ARRL announced today that they have filed comments with the FCC requesting a dismissal of the Petition for Declaratory Ruling filed by New York University (NYU) regarding digital encoding and encryption. This petition basically claims that proprietary and closed protocols like PACTOR violate current FCC rules, an opinion I’ve had for several years. I think the AMBI vocoder used in D-STAR and other digital voice modes falls into the same category as well as it’s not openly documented, like the rules require. Due to the lack of documentation and openness, such encoding is de facto encryption, which is prohibited.
ARRL’s filing has me smacking my head. Rather than openly addressing the issue of protocols in amateur radio that are closed and proprietary, they attack the language proposed by the Petition. Furthermore, they pull CW into this, stating,
“The proposed prohibition arguably could include, presumably unintentionally, CW (Morse Code), which is a longstanding means of encoding transmissions. The very fact that messages sent in CW are “encoded” by any definition of the term starkly demonstrates the problem with this proposal.“
I’m not sure if ARRL is intentionally being obtuse or just doesn’t understand the crux of the issue with “un-openly” documented digital protocols. CW, while technically encoding, is 100% openly documented, and has been for a century or more. It doesn’t require proprietary hardware, software, or algorithms to decode. PACTOR until most recently could only be decrypted with proprietary hardware. AMBI and others continual to be closed protocols. That’s the problem, not semantics over the proposed language in the petition snagging CW as encoding, and encryption.
A few weeks ago I started writing comments to file with the FCC, but I quite honestly lost interest. I don’t have a horse in this race, other than wanting to see amateur radio continue on well into the future. I’m just disappointed ARRL doesn’t get what the real problem is, doesn’t make an effort to correct it, and fails to even acknowledge that closed digital protocols are antithetical to the openness and historical foundation of amateur radio.
This article originally appeared on Radio Artisan.