the option of having the CMS system email them a copy of every message going in/out of their RF gateway for their own long term review/archival approaches.
Yes there a lots of details to be worked out in the above, but you get the basic idea.
Don’t give me the storage space excuse. This is 2018 and storage is dirt cheap. An archive of a years worth of every Winlink RF flowed message would fit on a freaking flash drive.
Don’t give me the privacy issues. Ham radio communications offer no expectation of privacy.
You can thank me later 😉
But Jeff, what about the concerns of increased congestion on the HF bands?
Okay, fair concern. Something tells me that if the suggestion above is put into place we will notice some reduction in the Pactor, ARDOP, WINMOR, VARA, (insert name of the latest new whizbang soundcard mode here) signals on the HF bands. A reduction as SailMail and the SatComm providers gain some new customers 😉
There are two ways of looking at the impact on band congestion. One is with more bandwidth allowing higher speed connections the congestion will be reduced some as many connections will complete faster. The other is that higher performance modes like Pactor 4 will enable users to download bigger files/messages. This will encourage increased usage that will only further add to the congestion on our HF bands.
Pactor 4 has been legal in many (most all?) other countries for years now. Thus I have to ask what should be a couple obvious questions. Has their regulation by bandwidth (vs symbol rate) approaches been a net positive or negative? Is Pactor 4 causing any significant problems in those regions?
Here’s a novel idea, let’s drop the obsolete symbol rate restrictions. Next let’s try allowing up to 2.8 KHz wide data modes in the existing HF automatic subbands for 5 years. Let’s try that for a few years and see how it works out here in the states. Fair enough?
The EmComm/disaster communications angle?
If we have to send another “Force of 22” into a Puerto Rico post-Maria “it’s all down” environment do you or do you not want them taking with them one of the most effective and efficient HF digital messaging modes (Pactor 3/4) available? Do you or do you not want them to be able to use compression on those links? If you answered “no” to either of those then you need to go review rule 97.1 and the Amateurs Code again.
What if we get a bad ruling/opinion of no Pactor 3/4, no compression?
I don’t think the FCC is even going to address compression. I would prefer they did, but this NPRM is about dropping the symbol rate not a series of endless side issues. If B2 is killed off then the impact of that will be far beyond just Winlink. Winlink is just one of several applications that use it.
I just don’t see the FCC having a major issue with Pactor 3/4 as long as they feel its technical characteristics are sufficiently documented. Given past waivers and what started this, I doubt they will have a problem with it under current 97.309(a). There’s also the possibility they could say it comes up short and issue another waiver while they rewrite 97.309(a) to allow it and similar modes.
I suspect in a few months we will be laughing at all this drama and wondering why this had to be such a big deal.
To wrap this rant up….
Do you still feel these proposed rule changes will have any impact upon criminals operating at terrorist and drug cartel levels? If so please allow me to propose three new Part 97 rules to ensure the security of our great nation at great risk in a dangerous world.
New Rule 97.901 would prohibit the possession, use by, and sales of amateur radio gear by/to anyone in/or associated with any terrorist, terrorist group or drug cartel.
New Rule 97.902 would create a new Universal License & Criminal Background Check system (ULCBC) at all ham radio gear Points of Sale.
New Rule 97.903 would stipulate that only spark gap transmissions will be authorized on amateur radio service after midnight UTC December 31, 2018. #MakeMarconiProud
Problem solved. Feel better now? Feel safer? Yes you can thank me later.
Yes the above section is a joke.