FCC filing claims digital modes raise national security concerns

Ted Rappaport N9NB submitted a filing to FCC, Nov 10, saying FCC’s NPRM 16-239, on amateur radio digital modes symbol rate, is viewed as "a direct threat to the national security"



A Radio Resource Media Group story by Sandra Wendelken says:



A wireless expert says the FCC is putting national security at risk by not enforcing amateur radio rules.



The FCC’s notice of proposed rulemaking (NPRM) 16-239 attempts to remove a limit on the baud rate of high-frequency (HF) shortwave transmissions. In an ex parte filing, Theodore Rappaport, Ph.D, told the FCC’s chief technology officer (CTO) Eric Burger the FCC should first address ongoing rule violations to proper usage of the amateur radio service — specifically, the use of obscured, private messaging, which is forbidden in Part 97 rules and creates national security concerns, as well as other violations.



“If allowed, NPRM 16-239 would perpetuate the current violations and would authorize obscured transmissions of unlimited bandwidth over the global airwaves, further increasing the danger to our national security, since these transmissions cannot be intercepted or eavesdropped by other amateur radio operators or the FCC,” Rappaport’s filing said.



Rappaport is the founding director of NYU WIRELESS, a professor at New York University (NYU) in three different schools and a leading expert in 5G technology.



The filing said public records clearly show how the evolution of undocumented, proprietary transmission technologies such as PACTOR and Winlink, ARDOP, Winmor, STANAG and other HF transmission schemes that use controlling software have created a national security problem in the amateur radio service. Third parties, including other ham radio operators or the FCC listening stations, cannot intercept and decode over-the-air transmissions when used in the popular automated repeat request (ARQ) mode.



“In my personal conversations with FBI and FCC officials, they admit they also are unable to readily decode these types of transmissions,” Rappaport said. “In my discussions with vendors of amateur radio equipment, they tell me that they are concerned about purchases of amateur radio equipment by criminal cartels, and that they believe it is happening daily.”



Rappaport urged the FCC to recognize the danger of NPRM 16-239 and address Part 97 rules to remove this type of obscured communication and other ongoing violations, before it enacts NPRM 16-239.



Read the full Radio Resource Media Group story at

https://www.rrmediagroup.com/News/NewsDetails/NewsID/17667



Read FCC filing by Ted Rappaport N9NB at

https://ecfsapi.fcc.gov/

file/1111110314487/FCC%20EX

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Download Notice of Proposed Rule Making NPRM 16-239 from

https://www.fcc.gov/document/amateur-baud-rate-nprm



On September 27, 2018, the Radio Club of America awarded the Armstrong Medal to Wireless Communications Researcher and Educator Theodore Rappaport N9NB

https://engineering.nyu.edu/news/radio-club-america-awards-armstrong-medal-wireless-communications-researcher-and-educator