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[SECC] FCC COMMENTS

Subject: [SECC] FCC COMMENTS
From: na4ar@arrl.net (Paul Toth-NA4AR)
Date: Mon, 03 Sep 2001 20:35:23 -0400
One of the keys to the future of Amateur Radio is maintaining the spectrum
allocated to the Amateur Radio Service.  Let's face it, building a better,
bright Amateur Radio hobby will be very difficult without frequencies to
operate on.

The FCC has recently asked for public comments on two key rulemaking
proposals. They are  the Creation of a 60 meter HF allocation and the
reallocation of 2390 MHz - 2400 MHz from Amateur Radio to the Land-Mobile
Service for the development of G3 Cellular Services.  I urge you to file your
comments with the FCC on these two important matters today.  You may do so by
sending email to ecfs@fcc.gov.  There is a pre-defined format for submitting
comments.  I am including my submittals for reference and so you know where
this candidate for ARRL SE Division Vice Director stands on these important
issues.

73!

Paul J. Toth-NA4AR
Asst. Director-ARRL Southeastern Division
West Central Florida SKYWARN Group (WX4TBW)

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Visit My Website on the Internet
http://www.qsl.net/na4ar

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

60 METER BAND PROPOSAL

<PROCEEDING>    RM-10209
<DATE>    SEPTEMBER 1,2001
<NAME>    PAUL J. TOTH-NA4AR
<ADDRESS1>    9231 120th Street N
<ADDRESS2>
<CITY>    Seminole
<STATE>    FL
<ZIP>    33772-2643
<LAW-FIRM>    NONE
<ATTORNEY>    NONE
<DOCUMENT-TYPE>    CO
<PHONE-NUMBER>    727-742-1665
<DESCRIPTION>  Email Comment
<CONTACT-EMAIL>    na4ar@arrl.net
<TEXT>
I fully support and recommend adoption of the proposed rulemaking to crea
te a Secondary Domestic Amateur Radio Allocation between the frequencies of
5.250 MHz and 5.400 MHz inclusion.  This proposed allocation will provide the
Amateur Radio Service a badly needed and highly utilitarian portion of radio
spectrum to support short to mid-range emergency communications.

Florida's West Coast is highly susceptible to communications emergencies
caused by a host of natural and manmade events.  The threat of Tropical
Weather disturbances, tornadoes, and our designation as lightning capital of
the world has created a demonstrable need for the reliable, round the clock,
station to station communications this band can provide.  Unpredictable
propagation on the existing 40 Meter and 75 Meter Amateur Radio bands makes it

necessary to split emergency communications based on time of day.  Further,
interference from commercial broadcast stations operating on the 40 Meter
band severely limits the use of this resource, particularly during darkness
hours
in Europe.  The proposed 5.250 MHz to 5.400 MHz assignment will allow
emergency communicators to maintain constant contact to move essential Health
and Welfare Traffic when other means of communications have been disrupted.

The creation of this 60 meter band will assure Amateur Radio operators who
voluntarily support the National Weather Service SKYWARN program a reliable,
point-to-point means of communicating vital and potentially life saving
information.  I urge you to act swiftly and favorably on this proposal.

Respectfully submitted,

Paul J. Toth-NA4AR
Assistant Director - ARRL SE Division

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2390-2400 MHz REALLOCATION PROPOSAL

<PROCEEDING>  99-81
<DATE>  September 1, 2001
<NAME> Paul J. Toth-NA4AR
<ADDRESS1> 9231 120th Street N
<ADDRESS2>
<CITY> Seminole
<STATE> FL
<ZIP>  33772-2643
<LAW-FIRM> None
<ATTORNEY>None
<DOCUMENT-TYPE> CO
<PHONE-NUMBER> 727-742-1665
<DESCRIPTION>   Email Comment
<CONTACT-EMAIL> na4ar@arrl.net
<TEXT>
Once again, commercial interests have targeted the frequencies allocated
to the Amateur Radio Service to generate more revenue and profits.  I cannot
justify removing 2390-2400 MHz from the trusteeship of the Amateur Radio
community.  This spectrum represents a natural resource set aside for the
development of new technologies as well as the delivery of emergency
communications services by Amateur Radio operators.

This proposed reassignment of spectrum, allocated to the Amateur Radio
Service, will make it difficult to modernize the communications tools and
systems our licensed operators need to handle emergency and public service
traffic, as mandated by Part 97.1 of the FCC rules governing our service.
Amateur Radio has served the United States and our citizens as a proving
ground for many new communications technologies.  Erosion of our spectrum
will undermine the ability of our operators to continue such innovation.

Some would argue the proposed use of this spectrum for so-called G3
commercial cellular services is more important to the general welfare of the
American public.  Yet, time and time again, commercial cellular and PCS
services
have clearly demonstrated significant vulnerability to service interruptions
from natural and manmade events, including severe weather, aircraft disasters,

large scale fires, earthquakes and more.  The sheer weight of millions of
potential commercial users has caused these systems to collapse under their
own operating overhead.  It is the licensed and skilled operators of the
Amateur Radio Service that have time and time again, provided the needed
conduit for emergency traffic.

There exists sufficient other RF spectrum to operate G3 cellular or any other
commercial service.  I strongly urge you to maintain the existing Amateur
Radio allocation for 2390 MHz - 2400 MHz.

Respectfully submitted,

Paul J. Toth-NA4AR
Assistant Director - ARRL SE Division




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