Prof. Theodore (Ted) S. Rappaport, Ph.D, PE David Lee/Ernst Weber Professor of Electrical & Computer Engineering NYU WIRELESS Tandon School of Engineering New York University 9th Floor, 2 Metrotech Center Brooklyn, NY 11201 www.NYUWIRELESS.org Ph: 646 997 3403
[email protected] Federal Communications Commission April 27, 2019 445 F St. NW Washington, DC 20022 Subject: Reply Comments in RM-11831 Dear FCC and ARRL Officials: In my role as a wireless communications engineer and expert, a former Federal Communications Commission Technological Advisory Council member, a friend to the amateur radio community, a licensed amateur radio operator (N9NB), a Professional Engineer in Virginia and Texas, and a life member of the American Radio Relay League (ARRL), I file this reply regarding RM-11831 to reinforce why the FCC must urgently adopt this proposal in principle, in order to ensure data transparency in amateur radio and to eliminate the use of private email and secret file transfers that are currently being transmitted in the amateur radio spectrum. I. Introduction RM-11831 cures ongoing deficiencies that the ARRL and FCC have ignored since the late 1990s. Adoption of RM-11831 would remove existing rule ambiguities to ensure that all data transmissions in amateur radio have a readily available decoder for public use and eavesdropping, so that the public and other amateur operators can “read the mail” and learn about the hobby while intercepting any data signal for meaning over the air. As shown here in my reply to comments, RM-11831 would vastly improve the effectiveness of ACDS transmissions in emergency situations by making all data “open” for others to hear and react to, as required in 13-1918.