From the SailNet forums - a posting by K7GO

I am writing in opposition of the ARRL's proposed RM-11708. I have enumerated my points for your consideration below.

1) A single commercial vendor is the primary beneficiary of the ARRL's proposed change: SCS, the sole provider of Pactor III/IV technology. Passing RM-11708 will greatly benefit a single vendor with proprietary technology. SCS has a monopoly position in the Pactor III/IV market with no existing competitors. The passing of RM-11708 could tremendously boost SCS's revenues and the proliferation of their proprietary technology. This would further increase our dependence on the product of a foreign vendor. Add to this the additional risk to US emcomm infrastructure due to our deepened technology dependence on a single, privately held company.

2) Pactor III (and soon Pactor IV) technology is largely used to the benefit of marine small craft owners who do not wish to purchase satellite internet service or other fee-based marine radio services for their crafts. They opt to utilize free hamradio instead. It is not in anyone's best interest for ham radio to become a replacement for commercial services. If RM-11708 is approved there will likely be an increased number of adopters of this technology to the detriment of commercial services like satellite internet.

3) Pactor III/IV transmissions are by their very nature encrypted. Without an expensive (approximately one thousand dollar modem) from SCS these transmissions cannot be effectively monitored. This nullifies any sort of self-policing of the amateur service. I cannot think of a single additional area in the amateur radio service where this is true.

4) The subsequent proliferation of unmanned e-mail "robots" will put tremendous pressure on narrowband data mode users. Highly bandwidth efficient narrowband data users (PSK31 is one example) will suffer due to the inability of the Pactor robots to detect the low-energy narrow-band signals. The consequences of the increased congestion would be difficult to avoid and could as a side effect decrease the number of narrowband data users.

Thank you for your consideration.
Lewis R Paceley

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