I wish to express my strong opposition to the proposed rule change RM-11831. I have three primary concerns:
1. The problems the petition seeks to address are demonstrably inaccurate: 

Stations sending digital modes are readily identifiable, and their content can be read with widely available software that is open source, and with technology that is a fraction of the cost of most radios. Frequencies can be passively monitored for digital transmissions by and those transmissions searched with algorithms, e.g., for callsigns, making digital modes easier to monitor than phone transmissions. 

There is no widespread or increasing interference from digital transmissions. The petitioner acknowledges the lack of formal complaints, and attributes it to the difficulty of identifying offending stations, which, as noted above is untrue. The voluntary band plan already segregates digital and phone transmissions on 6 of the 9 HF bands as well as the 10M band, meaning that the ham community has already taken steps to avoid conflicts among those using different transmission modes. And digital modes are highly efficient; replacing digital transmission with equivalent phone transmission would increase, not decrease, congestion on the ham frequencies.  

2. Digital modes are an essential public safety tool. Digital modes have several critical advantages over phone transmissions that are essential in disaster response and public service events. 
First, under good conditions, there are digital modes (e.g., 8PSK-1000F) that can transfer large amounts of data, with high reliability, extremely quickly--e.g., formatted, detailed reports of resources available and resources needed at a given location (information that could take hours to convey by phone can be delivered in minutes via digital). 
Second, under poor conditions, there are digital modes (e.g., MT63-2KL) that can transmit information (again with high reliability) many decibels below the noise floor under conditions where phone exchanges would be impossible. 
Finally, packet digital allows for passive transmission of data such as a station’s location, their capabilities, who is deployed to their location, or local conditions. This makes it possible, for example, for an incident commander to keep a real-time account of where her/his/their assets are deployed and what the stations’ capabilities and conditions are without actively requesting and receiving the information. 

3. Digital modes are super fun--let’s keep them! Digital modes are serving all the functions that ham radio was created to serve: we’re forming community and exchanging “remarks of a personal character”; we’re experimenting and advancing our collective understanding of radio and all the ways we can use radio to communicate with each other; and as noted above, we’re serving our communities finding out how digital modes can help make radio useful when we find ourselves without other communication channels. And if Ron K0IDT reads this, I’d be happy to talk with him about digital modes and would love to help him try some out.

Thank you for considering my comments.

Christian Helfrich, K7XTN
Radio Operator, Seattle Auxiliary Communication Service / Seattle ARES
Member, Puget Sound Digital Hams Net