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[802SEC] ***SEC Five Day Review*** RR-TAG Comments on FCC RM-11325, Amendment of Amateur Service Rules

Dear SEC Members,
Attached are comments that the RR-TAG proposes to file with the FCC. The
subject of RM-11325 is "Amendment of the Amateur Service Rules to
Facilitate Use of Spread Spectrum Communications Technology". The ARRL
is requesting that the FCC remove the require for ATPC. ATPC is meant to
insure that only the minimum required power to successfully communicate
is used by amateur operators. While there are several frequency bands
that the rule change would impact the one of greatest interest currently
is the 2.4 GHz frequency band. It is feasible that, without the ATPC
requirement, an amateur operator could radiate as much as 4 kW in that
band. The amateurs make the argument that ATPC is too complicated to
implement. That seems to contradict the widespread use of ATPC by a
number of technologies. Additionally it was the amateurs that originally
requested to use ATPC. The potential impact on unlicensed technologies
in the 2.4 GHz band could be severe. The RR-TAG believes that ATPC can
be implemented without imposing undue hardship on the amateur service.

The RR-TAG developed these comments during its May interim in
Jacksonville. A quorum was present and these comments were approved by a
vote of 9 Yes, 0 No, 0 Abstain.
The comment period for RM-11325 closes 30 May. I propose that the EC
review begins today (24 May) and closes at midnight CDT 29 May.
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