1. See Amendment of the Amateur Service Rules to Provide For Greater Use of Spread Spectrum Communication Technologies, Notice of Proposed Rule Making, WT Docket No. 97-12, 12 FCC Rcd 2591 (1997) (Notice).
2. See FCC Encourages Amateur Radio Experimentation, FCC News Release, March 9, 1981. See also 47 C.F.R. § 1.925.
3. See The ARRL Handbook for Radio Amateurs, 1992, pp. 21-7 through 21-17.
4. See Amendment of Parts 2 and 97 of the Commission's Rules and Regulations to authorize spread spectrum techniques in the Amateur Radio Service, Report and Order GEN. Docket No. 81-414, 99 FCC 2d 1432 (1985). The text of the Report and Order was printed at 50 Fed. Reg. 23423 (1985).
5. See ARRL Spread Spectrum Sourcebook, 1991, p. 8-64 and Chapter 9.
6. See 47 C.F.R. § 97.305(c), 97.311(a).
7. See 47 C.F.R. § 97.311(c).
8. See 47 C.F.R. § 97.311(a), (e).
9. See 47 C.F.R. § 97.311(b).
10. A list of parties filing comments and reply comments is attached hereto as Appendix A.
11. Notice, 12 FCC Rcd at 2591.
12. 47 C.F.R. § 97.311 (c) and (d).
13. Notice, 12 FCC Rcd at 2595.
14. Id. at 2592.
15. Id.
16. See 47 C.F.R. § 97.1.
17. William A. Tynan Comments at 5.
18. ARRL Reply Comments at 15.
19. Metricom Inc. Reply Comments at 4.
20. Philip R. Karn, Jr. (Karn) Comments at 1.
21. The Part 15 Coalition Comments at 1, 2.
22. See Karn Comments at 1; Lyle V. Johnson Comments at 1; ARRL Comments at 3.
23. ARRL Reply Comments at 15; Karn Comments at 1.
24. See 47 C.F.R. § 15.5(b).
25. See 47 C.F.R. § 97.113(a) and (b).
26. See 47 C.F.R. § 97.311(g).
27. Notice, 12 FCC Rcd at 2595.
28. Id. at 2593-2595.
29. Lyle V. Johnson Comments at 5; William A. Tynan Comments at 6.
30. Robert J. Carpenter Comments at 1.
31. Tucson Amateur Packet Radio Corporation (TAPR) Comments at 3.
32. Karn Comments at 4.
33. TAPR Comments at 3; Karn Comments at 3. Stations engaging in EME communication that are transmitting any emission other than SS can transmit with up to 1500 W Peak Envelope Power and unlimited antenna gain.
34. Id.
35. ARRL Reply Comments at 5.
36. The Central States VHF Society Comments at 6.
37. Mixed-mode frequency bands are frequency bands where different emission types, such as CW, phone, RTTY, data, and SS are transmitted. All amateur service frequency bands are mixed-mode frequency bands. See 47 C.F.R. § 97.305(c).
38. ARRL Reply Comments at 5.
39. Id. at 10.
40. Robert J. Carpenter Comments at 2; ARRL Reply Comments at 12.
41. See 47 C.F.R. § 97.311(g).
42. The power authorized Part 15 devices is 1 watt with 6 dBi antenna gain.
43. Notice, 12 FCC Rcd at 2594-2595.
44. Id. at 2593-2594.
45. Id.
46. Karn Comments at 4.
47. The "near-far problem" refers to a situation in which the use of a particular frequency segment or channel near the transmitting station is different than the use of the same frequency segment or channel at a location far from the transmitting station.
48. Karn Comments at 5.
49. Id.
50. Id.
51. ARRL Reply Comments at 14.
52. Lyle Johnson Comments at 4-5.
53. Id. at 5.
54. TAPR Comments at 4; Manager of the National Communications System Comments at 2.
55. ARRL Reply Comments at 10.
56. CW is defined as an International Morse code telegraphy emission having certain specified designators. See 47 C.F.R. § 97.3(c).
57. TAPR Comments at 4, 5.
58. Id. at 5.
59. Manager of the National Communications System Comments at 2, 3.
60. Id.
61. ARRL Reply Comment at 10.
62. See Amendment of Parts 2 and 97 of the Commission's Rules and Regulations to authorize Spread Spectrum Techniques in the Amateur Radio Service, Report and Order, GEN. Docket No. 81-414, paras. 7, 10.
63. See The Connecticut Power and Light Company, et al., v. Nuclear Regulatory Commission, 673 F. 2d 525 (1982). See also Amendment of Part 97 of the Commission's Rules Concerning Frequency Coordination of Repeaters in the Amateur Radio Service, Memorandum Opinion and Order, PR Docket No. 85-22, 2 FCC Rcd 243 (1986).
64. Section 97.119(b)(5) requires that the CW or phone emission be transmitted on a narrow bandwidth frequency segment. A "narrow bandwidth frequency segment," however, is undefined. Likewise, it is not clear what the phrase "a conventional CW or phone emission receiver" means in terms of amateur service equipment.
65. The Central States VHF Society Comments at 7, 8; William A. Tynan Comments at 8. See also Robert J. Carpenter Comments at 2.
66. ARRL Reply Comments at 13.
67. Id.
68. Additionally, we note that the amateur service rules do not quantitatively specify the bandwidth of an AM voice signal. See 47 C.F.R. § 97.307(f)(2).
69. The Central States VHF Society Comments at 7, 8; William A. Tynan Comments at 8.
70. Robert J. Carpenter Comments at 2.
71. AMSAT Comments at 4.
72. Raphael Soifer Comments at 5.
73. The Southern California Repeater and Remote Base Association Comments at 8.
74. See The 220 MHz Spectrum Management Association of Southern California Comments at 11.
75. TAPR Comments at 4.
76. Karn Comments at 2.
77. ARRL Reply Comments at 11.
78. Id.
79. John C. Koster Reply Comments at 2.
80. See 47 C.F.R. § 97.101(b).
81. See Letter from Chief, Private Radio Bureau, to Mr. Robert A. Buaas dated April 17, 1992, and extensions dated May 26, 1993, and December 27, 1994.
82. See Letter dated May 8, 1996, from Chief, Private Wireless Division, to Messrs. Greg Jones and Dewayne Hendricks. This STA was extended on November 6, 1996, May 8, 1997, and December 4, 1997, for additional 180-day periods. Reports outlining the finding of the experiments were submitted to the Commission as part of the extension requests. This STA expired in June, 1998.