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  Ham Radio Spread Spectrum Page, Part 1
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Back in 1998, the RF world got very excited about the possibilities of using spread spectrum for ham radio. Listed below is some historical information related to this movement -- FCC's initial proposed regulations that would make this possible, and comments from the community about these proposed regulations.


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Contents posted 5/30/98

 
FCC's First NII/SuperNet Press Release - 4/25/96


COMMISSION PROPOSES TO MAKE SPECTRUM AVAILABLE FOR USE BY NEW UNLICENSED EQUIPMENT; NII/SUPERNET DEVICES WOULD FACILITATE INTERCONNECTION TO THE NII


ET Docket No. 96-102 (Report No. DC 96-36, Action in Docket Case)

The Commission has adopted a Notice of Proposed Rule Making to make available 350 megahertz of spectrum at 5.15 - 5.35 GHz and 5.725 - 5.875 GHz for use by a new category of unlicensed equipment called NII/SUPERNet devices.

Action by the Commission April 25, 1996, by NPRM (FCC 96-193).

News Media contact: Rochelle Cohen at (202) 418- 0500. Office of Engineering and Technology contacts: Tom Derenge at (202) 418-2451 and Fred Thomas at (202) 418- 2449. [Internet file name: nret6007.txt]




 
The ARRL's SS Petition to the FCC


FOR IMMEDIATE RELEASE


Source: TAPR
posted April 3, 1996, El Granada, CA.

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of                   )
                                   )
Amendment of Part 97 of the        )    RM-8737
Commission's Rules Governing       )
the Amateur Radio Service to       )
Facilitate Spread Spectrum         )
Communications                     )


To: The Commission


PETITION FOR RULE MAKING
The American Radio Relay
League, Incorpated

Christopher D Imlay
BOOTH FRERET & IMLAY, P.C.
1233 20th Street. N.W.
Suite 204
Washington, D.C. 20036
(202) 296-9100


December 12, 1995


 
SUMMARY

The American Radio Relay League, Incorporated (the League), the national association of amateur radio operators in the United States, respectfully requests that the Commission issue a Notice of Proposed Rule Making at an early date, looking toward the amendment of the Commission's Rules and Regulations regarding the Amateur Radio Service, in order to facilitate, to a greater extent than is done by the present rules, the contributions of the Amateur Service to the development of spread-spectrum communications.

The petition proposes (1) to permit brief test transmissions using SS emissions; (2) to permit international SS communications between United States' amateurs and amateurs in countries that permit amateur use of those emissions; (3) deletion of unnecessary restrictions on spreading codes and repetitive definitions of "harmful interference," and (4) to provide for automatic power control to insure use of minimum necessary power to conduct SS communications.

The League urges that the Commission propose and ultimately adopt these proposed rule changes. These are, in the League's opinion, the minimum changes necessary in order to foster SS experimentation in the Amateur Service, while at the same time preserving those necessary existing protections against those who might conceivably exploit the amateur bands for non-amateur purposes. Spread-spectrum techniques are in regular use in Part 15 applications, but have not been given the attention deserved in other communications systems, such as the land mobile services, as a means of increasing the efficiency of use of crowded shared bands. The Amateur Service regularly functions as a provider of refinements of new technologies and provides means of deployment of those technologies on a cost-effective basis. In order to permit the degree of flexibility in use of this technology in particular, the Commission should provide the necessary regulatory environment to do so. These rule changes represent a conservative, and yet functional approach to reform of SS rules.



 
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554


In the Matter of                   )
                                   )
Amendment of Part 97 of the        )    RM - 8737
Commission's Rules Governing       )
the Amateur Radio Service to       )
Facilitate Spread Spectrum         )
Communications                     )

To: The Commission

PETITION FOR RULE MAKING


The American Radio Relay League, Incorporated (the League), the national association of amateur radio operators in the United States, by counsel and pursuant to Section 1.401 of the Commission's Rules (47 C.Z.R. § 1.401) hereby respectfully requests that the commission issue a Notice of Proposed Rule Making at an early date, looking toward the amendment of the commissions Rules and Regulations regarding the Amateur Radio Service as set forth in the attached Appendix. The purpose of the proposed rule changes is to Facilitate, to a greater extent than is done by the present rules, the contributions of the Amateur Service to the development of spread-spectrum communications. As good cause for the proposed changes, the League states as follows:

 
I. Introduction


     1. Use of spread spectrum communications in the Amateur Service is relatively new. It was first authorized by the Commission by Report and Orders 58 RR 2d 328 (1985). The Commission authorized spread-spectrum communications in the Amateur Service in order to permit amateurs to develop, test and operate low-cost spread spectrum systems, thus to stimulate technical advances in radio technology, consistent with the basis and purpose of the Amateur Service (47 C.F.R. Section 97.1). The Specific Benefits to the public to be gained from amateur use of spread-spectrum (SS) communications as determined by the Commission included the following: Reduced power density and concomitant reduction of interference to narrow band communication systems; 2) Significant improvements in communication under conditions with poor signal-to-interference ratio; 3) Improved communication performance in selective fading and multipath environments; and 4) Ability to accommodate more communication channels functioning simultaneously in the same spectrum than is possible uising frequency division multiple access exclusively.

     2. Since the time SS communications were first authorized in the Amateur Service in mid-1985, there have been some experimental amateur operations using SS techniques, but its use has not been widespread. The League believes that one significant reason for this reduced level of experimentation is due to limitations in the rules governing SS communications in the Amateur Service. The revised rules in the proposed appendix are intended to provide increased flexibility in the use of this mode, to encourage amateurs to experiment and use SS communications, to develop new techniques for increased spectrum efficiency using this mode, and to improve compatibility with narrow-band modes.

 
II. Spread-Spectrum Communications Rules Should Be Flexible


     3. Commission policy is and has been to encourage experimentation and to provide a Regulatory environment for the Amateur Service which encourages modern techniques, technology and uses of amateur radio. (1)

     4. SS communications are well-suited to the Amateur Service, especially in shared bands. Amateur experimentation in SS communications, in view of the apparent compatibility of SS communications and narrow-band modes commonly used in the Amateur Service, is of potential benefit in terms of spectrum efficiency. This was noted by the Commission in Docket 81-414. There were some concerns expressed by commenters in that proceeding. These initial objections fell into three categories: 1) concern about intraservice interference; 2) concern about inter-service interference; and 3) concern about monitoring issues, and the ability to protect the Amateur Service against interlopers. These issues are not of practical concern now, and they are not anticipated to become significant under the proposed revised SS rules. There have not been, in the League's experience, any established instances of actual interference to narrow-band amateur communications from SS communications. Tests conducted by amateur groups have established that certain configurations of SS operations can, due to increased in-band noise, trigger amateur repeater inputs (if those repeaters are carrier-operated), but that potential interaction is easily avoided by selection of spread-spectrum parameters. 58 RR 2d at 329, and authorities cited therein at footnotes 4-9. There are potential interactions between SS and narrow-band modes in certain circumstances, depending on processing gain and the randomness of spreading codes, however.(2) There have been no reported instances whatsoever, in the League's experience, of interference to other radio services from amateur SS communications. (3)

     5. Notwithstanding the Commission's general support of Amateur SS communications, as stated in the Report and Order in Docket 81-414, the rules adopted in that proceeding were quite circumscribed. The limitations were principally aimed at facilitating station identification by other amateur stations, and limiting spreading sequences by specifying a limited number of linear feedback shift registers. SS communications are currently authorized only for domestic communications, (4) and the frequencies available for SS communications were in the bands above 225 MHz. (5) They remain as originally enacted, to the present date.

     6. The Commission has generously granted and extended special Temporary Authority for SS experimentation, however. The experiences of amateurs pursuant to these past Special Temporary Authorities indicate that the present rules include certain significant limiting factors which could be liberalized without detracting at all from other, narrow-band amateur communications.

It is the League's belief, and apparently that of Commission staff as well, that experimentation in the Amateur Service, and particularly further SS experimentation, should be accommodated by increased flexibility in the rules, and not by reliance on STAs. According to a report by Mr. Buaas, K6KGS, holder of a Commission STA, which report was filed with the Chief, Private Radio Bureau in March of 1993;

Our work to date has focused on determining: a) what performance can be achieved utilizing several techniques in spectra already occupied by narrowband emitters, b) what level of interference results to existing users; c) what impact existing usage has on degrading SS performance; d) how much usage can be pressed into a given spectrum using CDMA; and e) what proposals we might make to change the Rules and thereby further encourage experimentation without the need for this STA.
*****
Several of our experiments have been particularly successful. We started with designs which would meet the limits set forth for Part 15 systems, and worked up from there. One hybrid design (DS coupled with slow FH) was particularly effective in minimizing interference...
*****
It is now clear to us that use of SS in the Amateur Service has been severely limited by the design restrictions in the Rules...
The League agrees that it is useful to relax somewhat the rules contained in Sections 97.305(b) and 97.311 governing amateur SS operation, to permit greater operating flexibility and the development of SS communications as a practical communications mode in the Amateur Service without adverse interaction with other modes.  


III. Proposed Rule Changes


     7. The first change proposed by the League is to permit brief test transmissions of SS emissions, as is permitted in Section 97.305(b) for other types of emissions, except that test transmissions using SS emissions would be limited to those frequency bands where SS emissions are authorized generally, as is the case with pulse modulation transmissions.

     8. Second, it is proposed to amend Section 97.311(a) of the Rules to modify the requirement that SS communications be limited only to domestic communications. Amateur communications have always been permitted internationally between countries that permit it, and SS emissions should not be prohibited between United states amateurs and amateurs in countries where those emissions are permitted as well.

     9. The reference in § 97.311(b) to unintentional triggering of repeater inputs, a reference in the rules governing SS communications since 1984, is unnecessary because it is merely repetitive of existing definitions of "harmful interference" in the ITU Radio Regulations and in commission definitions and interpretations generally. Harmful interference for non-safety-of-life radio services does not include squelch breaks and repeater activation. (6)

     l0. It is proposed to delete Subsections 97.311(c) and (d), in order to permit hybrid frequency-hopping (FH) and direct-sequence (DS) emissions, and spreading codes not currently permitted by the rules, but which are desirable. The current rules permit only two techniques, neither of which is optimal for sharing. There are newer codes, including those used by Part 15 device manufacturers, which have been optimized to avoid interaction with shared users. These could be used if the rules were more flexible . Elimination of the rule limiting amateurs to specific spreading sequences is necessary to facilitate experimentation. The proposed rule changes would delete the limitations on SS configurations contained in the present Section 97.311(d). This modification is necessary to provide sufficient flexibility to experiment with other spreading sequences, tap settings and frequency hopping techniques. Nor will the changes create any difficulty with station identification, (7) or with protection of the Amateur Service from commercial or unlicensed encroachment. The narrow-band identification requirement is sufficient, together with the documentation requirement in Section 97.311(e) of the Rules, to permit the degree of monitoring of SS activities of amateurs necessary to protect the Service. As the Commission appropriately recognized in addressing monitorability of unspecified digital codes in the Amateur Service, quoted in the Report and Order in Docket 81-414:

In balancing our objectives of encouraging new technologies against ensuring our enforcement capability, it must be recognized that there is an incompatibility between authorizing experimentation with "exotic" technologies and the employment of channel monitoring as an enforcement tool. Our ability to verify that the content of messages complies with our rule requirements will be hindered by the broad relaxation of regulatory constraints that we are ordering in this proceeding. However, the Commission agrees...that special provisions we are including in the final rules, as well as existing provisions that identification be made in plain English or the international Morse code, should, when combined with the zealous effort of the amateur community to protect their allocated frequency bands, provide adequate protection against unauthorized operation in the service.      58 RX 2d at 330.
     11. Finally, the proposed appendix would amend Section 97.311(g), to provide for automatic transmitter power control which would limit output power to that which is required for the communication, when more than one watt of transmitter power is used. This is a simple matter to accomplish technically, and it will insure compliance with Section 97.313(a) of the rules, which requires the use of minimum transmitter power. It will also minimize any potential for interference to other amateur stations and insure maximum spectrum efficiency.  


IV. Conclusion


     12. The League urges that the Commission propose and ultimately adopt these proposed rule changes, which are in the League's opinion the minimum necessary changes in order to foster SS experimentation in the Amateur Service, while at the same time preserving those necessary existing protections against those who might conceivably exploit the amateur bands for non-amateur purposes. Spread-spectrum techniques are in regular use in Part 15 applications, but have not been given the attention deserved in other communications systems, such as the land mobile services, as a means of increasing the efficiency of use of crowded shared bands. The Amateur Service regularly functions as a provider of refinements of new technologies and provides means of deployment of those technologies on a cost-effective basis. In order to permit the degree of flexibility in use of this technology in particular, the Commission should provide the necessary regulatory environment to do so. These rule changes were developed by a dedicated committee of League staff and volunteers familiar with the technology, and represent a conservative, and yet functional approach to reform of SS rules.

     Therefore, the foregoing considered, the American Radio Relay League, Incorporated respectfully requests that the Commission issue a notice of proposes rule making to implement the rules contained in the attached Appendix, and adopt the same after an opportunity for notice and public comment.

                              Respectfully submitted,

                              THE AMERICAN RADIO RELAY
                              LEAGUE, INCORPORATED
			225 Main Street
			Newington, CT  06111

                              By: Christopher D. Imlay
                              Its General Counsel


BOOTH FRERET & IMLAY, P.C.
1233 20th Street, N.W., Suite 204
Washington, Z.C. 20036
(202) 296-9100


December 12, l995


 
APPENDIX

Section 97.305(b) is amended to read as follows:
(b) A station may transmit a test emission on any frequency authorized to the control operator for brief periods for experimental purposes, except that no pulse or SS modulation emission may be transmitted on any frequency where pulse or SS is not specifically authorized.
Section 97.311(a) is amended to read as follows:
(a) SS emission transmissions by an amateur station are authorized only for communications between points within areas where the amateur service is regulated by the FCC and between an area where the amateur service is regulated by the FCC and an amateur station in another country which permits SS communications for its amateur licensees.
Section 97.311(b) is amended by deleting the last sentence thereof.

Section 97.311(c) and (d) are deleted in their entirety.

Section 97.311(g) is amended to read as follows:
(g) The transmitter power output must not exceed 100 W under any circumstances. If more than 1 W is used, automatic transmitter control shall limit output power to that which is required for the communication. This shall be determined by use of the ratio, measured at the receiver, of the received energy per user data bit (Eb) to the sum of the received power spectral densities of noise (No) and co-channel interference (Io). Average transmitter power over 1 W shall be automatically adjusted to maintain an Eb/(No+Io) ratio of no more than 23 db at the intended receiver .



Footnotes

 
1. See the Notice of Proposed Rule Making, 3 FCC Rcd. 2076 (1988).


 
2. These potential interactions are no different than those involving other mode compatibility issues in the Amateur Service except that current rules require protection by amateurs using SS emissions of users of other modes. 47 C.F.R. § 97.311(b). Conflicts are avoided by informal band planning and normal sharing considerations which work well in the crowded amateur bands. Avoidance of weak-signal subbands by SS operations is a reasonable preventative step.


 
3. In Docket 81-414, the Commission addressed concern by the National Association of Broadcasters (NAB) about interference to television channel 2 (54-60 Mhz) reception from amateur SS operation at 50-5Z MHz as follows:
...NAB's principal concern was that uncontrolled amateur transmissions might fall outside the allocated band into channel 2. The Commission believes that NAB's concerns are not well founded. First, rather simple transmitter output filters can be used by amateur licensees to prevent positively out of band emissions. Second, licensees in the Amateur Service have had no significant history of operating outside the allocated bands...In other frequency bands where the Amateur Radio Service has successfully shared allocations with different services, we expect no worsening of interference since the power density from currently existing narrow band transmissions having the same total effective radiated power. 58 RR 2d at 330.
The Commission also noted that the NAB's concerns were moot, since the authorization for SS communications extended only to bands above 225 MHz. 47 C.F.R. § 97.305.


 
4. In the Commission's rewrite of the Amateur Rules, commenced in 1988, the Commission deleted from the rules the reference to international use of SS communications because no international agreements had been enacted to facilitate such. The Commission indicated in Docket 88-139 a willingness to consider international use of SS communications if there were international agreements enacted to permit such. No specific agreements have been enacted on that subject to date.


 
5. The original proposal of the Commission in Docket 81-414 was to permit SS communications only in the 50, 144 and 220 MHz bands. Those bands were not authorized by the Report and Order because of certain comments which noted the limited size of the allocations and required limitations in bandwidth. Therefore, the Commission authorized operation only in the UHF and SHF bands.


 
6. See, the ITU Radio Regulations,at Article 1, in which "Harmful Interference" is defined as interference which endangers the functioning of a radionavigation service or of other safety services or seriously degrades, obstructs or repeatedly interrupts a radiocommunication service operating in accordance with these regulations. A virtually identical definition appears at 47 C.F.R. § 97.3(a)(22). Past Commission interpretations of interference to amateur repeaters have consistently applied the definition of "harmful interference" to exclude mere squelch breaks. And, the Commission held in an Order dismissing RM-7673 (DA-92-155, released February 10, 1992) there are "many other methods" available to prevent unintended triggering of repeaters besides restricting SS emissions.


 
7. It is not proposed to modify the station identification provisions in Section 97.119(b)(5) which contains the CW identification requirement for SS communications. The League questions the practicality of the requirement, in view of the variability of frequency on which the narrowband CW identification requirement may be located. Nonetheless, it is not proposed to delete the requirement at this time.




 
TAPR's COMMENTS

TAPR Comments on the League's SS Petition

Editor's note: Spread spectrum communications is a communications technology invented during World War II and used extensively by military agencies. There are two forms of spread spectrum communications in common use: one is frequency hopping, where a transmitter and receiver rapidly hop from one frequency to another in a pre-determined sequence. The other is direct sequence (or sometimes called code division multiple access) spread spectrum. In DS, the radio signal is spread very wide using a predetermined spreading sequence. A receiver must know the spread sequence to demodulate the radio signal. We will be featuring several articles, including a tutorial, on spread spectrum communications during the coming month or two.

This article presents the comments filed by the Tucson Amateur Packet Radio group in response to new spread spectrum rules proposed by the American Radio Relay League, Inc.


Below are the comments that TAPR filed on the League's Spread Spectrum Petition for Rulemaking.

It is still not too late to file any comments that you have on this matter with the FCC. An explanation of the procedure of doing this appears in the League's "FCC Rule Book" publication.

TAPR will be following this matter thru the entire rulemaking process at the Commission. The next step will be to file reply comments which are due at the Commission on March 12th.


Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of                        )
                                        )
Amendment of Part 97 of the             )         RM-8737
Commissions Rules Governing             )
the Amateur Radio Service to            )
Facilitate Spread Spectrum              )
Communications                          )

To:  The  Commission


COMMENTS OF
TUCSON AMATEUR PACKET RADIO CORPORATION

The Tucson Amateur Packet Radio Corporation ("TAPR") submits these comments in response to the above-referenced petition for rule making (the "Petition") filed by the American Radio Relay League, Incorporated ("ARRL").


BACKGROUND AND STATEMENT OF INTEREST

TAPR is a non-profit (501(c)(3)) scientific and educational organization with more than 2,500 members worldwide. It is chartered to engage in three principal activities: scientific testing and research into the development and improvement of technological systems for use in the amateur radio service including, but not limited to, digital packet radio communications; research and testing of systems, hardware, and software for packet radio local area networks and computer network systems; and disseminating to the public the information obtained as a result of such research and testing.

TAPR was founded in 1982 as a national organization with interests in the areas of packet and digital communications. It grew out of a 1981 effort to design a packet radio Terminal Node Controller, or "TNC," that would be available to amateurs at a modest cost. From these initial designs emerged what is now the de facto standard in amateur and many commercial packet radio operations.

Today, TAPR continues as an international, membership-supported research and development organization for the amateur radio community. TAPR continues to develop new communications technology, provide kits for the amateur community, and promote the advancement of the amateur art through publications, meetings, and communications standards. TAPR also maintains a web site (http://www.tapr.org), which includes a page specifically addressing current amateur spread spectrum issues ( http://www.tapr.org/spread_spectrum.html).


DISCUSSION

TAPR generally supports the recommendations made by the ARRL in its Petition. Spread Spectrum ("SS") technology has not made great advances in the amateur radio service since it was first permitted in 1985, in part due to the fact that, by today's standards, the Part 97 regulations on amateur spread spectrum are extremely restrictive. In particular, the small number of fixed spreading codes permitted under Section 97.311(d)(1) inhibits the use and development of SS by amateur radio stations. TAPR believes that it is in the public interest, and in the interest of the amateur radio service, to change the rules for SS in order to accelerate the adoption of SS by the general amateur community.

TAPR also supports many of the specific recommendations made by the ARRL.

First, TAPR supports the ARRL's request to modify Part 97.311(b) as it pertains to the unintentional triggering of repeater inputs. This section is redundant with other parts of the Commission's rules and, therefore, is unnecessary.

Second, TAPR supports the ARRL's request to delete sections 97.311(c) and (d), in order to permit SS emissions and spreading codes that are not currently authorized. Elimination of the rule that dictates specific spreading codes is necessary to facilitate further experimentation and to match the provisions allowed under an existing amateur service SS STA, discussed below. In addition, it would facilitate the use and adoption by amateur radio operators of Part 15 SS equipment and hardware.

Third, TAPR supports the ARRL's proposed change to 97.311(g), which would provide for automatic transmitter power control to limit the output power of an SS station to that which is required for communication, when more than one watt of output power is used. TAPR, however, differs with the ARRL as to just how simple this requirement would be to implement technically. While TAPR agrees that technically it is simple to control the output power of a transmitter, it is quite another matter to make this control automatic and foolproof. If the Commission decides to proceed with this particular change to the rules, it should phase the change in over some reasonable period of time, in order to give the amateur community the opportunity to develop and deploy SS equipment that properly can meet this requirement.

While, as noted above, TAPR agrees with many of the ARRL's recommendations, it disagrees with a few of the proposals contained in the Petition.

In particular, TAPR differs with the ARRL with respect to the question of which frequencies should be authorized for SS emissions. In the Petition, the ARRL proposes that brief test transmissions of SS emissions be permitted only on those frequency bands in which SS emissions currently are authorized. TAPR believes that SS emissions should be allowed on all frequency bands covered by the SS STA currently held by Mr. Robert Buaas K6KGS (6m and 2m, in addition to the frequency bands currently authorized by Part 97). In addition, the Commission should allow SS emissions in the 219-210 MHz band, which was authorized for use by the amateur radio service after the Buaas SS STA was originally granted in 1992. Finally, the Commission should not impose any restriction on the length of time SS emissions are transmitted. Ample time already has been provided for the experimental phase of SS usage in the amateur service (five years of experimentation under the 1980 AMRAD STA and ten years under the current Part 97 rules), and it is now time to allow SS use without restriction.

TAPR also differs with the ARRL as to how station identification and documentation should be handled under a revised set of rules. The ARRL in its petition did not ask the Commission to delete sections 97.311(e) and 97.119(b)(5) of the rules, even though it questioned the practicality of the requirements set forth in these sections. TAPR, in contrast, recommends that the Commission delete these subsections of the rules. The interference and harm to the band in which an SS station is operating that would be caused by a requirement to use a CW identification outweighs the benefits that would accrue for monitoring purposes from the use of the ID.

As a result, the amateur radio community should be permitted to develop an approach for handling the necessary functions of monitoring and identification. TAPR already is working on possible resolutions to this problem and in the near future will be in a position to make a proposal to the Commission on this matter.


CONCLUSION

SS technology can provide many useful benefits to the amateur radio community if its use becomes more widespread and mainstream. In order to accomplish this, however, certain changes must be made to the Commission's rules governing the use of SS in the amateur radio service. By making these changes, the Commission will create a regulatory environment that will give members of the amateur radio service enough flexibility to develop innovative equipment and hardware employing SS technology.

For these reasons, TAPR urges the Commission promptly to issue a notice of proposed rule making to facilitate spread spectrum communications in the amateur radio service, as proposed in the Petition and as modified herein.

Respectfully submitted,
THE TUCSON AMATEUR PACKET RADIO CORPORATION

By:
Dewayne Hendricks
Tucson Amateur Packet Radio Corporation
8987-309 E Tanque Verde Rd #337
Tucson, Arizona 85749-9399
(817) 383-0000


~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Dewayne Hendricks, WA8DZP ! CIS: 75210,10 AppleLink: D6547
Warp Speed Imagineering   ! Internet: dewayne@warpspeed.com
43730 Vista Del Mar       ! Packet Radio: WA8DZP @ K3MC.#NOCAL.CA.USA.NOAM
Fremont, CA 94539-3204    ! AOL: HENDRICKS
Fax: (510) 770-9854       ! WWW: http://www.warpspeed.com/
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~



 
OTHER COMMENTS






Reply Comments to RM-8737
 

(Limited set of comments. If you have filed comments, please send
TAPR@TAPR.ORG a copy and TAPR will add them to their SS Page.)





Page note: SSS Online gratefully acknowledges the source of the above information to be TAPR -- we thank them for this information and for their ongoing work in support of Ham radio!



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