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Don’t wait! Initial comment period for ET 15-99 ends August 31

– Posted in: 630 Meter General Topics, 630 Meters

Its seems like an eternity since comments began posting on the NPRM to create a 630-meter band under Part-97, and almost equally long since the comment period formally opened with the publication of the proceeding in the Federal Register almost 60 days ago.

Its particularly important for stations that are actually operating on 630-meters now or have done so in the past to post on-point comments, hopefully supporting the implementation of the band.  It does not have to be a complicated comment full of numbers, measurements and calculations.  It can be simply identifying yourself as a ham and Part-5 station for X number of years or months and specifying your call signs along with a statement that you support the creation and implementation of a 630-meter amateur band under Part-97.  If you do choose to expand your comments,  its important not to conjecture unless you have data to back up those ideas and tone is very important as you are addressing people of political clout that will decide if and how this implementation will occur.  You should probably also state that after X-hours/days/months/years of operating at X-ERP, there have been no interference reports or problems associated with your station.  Short and simple is the best policy, when in doubt.

If you are a ham spectator, you can help also and similar rules apply to your comments.  Its important to keep emotion out of your comments as personal feelings are often disregarded and hurt credibility.  Stick to the facts and don’t try to oversell your position.  If you have never actually been a station operating on the band (transmitting and receiving), you will likely have little input to make other than offering support unless you have been involved with the core group in making measurements and analysing data.   There are a couple of ham comments posted that I expect will be disregarded very quickly due to tone and content.  Note that there will be no repeaters on 630-meters.  Being informed about the basic nature of 630-meters in addition to the NPRM is important if you are going to post a comment that attempts to do more than show support for the process.  Credibility is very important!

It is likely that the opposition will wait until the last minute to post their comments and the reply comment period will last 30-days, starting September 1 and ending September 30 (See this downtime schedule during that time frame).

To post a comment, I recommend writing it first in your favorite word processor program and render it as a PDF after you have spell and grammar checked the content.  Its probably best that you sleep on what you wrote for a night or so before posting, unless you are coming up on the deadline, to make sure your comment is appropriate.

Click here to access the FCC Office of Engineering and Technology submission page.

filing

In the top box, Proceeding Number, enter 15-99

In contact info, Enter your Name and e-mail address.  You can leave law firm/attorney/author blank.

In details, the filing type drop down box should be COMMENT.  If not, drop the box down and select Comment.  All other fields can be left blank, including the Exparte presentation check box.

In address, make sure the Filer radio button is selected unless otherwise specified, and select the address type (US or International).  Enter your full address.

In documents, select the browse button and navigate to the comment file that you created.  Select that file and the file name should be listed next to the Browse button once you click on it.  A custom description is not required.

Select continue and I believe that you will be asked to confirm your information before submission – Don’t quote me on that as its been a few months since I filed, but it should be obvious.  If you have problems, send me an e-mail on the contacts page and I will reply quickly most of the time.

I believe that the same process will be used for the reply comments and those are equally important and much more complicated as issues have to be addressed carefully, avoiding personal attacks and emotion.  It really has to be like a dry legal brief.

If you have any questions, please send me a message on the Contact page.