November 10th [Theodore Rappaport] the FCC sent one Ex parte filing in relation to a proposed rule change that would remove the baud rate limitation of digital radio frequency (RF) transmissions. According to [Rappaport] There are already encrypted messages that cannot be read on the amateur radio waves and that would make the problem worse.

[Rappaport] is a professor at NYU and founding director of NYU Wireless. His concern seems to be primarily related to SCS, which have some proprietary systems for compressing PACTOR as part of Winlink – in some cases for sending email from shipboard ships.

The FCC proposal Related to a request from the American Radio Relay League (ARRL) to lift the baud rate restrictions imposed in 1980, presumably to limit signals that use too much spectrum on the bands. However, PACTOR 4 – specifically mentioned in the proposal – has a low bandwidth, but can send 5,800 bits per second and is therefore not permitted in amateur bands. The ARRL argues that this actually prevents efficient use of the tapes. Note that while PACTOR-II, -III and -IV are known, PACTOR are proprietary and generally cannot be decoded without using an approved modem.

It does not seem to be particularly important to us that increasing or removing bandwidth limits would necessarily lead to national security problems in and of themselves. First, the air waves are not entirely American. While the FCC can control radio operators in the US, that’s not the whole problem. Second, enforcement is lax, but doesn’t have to be, and anyone who really wants to compromise national security is likely to flaunt the law anyway. And finally, anyone who really wants to send secret messages can probably do it another way and / or use steganography to hide their encoding.

So we’re not sure what the submission is really about. Sure, sending encrypted messages on the ham bands is against the rules that should be better enforced. If PACTOR-IV is to be used on ham, it should be open. However, increasing the baud rate limit prevents or does not allow this. Is it really a national security risk? If so, it seems only slightly to us. What do you think? Let us know in the comments.