Please do not approve RM-11831.  Arguments in support of RM-11831 are based on false premises.  The implementation of RM-11831 would have a significant and negative effect on emergency services provided by amateur radio operators in the US.

Winlink is a service provided by radio amateurs to transmit e-mail in situations (such as natural disasters) in which the internet is not available.  Methods of data compression do not result in "encryption," but are, in fact, based on open-source encoding algorithms.  Messages sent in this way can be decoded by a third party based on publicly available information, as required by other FCC rules.  Implementation of RM-11831 is not necessary, as FCC rules are already being met. 

Elimination of the data compression algorithms, as proposed in RM-11831, would significantly hinder the transmission of urgent messages in an emergency situation, especially those using Winlink.  Current disaster-preparedness and ongoing disaster-relief programs depend on these algorithms for efficient communication.

Furthermore, the deletion of Part 97.221(c), as proposed in RM-11831, will force all US ACDS stations into the narrow sub-bands provided in 97.221(b). This will result in more interference between users, not less.

Currently, in order to initiate transmissions, Automatically Controlled Digital Stations (ACDS) are activated to transmit by a human operator who is required to listen on frequency for activity, and to activate the ACDS station only when the frequency is clear. Busy-detectors are used in the software of both client and ACDS stations:  transmissions are prohibited unless the software detects a clear channel. FEC or CW identification is transmitted by all stations. These procedures prevent significant interference between users, obviating the need for removal of ACDS stations from current usage bands.

More information about my concerns can be found at https://winlink.org/sites/default/files/rm-11831_response_arguments.pdf

Respectfully submitted,

Robert E. Piston