[ARRL-ODV:9779] Comments as-filed, Migratory Bird NOI, Docket 03-187

Greetings. Today, just now, I filed per EC approval and following some good edits from Mr. Sumner and other EC members, comments on the FCC's NOI on the effects of towers on migratory birds. This, in essence, called for scientific data, which we don't have, on the subject of bird kills from (tall) towers. Our expert on this, now that our good friend Jim Maxwell is gone (he did extensive and thorough research on the effect of towers on migratory birds) is Jay Bellows, who litigated successfully a tower case involving allegations of danger of the tower to birds. The EC only wanted to file reply comments, and it worked out well, since we have made an argument that the available studies indicate that towers less than 300-400 feet do not constitute a bird problem. If FCC will conclude this, we can use their determination in antenna cases where the issue arises. Here are the reply comments. 73, Chris W3KD
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W3KD@aol.com