Discussion in 'Ofcom Licence Review - Consultation' started by RSGB Forums, Sep 11, 2014.
Do you agree that the proposed changes will clarify RAYNET operation under the Licence?
Dead simple this. Just make it clear that all Amateurs may transmit messages when requested by approved user services, or sub agencies working for those user services. Transmissions must be within bands and power levels associated with the licence level of the Amateur. It's as simple as that. If we have a national or local emergency Amateurs should not feel in anyway constrained by their licence, other than bands and power.
2.96 - encrypted messages. Where is this coming from? Was this requested by RAYNET?
FCC looked at this very question for US ops recently. The justification was supposed to be that health insurance providers would be unhappy about unencrypted patient information circulating. FCC decided this was unwarranted. We're not really subject to that same pressure here anyway, so why would this be needed?
I am of the opinion that amateur transmissions should always be in the clear. It's a long-standing principle, erosion of which would be dangerous. I can perhaps see a case in respect of remote control (but even that doesn't require encryption as such - perhaps signing with public/private key pairs), but that doesn't seem to be what is being proposed.
Ok just a bit of guidance as it affects quite a few other topics:
Several of the Ofcom proposals interact with others.
So for this example, will need to carefully distinguish between user service message content (on fairly rare occasions perhaps), and the separate/ongoing need that identification of the station always remains clear (Q6), and even a potential interaction with the 5MHz military/cadet comms clause in Q1 (which effectively involves a user service)
PS Am an ARRL e-member, so had seen how the topic went over there
The situation of a user service handing a Raynet group a previously encrypted message for transmission has been known and accepted for a long time. We checked it out with Ofcom some years ago. To me this clarifies it. The transmission callsign is identified, but the amateur has not encrypted the transmission.
This is not for all amateurs as suggested, because doing so and getting errors as a result may well invoke their PL cover being called upon, and a normal amateur does not hold PL cover to £10m. It should be specific for Raynet groups only.
The above is a personal view.
Group Sec Glos Raynet
Vice Chairman, RSGB Emergency Communications Committee
As it stands that is not what 2.96 says:
2.97.2 is then ambiguous. The distinction is not being made between the licensee doing the encryption and passing a message that was already encrypted by the user service. If Ofcom's intent was a derogation of licence clause 11(2) specifically for this purpose they should frame it more tightly.
Speaking personally, just as an average amateur, not involved with Raynet (at least not for a very long time!), I am still uncomfortable with this. Presuming the need for this has been discussed previously can somebody provide a link to relevant threads?
This change makes a radio amateur responsible for securely encrypting a message for the User Service and the radio amateur might then be liable if the level of encryption is subsequently found inadequate and the information decrypted and released. It must be the responsibility of the User Service to encrypt their data. Radio amateurs should simply transfer the resultant binary files provided by the user.
There are enough open source tools to encrypt messages to such a high level, that nobody would bother trying to crack them, unless GCHQ etc were interested in the content, and even then it would take loads of time. Can talking in a relatively rare language be considered 'encryption?
The amateur is respnsible for the content of messages sent and I would not pass an encrypted message, the content of which I could not check.
Jim, If Ofcom are happy and thereby indemnify me, I have no issue at all.
Indemnify also means to secure against loss. I assume that that is what "Ofcom said some years ago they were happy for 3rd party messages to be passed encrypted if they were presented to the operator in an encrypted form" means. AIUI, Ofcom has released the sender from any responsibility for any message so transmitted. It would be a different matter if I were to encrypt a message and send it or transmit any file with hidden info (stenography).
Back in the 70's a friend of mine was visited and accused of coded transmissions for speaking Russian. And the American Army used Navajo in WW2.
Even if there is genuine need to encrypt some messages, then there must be an explicit statement that requires station identification in the clear (un-encrypted). Without the specific requirement to identify in the clear, the use of the amateur bands by un-licensed operators would be undetectable and potentially be a cover for all sorts of illegal activities by criminals, terrorists etc. The suspicion of such activity could result in additional queries from licenced amateurs to Ofcom and additional investigations by Ofcom.
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