Please find attached comments filed just now in the above captioned proceeding. These were filed under my signature due to Chris Imlay's representation of Robert Bosch in the same proceeding. Bosch and its counsel have been cooperative with ARRL from the very outset of this proceeding, in the form of a petition for rulemaking filed in 2011. There is a good case for compatibility between short range vehicular radars and Amateur Radio at 77-81 GHz, as demonstrated by the results of an ITU study (attached as a PDF as Exhibit B) in which radio amateurs fully participated and contributed. Simply put, among those who have sought to share Amateur Radio spectrum, Bosch has done it right by approaching us early and accommodating our concerns. (That the leaders of this initiative at Bosch are all German radio amateurs does not hurt.) The same can't be said for the FCC, which, in acting on Bosch's petition, proposed rules well beyond the scope of what was asked for, and indicated it was considering suspending Amateur Radio in the 77-81 GHz band. In doing so, the Commission erroneously asserted a lack of characteristics for amateur systems in this band and a lack of studies on the issue. We have enlightened them. Chris has advised that reply comments will likely be necessary in this proceeding, as a filing is anticipated by a consortium of US automotive interests, with which Bosch has disassociated itself, suggesting at least the relocation, if not outright removal of the 4 mm band from the Amateur Radio Service. We will of course vigorously oppose this. What is not an option for us is opposing vehicular radar in this band at all. The proponents simply have too strong of a compatibility case, and the international momentum in standardizing around this frequency band has been well established for years. While it is necessary to file these comments under my signature, Chris prepared a first draft for my consideration on Monday. I worked on this draft as able while otherwise fully engaged in the WRC-15 Conference Preparatory Meeting in Geneva, and sought some guidance from Dave and Kay on Thursday. Dave and I edited the draft a bit more before sending it to the Executive Committee on Friday. I thank the entire Executive Committee for its approval to file, particularly Tom Frenaye for some well taken suggestions. 73 de Brennan N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079