Response to RM-11831 from Timothy Helming, WT1IM
RM-11831 is misguided in its premise, overreaching in its scope, and (if adopted) would be harmful not only to Amateur Radio, but perhaps even more importantly, to the persons and communities served by Amateurs in the United States and beyond.
By way of background, I am a licensed Amateur of over 25 years' experience, and hold leadership positions in both recreational radio and emergency communications organizations in the Seattle area. I have participated in public service communications for most of my Amateur career and intend to continue doing so as long as I am able. 
If adopted, RM-11831 could greatly curtail or even eliminate the use of important digital modes on the Amateur bands. Digital modes have proved nothing short of revolutionary to Amateur communications for logistical and emergency operations. Any Amateur who has taken part in verbal or Morse traffic handling knows that the processes of sending, validating, acknowledging, and, when necessary, correcting, such messages is a slow and painstaking process. By contrast, the digital modes that enable systems such as Winlink, are fast, reliable, and, once learned, easy to use. 
Progress in the radio art has always encompassed new modes of transmitting and receiving, rendering existing equipment unable to decode the newer signals. The petitioner claims that digital transmissions are opaque to the average listener (and, by extension, to the FCC itself) because of the necessary software and/or hardware required to decode the transmissions. While it is true that one cannot decode these transmissions by ear, a similar argument could have been made when AM succeeded CW, when SSB succeeded AM, when FM succeeded all of the amplitude-modulated modes, etc--each new modulation mode rendering the previous-generation technology deaf to the new transmissions. History has proven that none of these deveopments impeded the self-policing of Amateur Radio, and fortunately for all of us, not one of those modes was prohibited on such grounds. Needless to say, the benefits of these advances to the radio community and the public at large have been incalculable. 
In exchange for theoretical protection against unlawful and dangerous transmissions by evildoers ("protection" that would be utterly meaningless in practical application, since criminals by definition flout the law), the petitioner proposes to take away from Amateur and emergency communications teams many very real benefits conferred by digital communcations. These include:
High-speed transmission of messages, with automatic error correction and validation
Conservation of bandwidth (compared with voice modes)
The ability for Amateurs to communicate to non-Amateurs via email, providing a seamless interface between communities for practical and timely communication
Real-time and near-real-time transmission of photos and even video (for example, from Amateurs in an earthquake or flood zone to emergency management officials in a command center)
The ability of the Amateur community to self-police is not meaningfully impeded by the advent and adoption of the existing digital modes, nor will it be by future modes. Hardware, software, and training are readily available to those with an interest in monitoring digital transmissions. 
It is worth noting, as well, that some in the discussion have erroneously conflated digital encoding methods with encryption. Winlink email (as one example) is encoded but it is not encrypted. Ignorance of the difference between encoding and encryption has led some commenters to believe that popular digital modes violate the FCC prohibition of encryption on the Amateur bands. I know of no Amateurs who wish to promote, or take part in, encrypted communications.
To conclude, I ask the reader to consider the following: if the contents of this statement were a message to an incident command center following a disaster where Amateur Radio operators were asked to provide a field report, using standard voice messaging protocols for error-free transcription by the receiving station, the statement would take approximately nine minutes to read and confirm, assuming zero errors (and a zero error rate in a statement of this length is highly unlikely). By contrast, to send this message as a Winlink email, whose error correction and validation are intrinsic to the system, would take approximately 30 seconds via an RF packet connection. 
I endorse the motion to dismiss RM-11831 by the Amateur Radio Safety Foundation (https://www.winlink.org/sites/default/files/rm-11831_motion_to_dismisspetition.pdf), as well as the comments in opposition to 11831 by members of various Amateur emergency communications organizations.
I urge the Commission to reject RM-11831.
Sincerely, 
Timothy Helming, WT1IM
Public Information Officer and Sector Lead, Seattle Auxiliary Communications Service
Vice President, Puget Sound Repeater Group
Seattle, WA