Does Pactor Modes 2,3 & 4 Violate Current FCC Rules? FCC NPRM 16-239

Dear Colleagues:
There is a very important communication we should take a moment to read.
Whatever your viewpoints are on the issue, please spread the word, far and wide through all of hamdom.
This requires immediate attention and public comment to the FCC and ARRL.
Scot Stone, in the FCC, has been involved with this filing from the summer- it appeared just days ago at the FCC.
It’s from the maker of Pactor. SCS.
https://ecfsapi.fcc.gov/file/110731917879/16-239.pdf
It’s urgent that hams around the world read this and comment, calmly, succinctly and factually.
I claim that the thousands of hams who have credibly and earnestly commented on 16-239, RM-11708, RM-11759, and RM-11306 are NOT pactor haters, but are simply devout, dedicated hams who love the amateur radio hobby, who care about public safety, who care about the self-policing open nature of the hobby, and who want to honor the FCC rules that mandate that amateur radio communications be open and interceptable, that they not bypass commercial services, that they not create interference, that they not conduct business over ham radio, and that they be such that it is easy to identify the callsign of the transmitter.

All of this is called out in FCC Part 97.1, 97.3, 97.309, 97.113, 97.119, 97.123, where the appearance of the word ” Pactor ” in Part 97 rules was referring Pactor 1, the original open source, documented Pactor mode with standard forward error correction coding.

Pactor 2,3, and 4 use a trade secret, non-public compression method that serves as effective encryption. The posting above alludes to this fact.

Please, read the comment, and consider if you want ham radio to become a closed HF internet service of unlimited bandwidth transmissions , and please consider the thousands who have commented in the past (who are consistently ignored by ARRL and by some at the 3rd floor of the FCC) and its impact to date, and on the future use of HF bands in amateur radio.
I claim that Pactor 2,3,4 is NOT decipherable, it’s not open source and it is not open speech, and was in fact designed to be secure — this is why the compression scheme is a trade secret- as admitted in the posted letter. I have asked the FCC- they admit they cannot intercept Pactor transmission. Nor can the FBI.
I have found there are a few $20,000 signal intelligence products that can do partial interception- not full decoding.
Thanks for spreading the word, and getting involved by reading the post above, and becoming active in replying, in public, at the FCC 16-239, to provide facts, and to challenge the positions. Ask the FCC to prove for themselves if they, or any 3rd party, can randomly intercept a pactor ARQ transmission. They cannot.
As you read the post above, ask yourself: Why allow Pactor, and not commercial STANAG modems used for HF secure wideband transmissions? NPRM 16-239 makes no differentiation.

Most every country in Asia forbids Pactor, in part due to national security concerns.

I ask you publicly to consider voicing your concern about NPRM 16-239, and urge the FCC to not enact it, and to further require that **all transmissions** be open and interceptable by any 3rd party over the air on all amateur bands. TU for the bandwidth and consideration.
73,
Ted N9NB
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