The FCC’s Wireless Telecommunications Bureau is soliciting comments on a Petition for Declaratory Ruling filed on behalf of New York University (NYU) seeking to clarify that Section 97.113(a)(4) of the Amateur Service rules prohibits the transmission of “effectively encrypted or encoded messages, including messages that cannot be readily decoded over-the-air for true meaning.” Comments are due by December 2, with reply comments (comments on comments already filed) due on December 17. The FCC has requested that all filings refer to WT Docket No. 16-239, which grew out of an ARRL Petition for Rule Making seeking elimination of symbol rate limitations on the amateur bands and is unrelated to the wider encryption issue.
A footnote in the Petition says the efficacy and availability of recently announced software to decode Winlink communications when sent using different PACTOR modes is “unclear” as it applies to existing PACTOR-capable modems. “If any bits or letters are missed or corrupted during the reception — as would be expected under HF propagation — the message cannot be realistically decoded,” the footnote asserts. SCS, the company that created PACTOR, recently unveiled its PMON software that it says offers the ability to monitor the content of PACTOR 1, 2, and 3 transmissions over the air.