RE: Comments on PSHSB 17-344
> Ladies and Gentlemen,
> I am writing to urge the Commission to dismiss proposals that would 
> permit wideband digital modes on
> narrowband HF frequencies.
>
> The following arguments were prepared by Peter S Alterman, W2CDO and
> were previously submitted. I fully support these arguments.
>
> The particular issues that make wideband modes in narrowband HF 
> frequencies incompatible with all
> other services, especially during emergencies are:
>
> Impede, Rather than Improve Emergency Communications:
> Unattended wideband modes, e.g., PACTOR , require expensive equipment 
> at both ends of the
> communications path. This equipment is available through a single 
> manufacturer. This limits the number
> of stations that can deploy such a mode during an emergency.
>
>  On the other hand, most amateur radio
> stations on either side of a communications channel during an 
> emergency have the necessary
> equipment, available from a wide variety of manufacturers (and even 
> home brewed equipment) to
> successfully communicate.
>
> Not Efficient: PACTOR wideband modes are not efficient. They consume 
> limited HF frequencies
> dedicated to narrowband communications. In fact, these modes have a 
> bandwidth footprint that is
> comparable to SSB voice bandwidth and therefore would be better 
> located within those subbands, if
> anywhere.
>
> Encryption: PACTOR modes are encrypted modes. Encrypted transmissions 
> are explicitly forbidden by
> Part 97.
>  More germane at this point in time is that the Defense, Intelligence 
> and Law Enforcement
> authorities of the United States aggressively oppose any expansion of 
> encrypted communications of any
> sort and this position is a vexed issue at the highest levels of 
> government.
>
>  A corollary argument that has
> been put forward regards a putative need for encrypted communications 
> to satisfy HIPAA privacy
> communications requirements. The Centers for Medicare and Medicaid 
> Services, DHHS, which is
> responsible for HIPAA regulation and the Office of Civil Rights, DHHS, 
> which is responsible for policingHIPAA compliance, do not classify 
> amateur radio communications as Covered Entities under HIPAA.
>  That means that such communications when used to exchange data 
> regarding a patient are not subject to
> HIPAA regulations or the Privacy Act regarding protection of 
> personally identifiable information. Any
> argument made on these grounds should be immediately dismissed as 
> misleading.
>
> Unavoidable Harm to Thousands of Active Operators: Winlink, indeed any 
> unattended mode, interfere
> with ongoing narrowband communications in HF. This also is a violation 
> of Part 97 regulations governing
> the behavior of amateur communications. Narrowband communications 
> modes are not compatible with
> the bandwidth demands of wideband digital modes. Tens of thousands of 
> amateur radio operators will
> be unavoidably harmed if unattended and wideband digital modes are 
> allowed free rein in narrowband
> HF frequencies. This is clearly not in the best interests of the 
> amateur community.
>
> Unnecessary Regulation: Finally, the Commission has the authority to 
> direct waivers and special
> permissions to allow or disallow any communication and mode anywhere 
> within the amateur frequency
> allocations during times of emergencies. There is no need for a 
> regulation giving special privileges
> sought by special interests advancing their monopolistic mode on the 
> basis of emergency
> communications service.
>
> Respectfully,

William K. Mabry, N4QA