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Communications Encryption

FCC Considering Proposal For Encrypted Ham Radio 371

Bruce Perens writes "FCC is currently processing a request for rule-making, RM-11699 (PDF), that would allow the use of Amateur frequencies in the U.S. for private, digitally-encrypted messages. Encryption is a potential disaster for ham radio because it defeats its self-policing nature. If hams can't decode messages, they can't identify if the communication even belongs on ham radio. A potentially worse problem is that encryption destroys the harmless nature of Amateur radio.There's no reason for governments to believe that encrypted communications are harmless. See hams.com/encryption/ for more information."
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FCC Considering Proposal For Encrypted Ham Radio

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  • So... is it not possible to send/receive encrypted content when using packet radio?

    • Re: (Score:3, Informative)

      by Anonymous Coward

      Possible vs legal describe two completely different circles on the diagram. In a few places, they even touch.

    • Re:packet radio? (Score:5, Insightful)

      by Michael Casavant ( 2876793 ) on Wednesday June 26, 2013 @08:30AM (#44111441)
      No, it is illegal to send encrypted content via packet. That makes any kind of web browsing pretty much impossible (Google, for example, does https for everything now...and I wouldn't want my plain-text passwords going all over the place).
      • by h4rr4r ( 612664 )

        What is the logic for making that illegal?

        Would it be equally illegal to use codewords to hold a private conversation?

        • by n1ywb ( 555767 )
          Absolutely illegal.
          • by h4rr4r ( 612664 )

            Why?

            To me this sounds like something from the 30s. Do you have to have a silly mustache? Perhaps a big old chair to broadcast from?

            • You're right! I'm a ham and I'm in my 30s!! No mustache though, sorry.
            • Re:packet radio? (Score:5, Insightful)

              by ColdWetDog ( 752185 ) on Wednesday June 26, 2013 @10:42AM (#44113311) Homepage

              Because, one of the longstanding implicit quid pro quo behaviors of Amateur radio is that it is 'harmless'. Amateur radio operators are given the freedom to use a significant swath of radio frequency for non commercial use. Amateur radio is designed to be self policing. If somebody starts sending commercial / illegal / inappropriate transmissions, other radio ops are supposed to help figure out where the transmission is coming from and cooperate with the FCC in finding the miscreant.

              So, if you obfuscate the transmission, all of that goes out the window. Then the feeling is that the FCC will decide that amateur radio isn't worth the bother (and we can be a real PITA [arrl.org]) and shut the whole thing down.

              It's a slippery slope that no one wants to peer down.

              Not EVERYTHING on the planet needs to be attached to the Internet....

            • HAM radio is about experimentation. The communication part is almost a side effect. Radio-amateur frequencies were never intended to substitute commercial telecom networks. So if you transmit something on the HAM frequencies, it's expected that everybody can decode the message. It's part of the experimental nature of HAM radio. You can not even use it for relaying messages for a third party, that's what phones are for.

              That's the intent. Then again, there has been some erosion already, e.g. with the D-Star p

        • From the summary:

          If hams can't decode messages, they can't identify if the communication even belongs on ham radio. A potentially worse problem is that encryption destroys the harmless nature of Amateur radio.There's no reason for governments to believe that encrypted communications are harmless

          • by fche ( 36607 )

            Perens is not making a legal claim, so your answer is nonresponsive.

            • It's a little lengthy to post directly, but here's the info you're looking for (I think): http://apps.fcc.gov/ecfs/document/view?id=7022424684 [fcc.gov]

              Skip down to FCC regulations part 97.113 (4)
              enjoy
            • Re:packet radio? (Score:5, Informative)

              by MozeeToby ( 1163751 ) on Wednesday June 26, 2013 @09:06AM (#44111895)

              Ok, let me elaborate. The HAM network is almost completely self policed. It would be trivially easy to abuse the spectrum and ruin it for everyone so it's in everyone's best interest that people who don't follow the rules, who are using it for commercial gain for just one example, are reported and stopped. Allowing encrypted traffic would allow me to sell internet service to people in rural areas because there's no way to detect what is in the encrypted content. If something becomes profitable enough eventually you'll choke the spectrum and make it unusable for everyone. Keep in mind that this isn't a managed slice of spectrum, there's no one in charge of who is using what frequency where. Get enough sources broadcasting and it simply won't work.

              • by h4rr4r ( 612664 )

                Sounds like they are regulating it incorrectly for 2013 then. Why worry about what, when you can easily control how often. Limit each participant to some amount.

                This whole thing has too much legacy cruft it seems like from the outside looking in.

                • by egamma ( 572162 )

                  Sounds like they are regulating it incorrectly for 2013 then. Why worry about what, when you can easily control how often. Limit each participant to some amount.

                  This whole thing has too much legacy cruft it seems like from the outside looking in.

                  So if there are, say, 525600 licensed ham operators, each one gets to broadcast for exactly one minute every year?

              • Re:packet radio? (Score:5, Insightful)

                by chihowa ( 366380 ) on Wednesday June 26, 2013 @09:19AM (#44112049)

                Well they already allow proprietary protocols like DSTAR (you can decode the packets and see what's there, but you have to pay a company for the privilege to do so - not quite in the spirit of ham radio).

                Why not allow encrypted packets with a cleartext callsign wrapper? Then you can verify the source of the packets and have access to modern uses of the spectrum. Frankly, I think digital modes are more interesting that ragchewing with the oldtimers anyway, and some of the old FCC rules and bandplans are causing amateur radio to seriously stagnate.

                • by h4rr4r ( 612664 )

                  What is the difference between this DSTAR and encryption then? If I don't pay then it sure sounds like it is obscured to me.

                • by hawguy ( 1600213 )

                  Well they already allow proprietary protocols like DSTAR (you can decode the packets and see what's there, but you have to pay a company for the privilege to do so - not quite in the spirit of ham radio).

                  Why not allow encrypted packets with a cleartext callsign wrapper? Then you can verify the source of the packets and have access to modern uses of the spectrum. Frankly, I think digital modes are more interesting that ragchewing with the oldtimers anyway, and some of the old FCC rules and bandplans are causing amateur radio to seriously stagnate.

                  Because the callsign wrapper doesn't help you find abuse - why would a business pay for an expensive business radio system if they can just issue "cheap" ham radios to their employees and encrypt their data so no one knows they are using it for business?

                  DSTAR has the same problem (though mitigated because any ham can buy a DSTAR receiver), proprietary codecs shouldn't run on ham bands.

              • Re:packet radio? (Score:5, Interesting)

                by Anonymous Coward on Wednesday June 26, 2013 @09:42AM (#44112345)

                First, it's "ham", not "HAM" - "HAM" is *NOT* an acronym, but merely a slang expression, short for 'amateur'.

                Second, what's being proposed is to encrypt third-party messages in order to preserve security and privacy.
                An example might be information that's otherwise subject to HIPAA. Another might be a requests/responses
                between governmental (Federal/state/tribal/municipal) emergency management agencies, such as logistics issues,
                that might be sensitive information, but not necessarily "classified" in the traditional military sense.

                Third, this is strictly a *proposal* at this time - this is a Rule Making notice (hence, the RM number) and the FCC
                has now opened the gate for comments. Therefore, if, after reading the RM thoroughly and studying the needs of
                clients (such as the Red Cross, Salvation Army, and various government agencies that Amateur Radio operators
                in the US serve during times of disaster, etc.), you disagree with the proposal, you're more than welcome to submit
                your own comments.

                Fourth, bear in mind that, at least in the US (and that's what's being discussed here), the originating and receiving stations
                *MUST* keep a copy of all third-party traffic anyway.

                Fifth, all of this traffic, be it encrypted or in the clear, would be sent from one amateur station to another and those stations
                must (continue to) follow the identification rules. So, if you happen to overhear W1XXX sending an encrypted message to
                W2XYZ, don't get your knickers in a twist - it'll be their responsibility to follow the rules. OTOH, if you overheard an encrypted
                message (or even an unencrypted stream of bits/noise) and there was no accompanying identification, then you're free to
                call 1-888-CALL-FCC and notify them, as you might for any other "intruder".

                It wouldn't matter if it's sent by packet (which, BTW, is usually identified under the AX.25 protocol with the callsign embedded
                in the packets) on VHF, or via WINLINK using PACTOR or WinMOR, or PSK31 or RTTY or any of the other digital modes.
                Or, gasp, even CW...

                Now is the time for amateurs to put their thinking caps on, study the current rules, study what's being considered in the RM,
                learn what the local and served agencies need and/or can live with, and file well-reasoned comments and suggestions for
                implementation with the FCC. The idea is to enable amateur radio operators to better serve their communities, after all...

                And, be prepared to do a second round of "Reply Comments" to address the various issues raised in the initial comments.

              • The HAM network is almost completely self policed.

                I think this is confusing "mostly well behaved" with self policed. For instance, look at the abject fuckery that goes on at 14.313 MHz each and every day. All manner of rule violations. Not judging the rules here, but no question, deep and serious violations of them. No one "polices" this in any sense of the term; nothing any ham does shuts it down, slows it down, restrains it, or otherwise serves as a "police" function. Reporting it to the FCC does nothing

          • by DrXym ( 126579 )
            Voice encryption and data encryption are going to behave in different ways. A voice conversation is likely to be one person talking for a few seconds and then the other end and vice versa. Data traffic is likely to be continuous and highly bidirectional in nature with a bias towards the recipient. Anyway I'm sure that the encryption used could have a backdoor key or low entropy so governments could peek in if they wanted while keeping casual snoopers out and increasing the bandwidth capacity by using it mor
        • I can't speak to the logic behind it, but yes, that's equally illegal. The FCC regulations say that anything designed to "obscure the meaning" of communication is prohibited on amateur radio.

          It's been generally held, though, that secure authentication is okay - the meaning there is "prove you are who you say you are", "this is my proof", "okay, accepted" (or "sorry, rejected"). As long as it's possible to tell that that's the gist of the communication, obscuring what one would need to know to prove it i

        • What is the logic for making that illegal?

          Don't apply for a job in government...

      • Illegal? Or outside the spec? Do cops kick down your door, or do other ham guys give you a severe frowning?

        • In principle, the FCC can take action against your license. In practice, they spend about as much time policing the ham bands as the FBI spends on D. B. Cooper.

        • by DarkOx ( 621550 )

          Yes the FCC will absoultly revoke your HAM license, if you make a habit of breaking the rules.

      • by n1ywb ( 555767 )
        I've thought about whether encrypting just the password would be legal, and I think you could argue that it is, because the letter of the law refers to the "meaning" of the "messages", and the password has no meaning (beyond the fact that it's a password and encrypting it doesn't obfuscate that meaning) and it isn't really a "message". The origin of the term "message" in the rules comes from radiograms. The reason for the rule is they want ham radio to be self policing and not used for crimes, espionage, et
      • It is also illegal to use Ham Radio for commercial purposes. That makes almost any kind of web browsing pretty much impossible.

        • by h4rr4r ( 612664 )

          How is that defined?
          If you and I are having a discussion and during it you mention the need for an item that I just happen to have a spare of, can I offer to sell it to you?

          • The traditional paradigm in the ham world is: Asking your spouse to get a pizza on the way home: OK. Calling Pizza Hut (which you could do via phone patch) and ordering one: Illegal.

            • by n1ywb ( 555767 )
              Actually ordering pizza over ham radio phone patch is fine. The law bans comms in which you have a "pecuniary interest". I.e. you cannot earn money from operating a ham radio. Back in the old days, commercial operators didn't want ham radio ops honing in on their racket. Spending money on a ham radio is fine.
              • by n1ywb ( 555767 )
                There's one exception; you can legally arrange a private sale of ham radio equipment over the air.
    • Re:packet radio? (Score:5, Informative)

      by Chris Mattern ( 191822 ) on Wednesday June 26, 2013 @08:33AM (#44111473)

      Possible, yes. Legal, no. The fact that a large section of Internet traffic cannot be sent legally over packet radio is one of the reasons they want to do this.

      • Re:packet radio? (Score:5, Informative)

        by chihowa ( 366380 ) on Wednesday June 26, 2013 @09:34AM (#44112261)

        Read the memo [fcc.gov], though. The main reason they want to allow encryption is for communication with government emergency services. The proposed change would only allow encryption for these reasons:

        (a) signals exchanged between an amateur station and a space station in the amateur satellite service for the purpose of controlling the operation of the space station; and

        (b) signals exchanged between an amateur station and an unattended amateur station for the purpose of controlling the operation of the unattended amateur station; and

        (c) intercommunications when participating in emergency services operations or related training exercises which may involve information covered by HIPAA or other sensitive data such as logistical information concerning medical supplies, personnel movement, other relief supplies or any other data designated by Federal authorities managing relief or training efforts

        This isn't about modernizing amateur radio or allowing exciting new uses, it's about making it compliant with other boring federal regulations.

        • by chihowa ( 366380 )

          To clarify, the satellite and unattended operation stuff is great, but it has already been informally addressed. Ciphers are allowed for authentication, provided that they don't obscure non-authentication content. This proposed rule would expand that to cover control codes for satellites and unattended stations, but in spirit those exceptions were tacitly allowed already.

    • which is to say, the compression algorithms for the various packet formats are open to all. some packet generators are proprietary. some are free or low cost things whipped up on computer by hams.

      there is an argument going on at eHam these days about whether your (open) transmissions are being copied by the spooks.

      duh. they listen to everything.

      encryption is a path to banning amateur radio communications altogether, as various pig-headed dictatorships try to lock down discussion and turn everybody's eyes

  • by Myself ( 57572 ) on Wednesday June 26, 2013 @08:34AM (#44111487) Journal

    Whenever I try to convert part-15 geeks into part-97 geeks, they're interested in high power, they're interested in DIY equipment, they're interested in satellites, they're interested in propagation, and as soon as I mention that you can't swear or encrypt, they walk away.

    "If I can't send useful traffic over it, why would I bother?"

    Ham radio is losing a generation of geeks who've grown up on a more-free network and aren't interested in a restricted one. Should we just let them go?

    • by h4rr4r ( 612664 ) on Wednesday June 26, 2013 @08:41AM (#44111575)

      Or maybe make that network more free. What exactly is the point of this overly restricted network? Seems like a total waste of a resource.

      Are you serious you that you can't swear? What exactly constitutes a swear word in ham radio? Are you required to dress up like it is the 30s?

      • by Opportunist ( 166417 ) on Wednesday June 26, 2013 @09:08AM (#44111911)

        Sir, I must request that you dress according to the occasion. We're not on the internet here, we have standards!

      • by havana9 ( 101033 )
        I think having a moustache is important: https://upload.wikimedia.org/wikipedia/commons/7/79/Tesla_circa_1890.jpeg [wikimedia.org] But sometimes you could be also shaved: http://upload.wikimedia.org/wikipedia/commons/0/0d/Guglielmo_Marconi.jpg [wikimedia.org]
      • by HeckRuler ( 1369601 ) on Wednesday June 26, 2013 @09:27AM (#44112143)

        Because it's a limited resource. There's only so much bandwidth on the air. The equipment is made to work within a specific frequency, (because outside of that band, those frequencies are used for other things). Think of it like a river, it's owned by everyone or no-one, with lots of people wanting to use it. It's a natural monopoly. So it's regulated.

        A lot of really good uses for the airwaves exist and have their sections defined. One of those sections was set aside for the hobbyists to do with as they please. But they still have to play by the rules, because it's still a public place, using a limited resource, with others' rights you have to respect.

        Imagine if your internet connection stopped working whenever someone sent you a packet. You had a single channel for up and down communication, and you didn't have control over when people talked to you. Every time someone sent you an email, your downloads stop. Every time someone pings you, your wabpage stops loading. That's radio. If someone is an asshole, they can barge into your channel and talk over you. If they're malicious they could jam the entire band and DOS everyone.

        And yes, officially you can't swear. Just like you can't pirate movies over the Internet. You also can't sing.

        • by h4rr4r ( 612664 )

          I don't see how the need to regulate leads to these regulations. I can swear in public, I likely often do. I understand the need for some regulation, but it seems like a simple limit on how often one can use the resource would be far more valuable than these arbitrary restrictions.

          How did you know I could not sing?

    • by VAXcat ( 674775 ) on Wednesday June 26, 2013 @08:44AM (#44111609)

      Can't swear? You clearly haven't spent much time listening to 20 meters, or, at least in my part of the country, 80 meters. Sailors could learn a thing or two about swearing by listening in....

    • by n1ywb ( 555767 ) on Wednesday June 26, 2013 @08:53AM (#44111713) Homepage Journal
      I think I was a ham for about a week before I hear my first on-air cussword. I would advise against dropping the f-bomb but I've never heard of anybody getting in trouble for the occassional mild cuss.

      Ham radio is about:
      • Public service
      • Radio technology
      • International goodwill

      If you are interested in those things, you will enjoy ham radio, restrictions and all. If you are not interested in those things, see ya.

      • by h4rr4r ( 612664 )

        Why not just remove those restrictions?

        From what I can tell most of these folks seem to hate Radio technology, if they could communicate by banging on the transmitter with a rock they would. They like outdated stuff and have very little interest in anything new.

        • by LoRdTAW ( 99712 )

          Just listen to CB sometime. Unregulated CB communication is pretty much us-listenable. It has even waned in use for truckers where it was at one time romanticized and heavily used. Most truckers who put in a CB do it for show or as a customary thing. They now rely on smart phones for traffic, weather and communication.

        • by n1ywb ( 555767 )
          From what I can tell, you are a troll.
      • If you are interested in those things, you will enjoy ham radio, restrictions and all. If you are not interested in those things, see ya.

        I am not interested in supporting censorship, which is what you're doing when you pay your fees. See ya.

        • I am not interested in supporting censorship, which is what you're doing when you pay your fees. See ya.

          What "fees"? $15 for a 10 year license? It's not about censorship. It's called acting civilized, having respect towards each other, and having an environment where even kids can participate.

        • by ATestR ( 1060586 )

          Not really. The "fees" for an amateur radio license are trivial... $14 is the going rate to take a license test, and its good for 10 years. The government isn't making money on it. The rules are in place and generally followed by people because everyone who is currently licensed have agreed that is how they want to play.

          Again, as the grandparent post pointed out, if you don't want to play the game that is being played, choose another game. There are other radio based services that are different and may

  • Why, in a supposedly free country, is the possibility of something being "harmful" a justification for its being made illegal?

    • by VAXcat ( 674775 )
      It goes back to the origins of radio. Originally, it was all amateurs messing arouind. Then, as it became more useful and of interest to companies and governments, amateur radio types were quick to restrict themselves as harmless and non-competitive to these interests, in order to keep from being squashed as nuisances. I think it ought to be more like licensing of pilots - those licensed at the lowest skill levels can't charge for flying and can only fly for personal gain under strict rules. As pilots prog
  • We should sue the Japanese for changing their codes just before Pearl Harbor

    • by Z00L00K ( 682162 )

      And even when sending Morse code - is it in a minority language you are communicating or is it encryption?

      • I'd say as long as there is a publicly accessible "decoder" available AND it can be determined from the message what decoder is to be used (or the information is available at request), it's not encrypted.

    • by JustOK ( 667959 )

      The americans would be counter-sued for breaking their DRM

  • Seems like it would be a lot more effective to just add an emergency comms exception to HIPAA.

    The great thing about ham radio is that we have stacks of old, analog, simple, reliable equipment and we can get a signal through no matter what.

    Encryption on the other hand requries fancy radios and fancy computers and while we could probably swing it most of the time, situations could certainly arise where the smoke comes out of the fancy radio or the computer shits it's bits and we're left with an FM 2m ri
    • by h4rr4r ( 612664 )

      Encryption can be done with pen and paper if need be. Ever hear of one time pads?

      If we are too the point that this is infeasible your little radio network is not going to be useful for anything.

  • SSB radio already allows this: encrypted telex over short-wave is an originally military means of communication, which - for a few thousand dollars - is also with an amateur's and civilian's reach. With a 1 kW-antenna, your range is more than half the globe, under good conditions ( which last for about 6 hrs / day ).
  • "There's no reason for governments to believe that encrypted communications are harmless."

    There's no reason for private citizens to believe unencrypted communications government can spy on are harmless. Evidence: All of human history, and the reasons behind free speech and right against search and seizure.

  • Does anyone seriously not believe the famous numbers stations [wikipedia.org] as already an ultra-low-throughput form of encrypted transmission?

    Whether you send the data as electrical bits, RF, carrier pigeons, or a recording of Angelina Jolie saying "zero" and "one" over and over and over really has no relevance to the underlying meaning. Either it already breaks the law, or it doesn't.
    • Does anyone seriously not believe the famous numbers stations [wikipedia.org] as already an ultra-low-throughput form of encrypted transmission? Whether you send the data as electrical bits, RF, carrier pigeons, or a recording of Angelina Jolie saying "zero" and "one" over and over and over really has no relevance to the underlying meaning. Either it already breaks the law, or it doesn't.

      Totally true. But I've never heard a numbers station in a ham band. Hams can't just operate everywhere in the shortwave spectrum. There are certain frequency "bands" they can use. The numbers stations aren't within these bands.

  • Then we can move all our phone calls and texts over to Ham Radio and avoid PRISM...LOL
  • If you can't tell who or what is transmitted, you can't tell if it's 2 HAMs talking to each other or an agent reporting in to big bro.

    On the flip side, they could also not update the laws and just start arresting HAM operators by accusing them of encrypting.
    *Try to prove that you were not*

  • by EmagGeek ( 574360 ) on Wednesday June 26, 2013 @09:12AM (#44111965) Journal

    This is not a Notice of Proposed Rule Making (NPRM). This is simply a petition by a Citizen.

    If the FCC decides to consider the petition, it will issue a NPRM and open a comment period. It will THEN consider the petition with the collection of public comments.

  • by account_deleted ( 4530225 ) on Wednesday June 26, 2013 @09:25AM (#44112113)
    Comment removed based on user account deletion
  • People already can (and probably do) use ham radio for encrypted transmissions through steganography and you wouldn't even know it. Allowing this explicitly wouldn't let "the bad guys" do anything they can't already do, but it would help regular, law abiding citizens to use it more effectively and safely. It might also create a communications channel that you can be pretty certain is free from state-sponsored espionage and corporate control.

  • You need to buy decryption keys (patented and closed source) from ICom.
    FCC has clear rules that state encoding scheme should be OPEN and published in order to be called encoding and not encryption. D-star is neither open nor published.

    France already made D-Star illegal on those grounds and I am very glad. D-Star is the biggest SCAM ICom has pulled on HAMs, they sneaked in their proprietary closed tech as a "solution" to a problem that didnt exist and in effect almost monopolized digital market.

    You can compa

  • A Really Bad Idea (Score:4, Interesting)

    by jasnw ( 1913892 ) on Wednesday June 26, 2013 @09:41AM (#44112337)

    I've seen HAM radio at it's best, and how it can be taken out by any idiot with enough broadcast power. I was in Puerto Rico when a bad hurricane hit the island and wiped out all communications over most of the island. A good friend was a HAM operator, and he linked up with a semi-formal network of HAM operators along the east coast that activates whenever there's a hurricane disaster. These people provided the only communications for large numbers of people for several days, and were instrumental in saving lives. At one point, however, one pin-headed yokel got on the frequency the net was using and rebroadcast AM radio music with a lot of watts behind it. They finally got this guy off the air (with some FCC help), but he hindered the net for almost a day.

    The HAM community does a lot for many others who are not HAMs, and to open their bands up to individuals who only see dollar signs everywhere and only think of their own "rights" to do whatever they damn well please would be both a travesty and a serious mistake.

  • As an Extra Class license holder, I sincerely hope this doesn't get approved. Yes, it's restricted to only emergency communications, but allowing encrypted transmissions at /all/ means that any of them could be from non-licensed individuals, and brings into question legitimate uses of the airwaves. Leave our airwaves open!
  • NO. Never, do not allow it.

    Their argument that "it is needed" for emergency situations is bovine fecies.. this is the WORST time to obscure your communications.

    The ham bands are not for private communication. I hope the FCC does not let these fools ruin ham radio.

  • by Wapiti-eater ( 759089 ) on Wednesday June 26, 2013 @10:18AM (#44112865)
    Are we an Emergency Service? No - we are not. That is what part 90 is for.

    We are hobbyist, enthusiasts that practice the radio art and sciences. As such, we develop the skills and methods to make things work, when all else fails.

    We fill in, when asked, when established systems fail. We are not a "First Responder" that jumps into any and every situation with our "magic" HTs to save the day.

    If you want to be part of an EmComm organization, join one - they have their own radio service under part 90 rules. They use encryption there - and it works well.

    Thankfully, the public communications community has noticed when things have gone bad and we've stepped in to help. They've evolved their systems to be more robust and survive events. No, they're not perfect and there will be opportunity to help out in the future. But, we provide that help out of civic duty. Not as an EmComm service.

    Allowing encryption on the Amateur Bands will further dilute the separation between our hobbyest, experimental service and established EmComm services. When those EmComm service start asking for more bandwidth to support their growth - where do you think they're going to look? If we're already providing EmComm services - predeployed, dedicated, secure encrypted, agency specific communications - what shouldn't they have our bands?

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