THE SINKING OF THE BOUNTY REPLICA
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This Bounty replica ship was made famous by appearing in various movies you may have seen. It was in marginal condition and short of crew, and set to sea in conditions that would have been a challenge to a vessel in good repair with an adequate crew. It was not up to the task of superstorm Sandy. Radio and communications were important in the rescue of the survivors when it sank. The captain, Robin Walbridge KD4OHZ, had only a hand held sat phone which was not powerful enough to operate below deck in the storm. There was no external antenna to connect the sat phone to, so that it could be used below decks where it was quieter. There was an emergency locator beacon (EPIRB) that was used to contact the USCG which was not activated until the weather had deteriorated to the point Coast Guard rescue was not feasible. Much earlier, a crew member repeatedly asked to contact the Coast Guard directly, but was repeatedly overruled by the ship's captain. Walbridge made contact later with the Bounty business organization, NOT the Coast Guard directly, by amateur radio email. The Bounty organization management then contacted the Coast Guard. The bottom line is that the ship set sail in bad weather conditions with an underpowered Sat Phone and amateur radio for HF Winlink email for business "communications, on a regular basis," with the bounty organization's land offices. No radio was on board that was capable of contacting the coast guard directly on their HF calling frequencies. They could not contact anyone on the 20 meter amateur radio maritime net, perhaps due to the static crashes of the storm and late time of day. The microphone of the ham radio may not have been tested before sailing or may not have even been ever used, since Winlink was the only purpose of the radio. If Walbridge had attempted timely contact with the Coast Guard earlier, and had made an unequivocal declaration of vessel in distress, the loss of life might have been prevented. If he had diverted to port earlier as warned in a general advisory by the Coast Guard, the ship might have been saved. It is also possible that captain Walbridge KD4OHZ, consciously and repeatedly avoided contacting the Coast Guard directly. Embarrassing questions might have been asked about the condition of the vessel, the injuries to crew members (who should have been evacuated earlier for medical treatment), why they did not declare May Day or Pan Pan earlier when a rescue was likelier, or the decision to be at sea in a major hurricane. Furthermore, a VHF hand held radio, not Winlink, was employed by the Bounty to talk to various USCG rescue aircraft overhead. Another event should have been immediately reported earlier to the Coast Guard, so that the injured crew member could have been evacuated for treatment, while rescue still was possible. From the Coast Guard official report: "2012-10-28 18:30:00 Prokosch Seriously Injured: Prokosch falls onto aft cabin bulkhead as he retrieved other colander from galley. "Fell 10-15 across tweens and hit his head on the arms chest." (Black) Black informs Svendsen. Breaks vertebrae, 3 ribs, and shoulder. Asked John Svendsen to assess his injuries - "Make sure I'm not paralyzed."" The captain again fails to prioritize crew safety and well being. The Coast Guard was contacted only much later after this serious reportable injury, and when he finally was ready to admit that the ship was sinking. So claiming that a Winlink email system was the main means of establishing communication with the Coast Guard was a bit of an overstatement, and also a reflection of the Walbridge's continuing negligence. This could happen again, if people do not outfit their vessels with adequate commercial equipment for safety and communication gear, instead of what ARRL and Winlink are promoting. Read the quotes from the Official USCG reports and other sources below to verify these facts. I would also suggest you compare the testimony under oath in the USCG report to the later statements by Doug Faunt, N6TQS, used by the ARRL, Winlink, The Amateur Radio Safety Foundation (ARSFI), The Seven Seas Cruising Association (SSCA), and SCS, to promote the use of their Pactor modems used for free HF email over amateur radio. This Faunt account is referenced in FCC comments on RM-11708 and WT 16-239, to expand this activity. For more on the FCC proceedings, see /FCCrulemaking.html>
VERY IMPORTANT SAFETY WARNING: If you are a blue water sailor reading this page who is considering buying a ham radio setup for email, and you have been enticed by an item on the webpages of the ARRL, ARSFI, SSCA or Winlink, you need to read this Coast Guard instruction and heed it, for the safety of your vessel and crew: "Currently the US Coast Guard email system is not set up to accept or respond to emergency SAR messages. If you are in distress or need to report an emergency, do NOT send it via email; contact the Coast Guard via telephone or radio." Click this link to see the full Coast Guard instructions: https://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-Response-Policy-CG-5R/Office-of-Incident-Management-Preparedness-CG-5RI/US-Coast-Guard-Office-of-Search-and-Rescue-CG-SAR/Contact-USCG-SAR/ The Coast Guard itself states that email contact is NOT to be used in the event of emergency, since email is not monitored 24/7/365. I have tried to provide links which give a variety of viewpoints for balance, as well as official Coast Guard reports, not advertising that has a "spin" to support an agenda. Before you obtain a Winlink HF email system, you should have an EPIRB (don't forget to register it, so the USCG knows its YOUR vessel in distress), a GOOD portable Sat phone you can take in your ditch bag (don't forget to load into speed dial memories all the USCG phone numbers from their website), and a hand held VHF marine radio (to talk to the USCG or nearby vessels from your life raft). IF you want to talk to the USCG on HF voice as instructed, you will need a rugged powerful radio like the Icom M802 that transmits on USCG hailing frequencies as well as to other ocean going vessels. See http://www.icomamerica.com/en/products/marine/ssb/M802/default.aspx. Safety is not a hobby; get it professionally installed by your marine electronics dealer. He will make sure your HF radio is programmed with all the channels you need, and a proper antenna with non corrosion grounding and lightning protection is installed. NOTE: A modified ham rig displays frequencies, not channels, and you may not have time to figure channel frequencies in an emergency. AFTER ALL THESE ESSENTIAL ITEMS, you can consider an HF email setup. You will need an expensive Pactor modem, around $1500 more. Then you choose whether to pay Sailmail $200 a year for email access and obtain a ship's commercial radio license. Or you can also use Winlink for fees ("donations") charged by ARSFI and Winlink, and obtain a General Class Amateur Radio License, which requires an FCC written technical examination. But you should compare the costs of the HF radio system plus installation and antenna, Pactor modem, connect fees, and maintenance for the system with the use of competing, easy to use, license free, satellite phone and email systems. You already own the sat phone and probably a lap top computer, all you need to do email. The HF email alternative requires a lot more electronics gear that others aboard probably cannot figure out how to use, and it requires an FCC license to use it. Here are shopping guides that explain the true costs in detail: http://www.globalmarinenet.com/hf-radio-and-pactor-modems-vs-satellite-phones-for-email-at-sea/ http://www.globalmarinenet.com/hf-radio-vs-satellite-phones-what-is-really-free/ I am still baffled why ARRL, SSCA, Winlink, and Amateur Radio "Safety" Foundation still refer to the Bounty sinking on their web sites; if anything, it is an excellent example of HOW NOT TO CONTACT THE COAST GUARD. Usually a distress call should be in a mode that is most likely to be heard by the largest number of people. That should be by EPIRB or voice, not a proprietary digital mode readable only by others who possess an SCS Pactor modem. Disclaimer: This essay is my summary of the various stories about the Bounty replica ship sinking. All of my primary information comes from the sites in the links cited below, so that anyone reading what I wrote may verify my statements from the primary sources in the links, such as the final Coast Guard report and interviews with actual crew who survived. Unfortunately, the captain, a ham operator who lived a large portion of his life doing what he loved - sailing a vintage style pirate vessel replica - is not here to explain or defend himself. My perspective comes from reading Moby Dick and pirate stories when I was a kid in school, and at one time dreaming about the possibility of doing exactly what the other deceased crew member, who claimed to be a descendant of the authentic original Bounty crew did - live her dream. So I leave it to the experts - the Coast Guard and people who actual own and operate boats. However, the relevance of the Bounty story is brought up by ME because it was stated as a reason for FCC legislation (RM-11708), by the ARRL, Winlink, and SCS, a company who sells radio modems for use with SailMail and Winlink, to exploit the Bounty tragedy to support their commercial agenda. Read the links and form your own opinion. Here is the ARRL story on its web page, which puts the best possible PR spin on it. It is duplicated on the Winlink web page. I particularly invite you to compare the statements found there by Doug Faunt, N6TQS with testimony in the actual Coast Guard report referenced later in this web page: We had Winlink on the ship that we used for e-mail and accessing the Internet to post to blogs and to Facebook, and we finally found an e-mail address for the Coast Guard. As a last-ditch effort, we used Winlink to e-mail the Coast Guard for help. Within an hour, we heard a C-130 plane, and later, a helicopter overhead.
http://www.arrl.org/news/robin-walbridge-kd4ohz-missing-at-sea-after-sinking-of-tall-ship-em-bounty-em-ship-s-electrician-dou
Here is a commercial equipment provider's information on the sinking:
I have provided an archived copy of it here, since SCS has removed the material from their web page, along with a number of other related items. Here is the advertising pitch from Amateur Radio Safety Foundation that claims over 10,000 yachts use the Winlink HF email system: Here is Winlink's page about the Bounty sinking and the use of communications: Here is the account of an actual survivor of the sinking. Read it carefully and consider the work done during the repairs to the ship done in port earlier by the crew themselves rather than a shipyard repair facility. Note also the replacement of the Sat Phone by a lower powered hand held unit. Later problems with the engines are traced to filters. Money was always an issue. Two seasons ago, the ship's satellite phone broke and was replaced with a handheld unit. Last year, during the Boothbay refit, the ship was scheduled for repainting and re-caulking, along with a reconfiguration of the space below deck. Hansen and Walbridge tried to save money by having the Bounty crew do most of the work themselves. One crew member said that he asked the office for a new fuel-filtering system but was told to make do with the old one.
Read the account of one of the crew here: The port generator was by now the only thing running, and it, too, would soon be submerged. Faunt and Svendsen helped the ailing Walbridge up to the navigation shack, where, with effort, he was able to use the last of the ship's electricity to send an email to Simonin via ham radio. At 8:45, she forwarded the message to the Coast Guard; in the hours that followed, McIntosh's C-130 carried out its vigil circling over the ship.
Simonin was the Bounty organization business contact person on land. Bounty used WinLink to conduct all its business. It did NOT email the Coast Guard to establish first contact. Only AFTER Simonin obtained the Coast Guard email were they able to communicate via Winlink. The Coast Guard specifically warns people NOT to use email to contact it in emergencies. USCG website info, read down the page for contact procedure table: Currently the U.S. Coast Guard email system is not set up to accept or respond to emergency SAR messages. If you are in distress or need to report an emergency, do NOT send it via email, contact the Coast Guard via telephone or radio.
https://www.dco.uscg.mil/Our-Organization/Assistant-Commandant-for-Response-Policy-CG-5R/Office-of-Incident-Management-Preparedness-CG-5RI/US-Coast-Guard-Office-of-Search-and-Rescue-CG-SAR/Contact-USCG-SAR/Now that you know the FACTS, read the account:
Here is the analysis of the sinking by the Coast Guard, which gives the exact sequence of events and all details of the communication interchanges:
Given the injuries to crew and problems with dewatering, the Master and Chief Mate called for
assistance using a satellite phone and an HF e-mail system. They notified the owner via satellite
phone, who directed the vessel's shore support to contact the Coast Guard. At approximately
2045, the Coast Guard was notified by the vessel's shore support that the vessel was taking on
water and was last reported to be approximately 90 miles southeast of Hatteras, N.C. The Coast
Guard subsequently received a distress signal from the vessel's EPIRB and a C-130 was
launched to provide over-watch and establish direct communication with the vessel. At
approximately 2130 on Sunday, the vessel's starboard generator ceased operating when water
from the bilges splashed up and shorted it out. This left the vessel with no power.
160. After being informed of the loss of the port main engine, the difficulty with the bilge
pumps, the flooding, and the injury to the Captain, CM approached Capt. [redacted] and suggested that they should call the Coast Guard. CM testified that Capt. [redacted] told him the best thing for them to do was work on the generator and the pumps and get the vessel dewatered. The Captain chose not to take the Chief Mate's recommendation to
hail the Coast Guard at this time.
168. CM testified that, at approximately 1900, he once again asked Capt. [redacted] to call the Coast Guard, and once again, the Captain said "no."
169. At approximately 2000, the starboard generator shut down. The electrical bilge pumps stopped working but the portable hydraulic pump continued pumping. 2/M testified that, at the time, the water level in the engine room was now at the sole boards (a total level of 4 feet). Engineer was not in the engine room. 2/M s and AB now began changing out the fuel filter on the starboard generator itself. Neither had ever done so before. CM brought them a filter, and they were able to switch it out. It was reported that the process took from 25 - 40 minutes. During that time the electric bilge pumps were off line. 170. Also at approximately 2000, Capt. [redacted] agreed to call the Coast Guard. Attempts were made to use the single side band radio and INMARSAT C phone in the Nav Shack, but those were not functional. CM went up on the weather deck to use the handheld INMARSAT C phone. He testified that he called [redacted], [redacted], and tried calling CDR Mike Turdo, Executive Officer of CGC EAGLE, whom he had known through the Tall Ship community. He testified that he was having trouble using the phone, and could not tell if he was speaking to a person or voice mail. When he felt that someone had picked up he simply began to relay the vessel's position and that they were in distress. CM testified that he felt that he had the most success with the call to [redacted]. In fact, CM had not gotten through to CDR Turdo, but, rather, had left a voicemail. That voicemail was received and reviewed as part of this investigation. CM cannot be heard on it; it contains nothing audible. 171. At approximately 2045, U.S. Coast Guard Sector North Carolina's Command Center (SEC.NC CC) received their first notification of distress on the BOUNTY. That call came from [redacted]. had received the call from BOUNTY, and directed her to take action. She reported BOUNTY's last known position, that they had 15 to 16 persons on board, and that she was communicating with BOUNTY via the HF e-mail system. Sector North Carolina began coordinating Search and Rescue (SAR) efforts. was contacted by
the COMCEN, and stated that if the vessel was calling, they needed help and was the best point of contact for the vessel. He also related to the COMCEN that he believed that BOUNTY had 20 - 22 persons on board.
179. At 2141, SEC.NC CC notified that CG-2004 was en route to BOUNTY's last known EPIRB position to establish communications.
180. At 2215, Capt. [redacted] sent the following e-mail to [redacted] and [redacted]: 183. At 2246, Ms. [redacted] relayed e-mail information to the BOUNTY for contacting SEC.NC CC via e-mail. She explained that the HF e-mail system would not allow e-mails to go through until the vessel e-mails first.
184. At 2255 Capt. [redacted] sends the following e-mail to SEC.NC CC; We are 34-07 N X 074-08 course 130 speed 2.6 knots 17 people on board. I do not know how long I will be able to receive e-mail. My first guess was that we had until morning before we have to abandon seeing the water rise I am not sure we have that long. We have two inflatable life rafts. We have activated our EPIRB. HMS BOUNTY. 191. At 0005, CG-2004 established communications with BOUNTY, via VHF. BOUNTY relayed to CG-2004 that they have 6 feet in the lower hold. Discussions were had to determine if dropping pumps to BOUNTY to aid in dewatering would be feasible given the on-scene weather, lack of surface assets and BOUNTY's limited maneuverability.
192. At 0015, CG-2004 reported to Sector North Carolina Command Center that on scene weather is north west winds at 40 knots and 18 foot seas. 193. At 0022, BOUNTY relayed to CG-2004 that they had lost both generators, and were on battery power only. 194. At 0058, SEC.NC CC relayed to BOUNTY via e-mail that nearest surface assets were 8 - 10 hours away. Discussion began for a planned evacuation at sunrise. BOUNTY was directed to activate their second EPIRB if their situation worsens or if they start evacuation. At the time onscene weather was outside the operating capabilities of CG helicopters (H-60's). 196. At 0300, Capt. [redacted] had the crew muster near the Nav Shack to discuss the possibility of abandoning ship. Bosun testified that Capt. [redacted] asked "what went wrong, and at what point did we lose control?"
Notification
9. When Capt. [redacted] finally authorized CM to call for assistance on the night of October 28th , there had already been 3 crew injured (including himself), loss of the port main engine and port generator, problems with the starboard generator, blown out sails and damaged rigging, and flooding that had several feet of water in the bilges. With the clarity of post casualty analysis, looking at the timeline of continued difficulties aboard BOUNTY starting on Saturday October 27th and the continued proximity of the approaching storm center, the best time to have made the first call for assistance (pumps at least) would have been on Saturday when Capt. [redacted] attempted to engage the hydraulic bilge pumps, which were seen as emergency pumps. That said, based on testimony, his realization that the hydraulic pump did not work sometime the evening of October 27th, may simply have been too late, even if he had given the order right then to make the distress (MAYDAY) call. CM approached Capt. [redacted] twice on the afternoon of October 28th in an attempt to have notifications to the Coast Guard made. It is likely that earlier notification of the vessel's and crew's condition to ownership and the Coast Guard would have given more time to establish communications and ascertain the vessel's situation, and possibly arrange for assistance. However, as stated before, the on-scene weather conditions precluded air assets from assisting, and there were few if any vessels in the vicinity. Every tall ship captain interviewed for this investigation indicated disbelief over the actions of Capt. [redacted], and stated they never would have left port, or they would have sought a safe berth in sufficient time. Practically every vessel in the Atlantic chose to either tie up, or run from Hurricane Sandy. Capt. [redacted] chose to steer towards Hurricane Sandy at a near constant bearing and decreasing range with no compelling reason to do so. His actions conflicted with all known maritime methodologies for storm avoidance. It can only be concluded that he was not trying to avoid it at all. He purposefully placed his crew and his vessel into extremely dangerous conditions. This constitutes negligence.
5) Capt. [redacted] decided to notify the Coast Guard and HMS BOUNTY Organization regarding their distress much too late. When asked by CM S to call the Coast Guard, he refused stating that they would be better off working on the pumps. His decision smacked of pride, and was illogical given the danger they were in. He should have made calls for assistance on Saturday, October 27th at the first indication that the electric bilge pumps were not keeping up with the water ingress. This would have given them some opportunity to come up with an alternate plan or better their chances to receive assistance. This constitutes negligence. 7) The BOUNTY's single side band radio and INMARSAT C phone were not operational when the decision was made to request assistance. As they were not tested prior to departure from Boothbay or New London it is not known how long they were not functional.
Here is a YouTube video containing an interview with the captain of the Bounty: http://www.youtube.com/watch?v=BNDneMuO7-U&t=10m41s. You can see about 20 minutes into the interview the Bounty Captain's statement about chasing hurricanes, and some other interesting historic information. This is the Bounty's radio license: http://wireless2.fcc.gov/UlsApp/UlsSearch/license.jsp?licKey=2935665. This shows registration for only the SatPhone, a VHF ship to ship hailing short range radio, and EPIRB emergency beacons registered to the ship, which could have alerted the Coast Guard within maximum 45 minutes (depending on the position of the satellites) if activated in a timely fashion. By the time the SatPhone was tried to directly contact the Coast Guard, the noise of the storm was so loud above deck, the receiver could not be heard; the SatPhone had no separate above deck antenna, so it could not be operated below deck. This was a lower power replacement SatPhone which could have been carried off the ship to a life raft, a useful feature, but was not up to the job in this storm. No mention is made of the HF radio, and I have not found any information on exactly which ham radio was employed. Whether the amateur radio equipment was capable of all frequency transmit modification is unclear. However, one thing IS true - had the ham gear been modified for all frequency transmit while in port, it could have contacted the Coast Guard on one of its emergency channels legally, regardless of whether it was licensed or not. This is clearly a mistake on the part of the owners and operators of the vessel. The intent of using WinLink was to avoid commercial fees for a legitimate business use to contact the parent organization. This is the intent of this article: to demonstrate the dangers of this practice, and to urge boaters to employ the correct method of contacting them. It is also to correct some of the notions surrounding current pending FCC rulemaking which misuse amateur radio for pecuniary purposes. Check out this article titled "Insurance company sues owners of tall ship Bounty": Here is the analysis of the role played by ham radio, by a ham radio operator familiar with the Pactor mode and sailing. It is very critical of the use of ham radio as a substitute for professional methods.
Wikipedia has also since provided this very useful time line link: Finally, here is another more charitable account, including some details surrounding the Coast Guard hearing: As raised by the Coast Guard neither the HF radio nor the Satphone were verified working before leaving port. Possibly the reason HF contact on 20 meters did not succeed was that the microphone either did not work, or was damaged by salt water in the storm. Complicating this, the 20 meter maritime net on 14.300 shuts down later in the day, due to normal HF propagation conditions, and Walbridge had delayed calling there until SSB contact would not work. In this case, static from lightning in hurricane Sandy was probably intense, and people on shore may have shut down their ham stations to avoid damage to their equipment because the static was so loud it was pointless to take the risk of continued operation. Whether Walbridge would have been able to hear responding stations through the static from outside the storm area, if they were still active, is debatable. If the HF ham radio had been modified to transmit on maritime frequencies, they still might have contacted the USCG on the distress hailing frequencies. While illegal for normal ship to ship, or ship to shore, communication, any method is OK for emergencies. This is no substitute for a proper HF marine radio like the Icom M802 to talk directly on a USCG emergency hailing frequency or other vessels, but it would have been better than what was done. I still maintain the if amateur radio Pactor email (WinLink) is to be widely marketed as the primary means for ocean going vessels making emergency contact with the Coast Guard, we may see more bad outcomes along the lines of the Bounty sinking. This is why I oppose the institution of FCC RM-11708 as it is currently formulated, as well as the ARRL HF BAND PLAN PROPOSAL, which would promote even more use of Winlink as a substitute for available commercial services and use of HF radios not designed to communicate directly with the Coast Guard in the mode that USCG specifically requests (which is NOT by email). See the link at the beginning of the article for the Coast Guard emergency contact procedure. Vessels navigating inland water ways should be equipped with commercial grade VHF FM marine radios, not 2 meter ham rigs modified to transmit out of band. An amateur radio 2 meter rig can be modified for receive outside the ham bands, but transmitting with such a radio at full power on marine frequencies may burn out the finals, because it was not designed for that purpose. The use of HF amateur radio by inland vessels for email is also competition with commercial providers. I also maintain that IF ARRL intends to go ahead with supporting wide use of amateur based email by the boating community, it surely needs to be planned better than the current proposal. This will definitely take more time than is currently allotted. There is no reason to do it in the proposal's time frame. If this ARRL HF BAND PLAN PROPOSAL and FCC RM-11708 take effect in their current form, I predict that WinLink based internet access will become the Hydrilla of the HF amateur bands. Worse yet, more incidents like the Bounty replica sinking will result in loss of life and property. I have tried to provide links which give a variety of viewpoints for balance, as well as official Coast Guard reports, not news that has a "spin" to support an agenda. Back to the issue at hand, which is the implementation of the band planning in FCC RM-11708 and WT 16-239. The primary issue for me is the use of amateur radio, and Pending FCC Rule Making Procedures that will expand the use for free HF email. From statements by Doug Faunt, N6TQS, it was clearly evident that Winlink was being used daily by the Bounty organization when offshore to communicate with their home office rather than legal commercial providers. The FCC rule, "97.113 Prohibited transmissions (5) Communications, on a regular basis, which could reasonably be furnished alternatively through other radio services" was applicable, which ARRL seems to miss in their enthusiastic support for this. Walbridge and Winlink used radio for the most part NOT as emergency communications, except as an incidental by product of the free HF email for yachts. FCC rule Part 97.1 states: "(a) Recognition and enhancement of the value of the amateur service to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications." But free HF email for yachts is NOT emergency communications. Clearly government disaster relief operations want the emergency communications. If you want a steak, you should not have to buy the whole restaurant as I explained in my FCC Puerto Rico filing, http://wireless-girl.com/PSHSB17344.html. Seven Seas Cruising Association and Winlink organized a filing campaign to get FCC RM-11708 adopted. ARRL did not widely publicize it, thinking they could slide it through. See the whole story at: https://arrlse.org/ The SSCA and Winlink development team of Steve Waterman, Phil Sherrod, and Lor Hutchings mass comment filing operation by people like Randal Evans is explained in an FCC filing. Rarely do you see an amateur call sign in the signature of these comments requesting expansion of Pactor 4 for free HF email. See https://ecfsapi.fcc.gov/file/10100754910405/MATTHEW%20PITTS%20REBUTTAL1.pdf Only after the amateur community became aware of the FCC rule making and Winlink comment filing push, did amateurs get organized. In the final WT 16-239 Notice of Proposed Rule Making (NPRM), 92% of the comments were in opposition. It is still pending FCC action to make it a Report and Order (R & O). FCC rule 97.219 states: There clearly are ongoing violations of this rule, as shown in the Randal Evans comments to the FCC, since he sent messages from the radio frequency port of the system without a license. There are other instances we are aware of. There needs to be an FCC ruling that addresses this issue, the inappropriate use of amateur radio for routine daily business communications, the lack of station identification or content of message in a manner that can be monitored by any station. The other issue is unlicensed persons, who can automatically send email over amateur radio from the internet port of Winlink, without a working layer of protection to prevent inappropriate use. It is a use of "third party" that often moves well beyond the original intent of the amateur service in Part 97.1 and third party traffic rules. The destinations of these non ham originated messages can wind up in foreign territory where third party messages are not allowed at all even by licensed individuals, which is in conflict with our IARU international treaties. This automatic store and forward operation must be done in a separate segment of the spectrum to mitigate interference, if indeed it is allowed at all. Here is just one instance in many of this activity, in the FCC's own filings in RM-11708. FCC RM-11708 comments by a Winlink user, Randal Evans, employing a "borrowed" amateur call sign:
https://ecfsapi.fcc.gov/file/7521315143.pdf To: FCC - RM-11708
The sailing forms are all encouraging us to file comments in support of RM-11708. This is my first filing and if I mess this up, please see SailNet Forum at: http://www.sailnet.com/forums/general-discussion-sailing-related/111746-us-citizensurged-support-fcc-rm-11708-a.html I have experienced very dependable service from the amateur radio Internet Winlink system. Its a great service because all of the other available Internet services cost money. Even when I am topside crusing (sic) the system runs automatically below deck publishing my position reports and downloading my email. I use the system for sending position reports, ordering supplies, repairs, chatting with friends and posting to facebook. My only complaint is that it needs to be much faster. I am not a amateur radio operator yet but a friend lets me use his call with a SIDD on the end. I hope to get my own ham call soon. From what I read on the sailing forums, RM-11708 will allow Winlink eMail to run twice as fast. That is great and I am for that. Some of the technical folks are saying that if RM-11708 is published with no bandwidth we can get even faster Internet and might be able to stream movies on the Winlink Internet. I'm for passing RM-11708 into law with no bandwdith limits. I heartily encourage you to use the forum link in Randal Evan's comments to see how amateur radio packet is being promoted as an alternative to Sailmail. Is this a legal non commercial use of Winlink or is it a way of dodging a $250 per year fee for Sailmail? Are the Winlink Sysops controlling this kind of use? FCC 97.113(5) Prohibited Transmissions: "Communications, on a regular basis, which could reasonably be furnished alternatively through other radio services." Are ARRL Official Observers (OOs) monitoring this? Do OOs even possess the technology to do so, or do the inherent characteristics of Pactor even permit it? Some commenters indicate that even snagging the call signs is dicey when attempting to decode the transmissions. Let's get something straight. Randal Evans is NOT the bad guy here. He just wants to sail his yacht, and have free email while off shore. He made a financial decision based on misinformation a ham operator who was advocating for Winlink told him. This ham told him it was OK for him to "borrow" a ham license call sign. It is more common than most people realize. Randal Evans used the free HF email like he would use any other internet provider's service. Randal Evans read a posting in a sailing forum from Phil Sherrod, W4PHS, and Steve Waterman, K4CJX (Winlike Officers) telling him to file comments in FCC RM-11708 to get faster free HF email. With his limited knowledge of how amateur radio works, he filed a truthful and revealing comment on the common practices already in use, even before the proposed rule makings of RM-11708, WT 16-239, RM-11759, and the new Tech Enhancement are enacted. Once these Notice of Proposed Rule Makings (NPRM) are law, how much worse do you think it will get? The FCC will enact NO BAND WIDTH LIMITS in WT 16-239 NPRM, not just the 2.8 KHz the ARRL petitioned for originally in RM-11708. RM-11759 will reduce the Extra 75 meter phone segment by 50 KHz to provide more space for Winlink free HF email. This would open the entire CW/DATA HF band segments to wide band data used for HF email store and forward servers. Once a channel is designated for such a server, it no longer is available for any other use; this is how voice repeaters work on 2 meters. On VHF/UHF, the channel is set aside for a roughly 100 mile area. On HF, the propagation carries that channel reserved for the exclusive use of just ONE Winlink RMS transmitter WORLD WIDE. Techniques that work on VHF and UHF do not transfer well to HF. Currently, those wide band signals from Pactor are confined to narrow HF segments referred to as ACDS. Once RM-11708 and WT 16-239 are enacted, the entire CW/DATA segment will be available to wide band Pactor 4 or other Winlink free HF email RMS stations. How will the following FCC rule work? "97.101 General standards. (a) In all respects not specifically covered by FCC Rules each amateur station must be operated in accordance with good engineering and good amateur practice. (b) Each station licensee and each control operator must cooperate in selecting transmitting channels and in making the most effective use of the amateur service frequencies. No frequency will be assigned for the exclusive use of any station." When WT 16-239 is implemented, CW, PSK, JT, FT-8, and CW will become secondary users. There is no way to tell if the wide band data signal on the frequency is legitimate emergency communications or some one ordering parts for his boat or posting to Facebook. You will have to vacate the frequency when a Winlink RMS transmits on the frequency you had occupied, to avoid accusations of malicious interference. EACH Winlink user can access HF email for 2 hours each day. One Winlink estimate places the number of clients aboard yachts at 10,000 users. Steve Waterman stated on page 4 in his FCC filing https://ecfsapi.fcc.gov/file/10123298305905/%2017-344.pdf:  Imagine our usual "Tech License in a Weekend" classes, offered by a marina. Here is the real problem with the ARRL's Enhanced Technician license: it does not restrict "enhanced tech" use of HF bands for free email to third party users. Neither does it assure a store and forward email system (RMS) will be installed by a competent General Class amateur; Technician licensees will not have been tested on the operation of this equipment even at the user level, let alone at the Control Operator level. Yet a Technician licensee can set up an RMS under the new rules. Do you want your safety compromised in such a fashion? There is no way to tell if the wide band data signal on the frequency is legitimate emergency communications or some one ordering parts for his boat or posting to Facebook. Hams will have to vacate the frequency when a Winlink RMS transmits on the frequency they had occupied (because they cannot decode it), to avoid accusations of malicious interference. The ARRL Enhanced Tech License targets Randal Evans and this audience. If the ARRL plans are enacted, the result will be chaos and interference will render the spectrum unusable by anyone. So this is not about grumpy old guys begrudging sailors their hyper connectivity when off shore. It is about reallocating significant portions of the amateur service HF spectrum to uses formerly illegal in that space, when commercial spectrum is available. It should be about mitigating interference which will occur to all occupants of the amateur spectrum. It should have been about having a separate commercial spectrum service, where email operations are legally the primary users, professionally maintained and operated and licensed in its own spectrum, so that the kind of communication sent there is legal, safe, and reliable, without interference from non email users. Equip your vessel with the best safety and communications gear you can afford, and have it professionally maintained. Enjoy your cruise, in the knowledge you have taken all reasonable measures to ensure a safe, fun voyage. 73 and safe sailing, Janis Carson AB2RA |
2015 July ARRL Board Minutes Summary