My name is Terence (Terry) Rybak, I am licensed as W8TR, I have held an Amateur Radio license since 1963.
I am replying to REJECT RM-11828, RM-11708, RM-11759 and 16-239. 
I am  replying to the ARRL PETITIORM-11828. 

It does not grant 10 meter privileges to Techs that they are qualified for: FM, AM, repeaters, and satellites.
This should be changed to give parity with Tech's existing privileges, granting nearly 2 MHz more HF spectrum for Techs.

It will provide the opportunity for Techs to experiment, advance their skills, and interact with higher class amateurs in a variety of modes, to be mentored.
RM-11828 should be rejected, since it does not include this important benefit.

RM-11828 provides no proof it will increase participation in amateur radio or promote upgrades.
The current Technician beginner's license can be obtained after a one weekend course.
The General exam is not a burdensome barrier to upgrading to HF privileges either.
Study and take the test, as incentive licensing already provides.
RM-11828 grants Techs 55% of the total General HF VOICE allocations.
This will reduce the incentive to upgrade.
RM-11828 grants Techs 50% of the 80 meter General VOICE allocation.
This is too large. Old Novice CW segments were only 50 KHz.
This will reduce the incentive to upgrade.
RM-11828 grants Techs 50% of the 80 meter General VOICE allocation.
This is too large. Old Novice CW segments were only 50 KHz.
This will reduce the incentive to upgrade.
RM-11828 and RM-11759 seek to grant Technicians data privileges taken from the bottom 50 KHz of the current 80 M Extra Class phone band.
This is contrary to the long standing FCC policy of incentive privileges.
RM-11828 and RM-11759 should both be rejected.
RM-11828 includes 60% of the General VOICE allocation on 40 meters.
At night, the upper 100 KHz of 40 meters has foreign broadcast interference.
There should be NO 40 meter VOICE expansion for Techs. As this will reduce the incentive to upgrade.
IARU region 1 & 3 only has 200 KHz for both DATA and VOICE, some of it secondary.
RM-11828 grants substantial portions of the useable IARU Region 1 & 3 40 meter DATA AND VOICE allocation to Tech DATA.  This will interfere with current users of the band.  There should be NO 40 meter DATA privileges for Techs at all.  This will also reduce the incentive to upgrade.
The Tech license does not cover General Question Pool G2E02(B), G2E03(D), G2E07(A), G2E09(C), G2E10(D), G2E12 (C), G8C06 (B), G8C07 (B), G8C01(B), G1E05(C), G1E11(C), G1E12(A), G1E13(D), which cover essential modern HF digital communications procedures.
Existing HF DATA, FT8, and CW operations will be harmed.
The General exam is not a burdensome barrier to upgrading to HF privileges either.
Study and take the test, as incentive licensing already provides.
Oppose granting any additional HF DATA privileges to existing or new Techs. 

RM-11828 permits a Technician to be a control operator of a wide band automatic store and forward email repeater without any knowledge of its basic functions on a user level. 
Repeater operation on VHF and UHF uses local propagation.
Consequences of incorrect operation on HF to FT8, CW and DATA are world wide. 

The FCC has not finished RM-11708 or Docket 16-239. The FCC should dismiss RM-11828 until it has finished work on RM-11708 and 16-239.
Existing FT8 and CW operations will be harmed.