At the request of CEO Michel and President Roderick, I have just sent the email below to the FCC requesting an emergency temporary waiver for use of PACTOR 4 for response and relief to Hurricane Dorian. It is the same language used in the past two years when these requests have been made, but with the addition of the language related to its possible use on the five channels on 5 MHz for interoperability with SHARES and other federal response. 73 Dan Henderson, N1ND Assistant Secretary - American Radio Relay League, Inc. Regulatory Information Manager ARRL, the national association for Amateur Radio (r) 860-594-0236 dhenderson@arrl.org<mailto:dhenderson@arrl.org> From: Henderson, Dan N1ND Sent: Sunday, September 01, 2019 8:24 PM To: Scot Stone <Scot.Stone@fcc.gov>; roger.noel@fcc.gov; kathy.harris@fcc.gov; Curt.Bartholomew@fcc.gov Cc: Roderick, Rick, K5UR (President) <K5UR@arrl.org>; Michel, Howard, WB2ITX (CEO) <wb2itx@arrl.org>; Pereira, Carla, KC1HSX <cpereira@arrl.org> Subject: Emergency Request for Temporary Waiver for Amateur Radio Hurricane Relief Effort Greetings. This is an emergency request for a temporary waiver (for a period of thirty (30) days, subject to further extension at the Commission's discretion) of Section 97.307(f) of the Commission's rules. The request is made on behalf of ARRL, the national association for Amateur Radio, and for those licensed radio amateurs who are directly involved with hurricane relief via High Frequency Amateur Radio using PACTOR 4 modems in communications within the Continental United States relative to impending Hurricane Dorian. This request is authorized by Rick Roderick, ARRL President and Howard Michel, ARRL CEO. The circumstances are as follows: Section 97.307(f) of the Commission's Rules limits the digital data emissions of Amateur stations operating below 28 MHz to a symbol rate not to exceed 300 bauds, and in the 10-meter band (28.0-28.3 MHz) to a symbol rate not to exceed 1200 bauds. This rule invalidates the use of PACTOR 4 emissions. PACTOR 4 is a data protocol that permits relatively high-speed data transmission in the High Frequency (HF) bands and many Amateur stations active in emergency communications preparedness are capable of using this high-speed data protocol. It has been used pursuant to FCC temporary waivers to great advantage in Hurricane Maria relief and more recently in preparing for Typhoon relief communications in Hawaii. Trained amateurs with communications equipment in the southeastern United States are actively preparing to assist radio amateurs involved with the Amateur Radio Emergency Service (ARES) working with federal, state and local emergency management officials to assist with disaster relief communications in anticipation of the arrival on the southern East Coast of Hurricane Dorian. This equipment includes PACTOR radio modems that are capable of both PACTOR 3 and PACTOR 4 emissions. The modems are downward-compatible with slower speed versions of PACTOR. However, the higher data rates offered by PACTOR 4 emissions are critical to sending hurricane relief communications including lists of needed and distributed supplies, etc. Many other Amateur stations involved in hurricane disaster relief communications are capable of using PACTOR 4 emissions from their stations inside and outside the anticipated landfall area. All stations capable of use of PACTOR modems in connection with hurricane relief efforts should be able to use PACTOR 4 published protocols. These stations must be able to communicate with similar stations in the United States which are directly involved with hurricane relief efforts, as well as Federal stations on the five-channels on the 5 MHz involved with the SHARES network and other interoperability partners on those frequencies. It is proposed to limit the use of PACTOR 4 emissions to those radio amateurs in in the Continental United States who are directly involved with the hurricane relief efforts involving the U.S. mainland. This request is without prejudice to the resolution of Docket 16-239 which is presently pending and addresses the rule section discussed herein. Thank you for your consideration of this request. We would be most appreciative given the urgency of the matter. Respectfully submitted, Dan Henderson, N1ND Assistant Secretary - American Radio Relay League, Inc. Regulatory Information Manager ARRL, the national association for Amateur Radio (r) 860-594-0236 dhenderson@arrl.org<mailto:dhenderson@arrl.org>