ODV, Later today the opportunity for public comment on the FCC symbol rate draft Report/Notice will close and all contact with the FCC staff will become prohibited. (This period is known as the “sunshine period” even though it actually is a period of communication black-out, or darkness, the opposite of “sunshine.”) As of this morning only a single comment has been filed addressing the FCC’s draft. Most of this filing discusses subjects not directly relevant, but a short expression of support is made for “replacing the old symbol rate constraint with the reasonable bandwidth limitation as proposed.” It is good practice for supporters to file at least a short statement re-affirming their continued support, even without any expressed opposition. I also became aware that the 219-220 MHz segment of the 1.25 meter band had not been addressed in the draft Further Notice. Although this portion of the 1.25 meter band has never been subject to a symbol rate limit, it is subject to a 100 kHz bandwidth limit. Bandwidth limits for the other VHF bands, including 222-225 MHz, are subject to the Further Notice so with a brief statement of continued support I suggested that the bandwidth issue also be included for the 219-220 MHz segment so that if changes are made this segment could be included at the same time, rather than being left “an orphan”. [ The Administrative Procedures Act requires notice and public comment before amending rules, so the different bands have to be included in the Further Notice if a change is to be made at the next step. ] Recently there have been expressions of renewed interest in using the 219-220 MHz segment for digital links. One last note: it is not unusual for the Commissioners to adopt a non-controversial item by unanimous consent a day or two before the public meeting so that more time can be spent on other issues during the meeting. I would not be totally surprised if this item is adopted a day or two before the scheduled Nov. 15 meeting. If that happens there will be a public notice announcing its adoption and removal from the meeting agenda, and I will let you know. A copy of this morning’s filing is attached. Contact me with any questions. Regards, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.
