1) It transmits without checking if the frequency is already in use, and is thus a source of interference to other users
2) It uses a proprietary protocol that requires purchasing expensive hardware froma single company (https://www.p4dragon.com/download/SCS_Pricelist_2019_REV-A.p...) to decode
The solutions proposed are
1) Limit "Automatically Controlled Data Stations" like Winlink to a specific range of frequencies 2) Limit the protocols they use to ones that "can be be monitored, in it’s entirety, by 3rd parties, with freely available open source software"
You can read the petition at https://ecfsapi.fcc.gov/file/100918881206/PETITION%20FOR%20R... for more details.
1) It uses proprietary PACTOR III and IV modems that only one company makes. This means to monitor Winlink you need to shell out thousands of dollars for a modem.
2) PACTOR transmissions don't send any ident in the clear, the ident is part of the PACTOR code.
3) There at least used to be an issue with PACTOR III modems both not detecting transmissions on the same frequency and falsely detecting transmissions on the same frequency, so Winlink stations were told to turn frequency-in-use detection off.
4) Theres a decent number of people who use Winlink as a substitute for Sailmail and thusly are in violation of 97.113(a)5.
From a brief Googling leading to Winlink's web site, it sounds like Winlink isn't even encrypted at all [1]:
> Q260 While monitoring transmissions from WL2K stations, I notice that the content appears as “gibberish”. Isn’t this illegal?
> A260 The content looks that way because it is a compressed binary format called "B2F." This format is available to anyone, so the compressed data is not considered encryption or illegal for radio amateurs.
Is the concern that people are encrypting Winlink payloads anyway? And wouldn't this already be illegal under current rules?
[1] https://www.winlink.org/sites/default/files/wl2k_faq_2015031...
(Edit: formatting)