How to File Standard Reply Comments for 16-239 Step by Step

This procedure is for users who have a Microsoft .doc or .pdf Adobe Acrobat style document ready to file, and do not wish to use the Express easy file method.

THE 9/17/19 FCC FILING DOES NOT FOLLOW THE RESOLUTION OF ARRL BOARD OF DIRECTORS MEETING.

IT WOULD ALLOW 2.8 KHZ WIDE SIGNALS EVERYWHERE IN THE RTTY/DATA/CW BAND SEGMENT.

This would create unacceptable interference to narrow band modes like FT8, RTTY, and CW.

Here are the actual ARRL Board of Directors minutes, see page 17.
http://www.arrl.org/files/file/2019%20Board%20of%20Directors/Final%20Minutes%20July%202019.pdf

IT IS ACCORDINGLY RESOLVED

(1) All automatically controlled digital stations (ACDS) below 30 MHz, regardless of bandwidth, are authorized to operate only within the ACDS bands designated in the FCC's Rules, 47 C.F.R. 97.221(b);
(2) All digital mode stations that operate with a bandwidth greater than 500 Hz also must operate within the ACDS bands designated in the FCC's Rules, whether or not automatically controlled;
(3) No digital mode station may employ a bandwidth greater than 2.8 kHz in any band below 29 MHz;
 (4) Reiterate to the Commission the need to remove, and the benefits of removing, the current baud limitations, subject to the conditions requested by the ARRL herein;
(5) Reiterate to the Commission the ARRL's unchanged position - most recently stated in its Comments submitted In the Matter of Don Rolph, RM-11699 - that the encryption of messages prohibited in Amateur communications by Section 97.113 of the Commission's Rules and by Article 25, Paragraph 2 of the International Radio Regulations, should remain prohibited;
(6) Request that the Commission remind Amateurs, by whatever appropriate means available, of the current prohibition against transmitting "messages encoded for the purpose of obscuring their meaning."


WE MUST RESPOND WITHIN DAYS TO BE HEARD! Here's how:

OPEN A NEW TAB IN YOUR BROWSER. THIS ALLOWS YOU TO READ THIS PAGE WHILE YOU TYPE INTO THE FCC PAGE.
Enter into THE NEW TAB ON your browser the following url or right click and open in a new tab:

https://www.fcc.gov/ecfs/search/filings?limit=100&proceedings_name=16-239&sort=date_disseminated,DESC

You certainly do not have to file something long to show your support. Concise on topic filings are best.

TALKING POINTS FOR YOUR FILING

IMPORTANT: Use polite respectful language that is brief and to the point. Before you access the FCC web site, you should have a document ready to upload. This file must be in either Microsoft .doc format or Adobe Acrobat .pdf format.

With Open Office freeware, you can create and edit a document in .odf format, but it must be converted to .pdf format before upload. When you are done editing, save the final document, and go to the upper left task bar FILE, get the drop down menu, and select "EXPORT AS .PDF". You will be able to name the document and save it. It will be a "read only" file. Use that .pdf document to upload to the FCC.

Start up your word processor, and create a new document. At the end, save it as a .pdf Adobe Acrobat file to upload.


     TALKING POINTS FOR YOUR FILING 
    IMPORTANT: Use polite respectful language that is brief and to the point.
    At the beginning of the filing, state:
    • Your name,
    • Your CALLSIGN (THIS IS VERY IMPORTANT), and
    • if you are an ARRL member and if so, for how long.
      This identifies you as one with a legitimate interest in the filing, not some unlicensed person.
    • I request that the FCC adopt the ARRL HF Band Plan as Part 97 Regulation, as described in the March 24, 2021 Petition for Declaratory Ruling by Carson, Kolarik, McVey, AND White.
    • A "voluntary" Band Plan will not be followed at all.
    • The ARRL HF Band Plan as described in the Petition for Declaratory Ruling reduces interference by separating peer-to-peer Narrowband modes from automatic Wideband Modes.
    • I oppose the part of the ARRL HF Band Plan that grants new digital and voice privilages to Novice and Technician class licences (RM-11828).
      (OR YOUR OPINION ON THAT COMPONENT OF THE BAND PLAN).
  • If that is all you want to say, you are ready to file.


    Once you are ready to file a REPLY COMMENT, and have your document composed and saved....
    1. Look along the top left of the displayed FCC 16-239 web page to find a box under FILTERS with a yellow line.
      At the bottom of that box, you will see:
        + New filing / + Express
      Click on + New filing.
      It will take you to a web page that already has a form partially filled out with "16-239" in yellow in the "Proceedings" field.
    2. Go down to the next field, where it says:
      *Required. Add filers. Press Enter after each entry, if there is more than one.
      Type in your name. Press Enter.
      IT WILL NOT TAKE YOUR NAME TIL YOU PRESS ENTER.
      Your name should now be in a yellow box inside the field.
    3. Skip the fields Law firms and attorney.
    4. Go down to the next field, where it says: email.
      Enter your full email address. Yourname@company.com or whatever.
      YOU DO NOT HAVE TO PRESS ENTER.
      IMPORTANT! The public will not see your email, unless you put it in your document.
      This only allows the FCC to send you a confirmation of receipt of your comments.
    5. On the Type of Filing box, go to the arrow on the right hand side of it.
      Click on the arrow.
      You will see a list of types in a drop down menu.
      Click on REPLY TO COMMENTS. That enters the type of filing in that box.
    6. Skip the fields File Number and Report Number and Bureau ID number.
    7. Go down to the next field, where it says: Address.
      Enter your street mailing address, like "1428 Elm St".
    8. DO NOT CHECK THE BOX "INTERNATIONAL" This is only for non USA filers.
    9. Go down to the next field, where it says: Address 2.
      Use this if you have a PO box or the street address includes apartment number or it won't all fit in the first box.
      Otherwise, skip this one.
    10. Go down to the next field, where it says: CITY * REQUIRED.
      Type in your city.
    11. Go down to the next field, where it says: STATE.
      CLICK ON THE ARROW ON THE RIGHT HAND SIDE OF THE FIELD.
      You will get a drop down box of states.
      Click on your state and it enters it in the field.
    12. Go down to the next field, where it says: ZIP * REQUIRED.
      Enter your zip code.
      The small box to the right of that one is for your ZIP + 4 digits, if you know them. Not required.
    13. Before you upload in your comments,
      check the box at the bottom that says "email confirmation".
      This causes the FCC to send you an email at the address you entered above to confirm they got your comment.
    14. ALMOST DONE! First be sure all blank areas on the form which have a "*" are filled in.
      The FCC system will NOT accept any filings that do not have that information.
      If you don't have all the fields filled in properly, it will reject it.
      Bummer.
      You are now ready to upload your pre existing .doc or .pdf file of reply comments.
      Click in the box for uploading files.
      Navigate your computer's file system to find your comment file.
      Click on it. Be sure you click on the correct file, not a love letter or a recipe. ^_^
      When the file uploads, it will show up in the box.
    15. There will appear an open box at the right to enter a description of your comment.
      Type in "REPLY COMMENT TO ARRL REVISED PROPOSAL"
    16. IMPORTANT: Review your address etc, for accuracy.
      Then click the button on the bottom: "Continue to Review Screen".

    One of two things happen.

    • If you did not fill out all the address and contact information in the required fields, you bounce back to the beginning.
    • IF all went well, you are now on "step 2" and the big yellow ball says that.
      Review your work, and click the button at the bottom, "Submit".

    IF all went well with "step 2", you are now on "step 3" and the big yellow ball says that.
    You will see your confirmation number and so on. Print this if you want to. You will not need to print it, if you checked the "email confirmation" box.
    Within ten minutes, you will see an automatic email in your inbox.

    IMPORTANT! WAIT! The FCC system is digesting your information and checking it. Nothing will appear to be happening.
    Do NOT file repeated duplicates of your filing.
    IF you do not WAIT as directed, but keep repeatedly clicking on SUBMIT, multiple filings will result.
    If you immediately check the FCC website, your comment WILL NOT BE THERE right away.
    Your filing will appear on the FCC site within a couple days.

    You are done! Thank you very much for your help.

    I am FOR use of amateur radio for legitimate emergency communications. I am AGAINST its exploitation for commercial or illegal use as a free HF email service or private radio network.

    73, Janis AB2RA

    FOR ANY SKEPTICS: HERE IS THE ARRL 9/17/19 LINK, read it for yourself:
    https://ecfsapi.fcc.gov/file/1091828798020/ARRL%20FCC%20Docket%2016-239%2009_17_2019.pdf

    On page 11 (THEIR page 6) is a heading: "III. Matters Raised by Commenters Outside the Scope of This Proceeding May Have Merit for Consideration in a Further Notice". The essential spectrum protections issues you filed on, listed above, are NOT included in the actual ARRL recommendation to the FCC for immediate action. They are included in this subsection that claims they are not "within the scope" and don't matter. They say these MAY be the subject of a MUCH LATER action. It only LOOKS like they included the ARRL Board of Directors items, but it is NOT a request of the actual filing. Read the conclusion. It says only to delete the 300 baud and allow 2.8 KHz EVERWHERE. "FINE PRINT" of lawyers, always read it, or pay the consequences.

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