Comment in response to Docket 19-348 (3Ghz) I am an Amateur Radio Operator, callsign W6BI. I use the Part 97, 3 GHz allocation to build and operate a high-speed data network for use in part by emergency/disaster agencies. It’s used to send texts, email and to provide video surveillance, video conferencing and VOIP (voice-over-IP telephony). This network is possible partly because of five 3 GHz radios I operate between 3.3 and 3.5 GHz. They provide valuable high-bandwidth links between sites. My network installation in Simi Valley, the and the Santa Clarita Valley, all in Southern , connects to other compatible network equipment in the surrounding area, provided by other radio amateurs. These three sections of the Southern California network alone cover an area of 240 square miles and a population base of 2.1 million people. Here is a list of the government agencies and NGOs my network serves:

Simi Valley Police Department ● Simi Valley Hospital ● Ventura County Emergency Medical Services ● The Camarillo Chapter of the America Red Cross ● The Emergency Operations Center of Leisure Village Camarillo ● The public at large. The ham radio network supports among other things, hilltop ● sites equipped with pan-tilt-zoom cameras. Because these amateur radio installations are frequently sited where there is no commercial or governmental presence, these cameras can provide unique views of incidents (particularly brush fires). Most specifically we were able to stream video from the in December 2017, the in December 2018, and the Saddleridge fire in late 2019. While the video streams generated stayed on our network, we successfully crossed them over to the Internet and then to YouTube (the URLs of which provided to the public via Twitter), providing unique views of those brush fires to the public. That enabled them to get real-time views of their surrounding areas, which might have proved invaluable to making possibly life and death decisions about whether to evacuate or not. The Thomas Fire, Ventura County, CA, December 2017 – video captured from a camera on the amateur radio network, and streamed to YouTube

Our efforts in disseminating video to the public during the Thomas fire were recognized by the Ventura County Board of Supervisors in June of 2018.

The Woolsey Fire, Ventura County, CA - December 2018 -– video captured from a camera on the amateur radio network, and streamed to YouTube These networks are built on technology developed and provided by AREDN (Amateur Radio Emergency Data Network, Inc., a non-profit, 501(c)(3)) which leverages devices manufactured for the commercial Wireless ISP industry. Using the AREDN software in place of that intended by the original manufacturer enables amateurs to re-purpose these devices into the Part 97 allocation. This allows high-performance, long distance networks to be created. I am opposed to the approval of this docket. Reallocating Amateur services out of the 3.3 and 3.5 GHz sub-band will have a detrimental effect on the operation of these networks and a negative impact on the agencies being served. Respectfully submitted, Orville Beach Simi Valley, California