Before the Federal Communications Commission Washington, DC 20554
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Before the Federal Communications Commission Washington, DC 20554 In the matter of: Proposed changes to Part 97.305 ) of the Commission's Rules to limit ) certain types of transmission ) RM-9673 on prescribed portions of the ) Amateur VHF and UHF bands ) Introduction I have been a licensed radio amateur (starting with WN5ITT) since February = of 1973. I currently hold an Advanced Class license (callsign WB5ITT), 1st = issued in August of 1974. I am a life member of the ARRL and the Texas VHF = FM Society (both since the late 1970s) and am currently serve on the Board = of Directors of the Texas VHF FM Society. I also hold FCC General = Radiotelephone license PG-9-5322 and am Chief Operator of Clear Channel-Dal= las's broadcast stations: KDMX-FM and KEGL-FM. I operate repeaters and = packet digipeaters on most of the VHF/UHF amateur bands and have been = active on the weak signal segments of the 50 and 432 MHz bands as well as = the satellite bands of 144 and 438 MHz. I am likely the only member of the = TX VHF FM Society currently Board of Directors to operate weak signal in = the VHF and UHF spectrum. The Texas VHF FM Society is a repeater coordinati= on group in the state of Texas; but, under Part 97 definitions, a = coordinator has NO legal standing with VHF-UHF weak signal operations; = only repeater and auxiliary operations. Discussion The Central States VHF Society (CSVHFS), which represents a large number = of the weak signal operators in the United States, filed a petition to = protect certain segments of the 50, 144, 222 and 432 MHz bands from = encroachment by wide band modes, namely FM voice and packet. On June 28, 1999 the Commission designated the CSVHFS filing the above RM = Number.=20 I support the CSVHFS filing and the Commission's RM. I believe that the = Rules changes desired by CSVHFS are in the best long-term interest of = Amateur Radio. I personally feel that the threat CSVHFS cites is real and = have personally encountered such problems in the years of my operation. = This threat does have the potential to severely limit the valuable long = haul / weak signal work and experimentation taking place on the bands = above 50 MHz. Also, the addition of RTTY and DATA will allow these modes to utilize the current CW only = portions of the 6 and 2 meter bands. This will allow more productive use = of these segments as in the HF frequency segments and prevent the = non-voice modes from causing problems in the SSB weak signal areas. In the petition, the CSVHFS did incorrectly quote Part 97.305 in their = requested change. I personally acknowledge that they have admitted to that = mistake and they merely request that the following bands only be affected: 50.0-50.1 Add DATA and RTTY 50.1-50.3 Prohibit angle modulated modes as in Part = 97.307(f)(1) 50.3-54 NO Changes 144.0-144.1 Add DATA and RTTY 144.1-144.3 Same as 50.1-50.3=20 144.3-148 NO Changes 222.0-222.15 Same as 50.1-50.3 222.15-225 NO Changes 420-431.8 NO Changes 431.8-432.5 Same as 50.1-50.3 432.5-450 NO Changes I plead that the FCC will see the error of the CSVHFS petition and correct = this in any positive action they take on this. The amount of bandwidth the = CSVHFS is requesting to be excluded from normal 5kHz deviation FM voice = and packet is less than 2 MHz total (less than 1% per band!) and will not = impact FM voice or packet operation at all while providing protection for = weak signal operations. In fact, FM voice will still be legal but only = under REDUCED deviation and bandwidth. Since most FM radios are not = capable of changing deviation on a per frequency basis, this is keep = almost ALL FM voice and packet out of the weak signal segments noted = above.=20 With 16-20kHz of bandwidth used by a standard FM voice or packet signal, = this can use up the space of 5-6 SSB conversations. This kind of interferen= ce is happening more and more. ARRL Headquarters has stated it believes in = education, but clearly education is not working and the ARRL itself does = not represent the MAJORITY of amateur operators in the United States. = Their education idea is flawed; if it were not, then why did the League = push for the 222-222.15 MHz prohibition on repeaters on the 1.25meter = amateur band some years ago? It openly acknowledged then that the weak = signal operators needed protection from FM users. Nothing has changed = since then and actual interference problems have grown because of the = amount of new Technician Class amateurs who received NO formal education = on bandplans (or they do not care about bandplans and will operate = anywhere the rules allow!). Summary I STRONGLY urge the FCC to adopt the petition as noted above and put into = effect the changes requested by the CSVHFS. Parts 97.305 and 97.307 of the = Commission's rules have prohibited such emission modes below 29.0 MHz for decades! Therefore, precedent has been set for this type of restriction= s on the VHF/UHF bands; more so now with the added growth of weak signal = enthusiasts because of the availability of multimode gear for these bands = in the past decade. Respectfully submitted, Christopher W. Boone WB5ITT PG-9-5322 PO BOX 803023 Dallas, Texas 75380-3023.