EX PARTE OR LATE FILED

June 3, 1997 4353 Napa Valley Drive Bellbrook, OH 45305

Federal Communications Commission 1919 M Street, N.W. Washington, D.C. 20054

RE: Reply Comments to RM-8737

Dear Sir or Madam:

Enclosed for filing please find the original and eight copies ofmy reply comments in this matter.

Thank you.

Sincerely,

No. of Copies rec'd or ~_ List ABCDE EX PARTE OR LATE FI~Qe~t\ F\Lt copy ORIGINAL Before the Federal Communications Commission Washington, D.C. 20054 ) r~~ ~ ,

In the Matter of ) WT Docket No 97·d ) ~,lt~."" " ;" .., .. .:L i '..... I'·' Amendment of the Amateur ) RM-8737 F"',<' Service Rules to Provide for ) Greater Use of ) Communication Technologies )

To: The Commission

REPLY COMMENTS OF: John R. Ackermann AG9V 4353 Napa Valley Drive Bellbrook, OH 45305 [email protected]

June 3, 1997

Introduction

I have been an amateur operator since 1974. I have held an Amateur Extra Class license since 1979, and a First Class Operator's License and its successor since 1980. Over the years I have actively pursued many facets of the hobby, including "DXing," contest operation, building and using voice repeaters, and weak signal VHF operation, but for the last decade my primary interest has been in using digital communications within .

Although I am a member of the American Radio Relay League, Tucson Amateur Corporation, and the Radio Amateur Corporation, I am filing these comments in reference to this Notice of Proposed Rulemaking, solely on my own behalf.

Discussion

I believe that the Commission's consideration of the rules relating to spread spectrum ("SS") communication is a step forward for the Amateur Radio Service, and I applaud this action. However, I am concerned that certain ofthe proposed rule changes will unnecessarily hamper the development and implementation of SS techniques in the ARS. Two proposed provisions cause me particular concern. Although some comments filed in response to this Notice of Proposed Rulemaking support their inclusion, I respectfully disagree and instead suggest that these provisions do not further the Commission's intent to encourage technical innovation within the Amateur Radio Service.

First, the requirement in proposed Section 97 .119(b)(5) for identification is counterproductive. The narrow-band identification may itself cause interference even though the SS emission does not, and it is likely to be difficult to correlate the CW identification with a particular SS signal. This requirement also precludes the use of currently available commercial SS equipment, as to my knowledge no such unit provides for CW identification.

Second, the automatic power control provision contained in proposed Section 97.311 (g) is unnecessarily restrictive. Automatic power control has the potential to improve the channel efficiency ofSS signals, but this is as yet unproven in the amateur environment, and it adds unnecessary complexity to the development of experimental hardware. I believe that at this stage of SS development, it would be more appropriate for the rules to encourage, rather than require, the use of automatic power control.

Another concern with proposed Section 97.311 (g) is the 100 watt power limitation. This limitation places SS in a second-class position with respect to other modulation methods used in the Amateur Radio Service, and it effectively precludes the use ofSS in some unique areas such as moonbounce.

Conclusion

One of the cornerstones of the Amateur Radio Service has been technological innovation. Numerous technologies that are in common commercial use today were first proven on the ham bands. However, amateur work with SS has been hampered by the current rules, and as a result hams have lost the opportunity to experiment with - and, based on past experience, likely improve - this technology. Therefore, I applaud the Commission's decision to consider relaxation of these restrictive rules.

However, as I have noted, the proposed rules still place SS at a disadvantage with respect to other modulation methods and unnecessarily constrain amateur radio operators' ability to advance the state of the art. I urge the Commission to remove these restrictions so that SS may develop on an equal footing with other technologies.

RESPECTFULLY SUBMITTED,