Draft comments to FCC

This is a draft and is not an official statement from the club.

We are an amateur radio club located in Brookings, Oregon. We greatly appreciate the changes made to Part 97 by the Commission's recent Report and Order, and support the amendments discussed in the associated Further Notice of Proposed Rulemaking.

Although the problem was most significant on the HF bands, already addressed by the Report and Order, due to these bands having some of the strictest baud rate limits and generally being the most congested, replacing the baud rate limits on all amateur bands would be a substantial further improvement.

Therefore, we support the proposal to remove baud rate regulations on the 2200 meter and 630 meter bands, as well as on the VHF and UHF bands which currently have such regulations. We believe that the current bandwidth limitations on the VHF and UHF bands have been working effectively, and that there is no need to change these limits. We have no particular suggestions for bandwidth limits on the 2200 meter and 630 meter bands, as we do not have direct experience with these bands.

Overall, we support the amendments contained in the Further Notice of Proposed Rulemaking. Preventing the use of excessive bandwidth by individual operators is important on all bands, but symbol rate limits are an outdated and ineffective means to achieve this.