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From: rcarpen@lan2wan.com
Subject: My Spread Spectrum Letter to FCC
Date: Thu, 28 Nov 1996 14:17:11 -0800
I mailed the following letter about a week ago. I've delayed in posting it to allow the recipients to get their paper copy first.

Bob Carpenter w3otc rcarpen@Lan2Wan.com Robert J. Carpenter, W3OTC 12708 Circle Drive Rockville, MD 20850-3713

20 November 1996

Chairman, Federal Communications Commission, Washington, DC 20554

Dear Sir:

On November 8, 1996, the Private Wireless Division of the FCC's Wireless Telecommunications Bureau modified the Special Temporary Authorization (STA) issued to Tucson Amateur Packet Radio (TAPR). I feel that these modifications, unless altered, will seriously compromise the results of any experimentation under this STA.

The major thrusts of the STA modification are:

a) allow Spread Spectrum (SS) transmissions on the amateur frequencies above 50 MHz,

b) allow the use of any spreading sequence,

c) no longer require stations using SS to identify in a manner which can be understood on conventional amateur receiving equipment.

Continued is the requirement that test transmissions must be terminated if they interfere with other amateur communication.

There is widespread alarm among the many users of the heavily populated amateur bands between 50 and 450 MHz that SS transmissions will seriously harm the present users. Thus it is very important that operation under the subject STA be conducted in an open manner so that all amateurs can participate and observe the results.

I request that the FCC require that users of the TAPR STA post their operating log, within 24 hours of each period of SS operation, on the well-known TAPR site on the World Wide Web (www.tapr.org). The log information must include: call letters of station, location, time, frequencies employed, power, antenna, SS type, etc.

This requirement would have a number of benefits:

1) without such a public record, other band occupants will have no way of identifying the source of SS transmissions, should there actually be interference,

2) it would demonstrate the technical prowess of TAPR in fielding real tests of real SS equipment,

3) without the open testing this requirement would encourage, the issue of SS in amateur radio will remain very contentious and clouded in distrust and misinformation,

4) it would demonstrate the serious and thorough nature of the tests under the STA,

5) by making the SS operation public in nearly real time, it would reduce the number of false reports of SS interference,

6) it would allow other users of the bands to correlate their observations with the SS STA users (after the fact).

I request that the Commission act immediately to add the above logging and posting requirement to the TAPR STA. It would not hamper experimentation in any way. It is not onerous. TAPR already possesses all of the necessary facilities.

Respectfully submitted,

`Robert J. Carpenter

cy: Greg Jones, TAPR Paul Rinaldo, ARRL