The FCC Notice of Proposed Rulemaking (NPRM) MD Docket 20-270 appeared in the October 15 edition of The Federal Register and sets deadlines of November 16 to comment and November 30 to post reply comments, which are comments on comments already filed. That means that the deadline for you to make comments is only days away.

I was able to finally figure out how to submit comments, so I’ll impart what I have learned. First, there are two ways to submit comments. One is to prepare a word processor document, as I did, and upload it to the FCC at the FCC’s Electronic Comment Filing System. The other is to make a brief statement for, or in opposition to, the proposed fees. You can type that right into the ECFS.

Yes, you can make comments that you agree with the proposed increase. Remember, however, that your comments are public and we know who you are (Just kidding).

First I will explain how to make a brief statement which is probably the prefered method for those who do not have a lot of time. Second I will explain how to upload a document. You might want to peruse the ARRL guide to submitting comments web page before you start.

They recommend not dwelling on how devastating such an increase might be to amateur radio. Obviously do not make accusatory statements. There are some blogs out there contending the FCC is trying to destroy amateur radio so they can sell our frequencies to private companies. This may, or may not, be true, but it is an example of what not to say in your comments.

Try to stick to what you know. Old timers have seen developments in amateur radio that benefited humankind and contributed to the landing on the moon (or what ever). Stick to those elements. I concentrated some effort on emergency communications because that is what got me interested in amateur radio to begin with. If you have participated in community service events, you might indicate how you feel part of the community because of it. If you have had to call for help with amateur radio, that might be something to tell them.

Making a Brief Statement

The brief statement is the easiest and quickest method of making a comment. If your comment is going to be 500 words, or less, this is probably the best method. My statement was about five pages so I had to use the method outlined next.

I recommend that you type out your comments in your favorite text editor. Read it over a couple of times and make any corrections. Be concise, but clear. If you read your statement and it sounds like a politicians campaign speech, you probably want to cut it down. If you have several points, you can use a number-bullet-type of arrangement such as:

I oppose the proposed fees on amateur radio licenses because:
1) I have participated in community events and have seen how amateur radio protects the lives of people in these events. On at least two occasions I have witnessed amateur radio operators calling for help for runners in distress that may have saved their lives [That was my personal experience. Wish I had thought to add that to my statement.]
2) I participated in actual emergencies with the Amateur Radio Emergency Service during weather emergencies that kept me up-to-date on what was happening and allowed me to keep in contact in case I had an emergency.
3) I find the life-long learning of amateur radio to be a benefit to me and helps me to keep abreast of technological advance in amateur radio and in other fields.
4) I personally constructed a robot that can take instructions through amateur radio and can perform appendetomies. [Only use if you happened to construct a robot that can take instructions through amateur radio and can perform appendectomies. Don’t use otherwise.]

Once you have your statement ready to cut-and-paste, go to the the FCC’s Electronic Comment Filing System Express Comment section. The following steps also apply for the standard filing.

In the Proceeding(s) box, type “20-270”. Two items will come up, but you obviously want to select 20-270.

Put your name in the Name(s) of Filer(s). If you are making the statement with others, add their names, as well. For example you could add all of the amateurs in your home.

Unless you are a law firm or attorney, go down to Primary Contact Email and add your email. Just below that click on the drop-down menu and select Comment for Type of Filing.

Go down to the Address of section and fill out your address. You can use any address where you receive mail, but I recommend using the address you used to obtain your license. I seriously doubt that the FCC is going to send you a letter on the matter. At the bottom, however, there is a box for Email Confirmation. I recommend that you check that and you will get an email confirmation that the FCC received your comments.

Click on the Continue to review button. If it looks good submit it. You’re done.

Standard Filing

If your comments are going to be lengthy, you might want to choose Standard Filing. Use the same steps as above to prepare to upload your comments. You can simply drag-and-drop from your directory to the web site.

The site says it will accept PDF, text, ppt, pptx, docx, xlsx, doc, xls, rtf, dwg documents of 25 MB per submision and a maximum of 5 files. I used LibreOffice (the freebie program because I am cheap) to create a docx file. When I tried to submit it, however, it kept giving me an error. When I saved it to a PDF, it uploaded with no problem. So if the site give you an error, I recommend saving it as a PDF to upload.

SUMMARY

I hope this helps you to get a comment in before the comment period is up. Remember the last date for comments is November 16.

I will let you know that in my comments, I did say that if they needed an increase, I would not totally object to a $15 fee. I also said that I agreed to a $50 fee (or higher) for vanity license fees. We have people that have been changing their vanity calls several times tying up a call you might want. A healthy fee might just prevent that. I also said that anyone under 18-years-old should remain free and to upgrade your license should remain free. That is my opinion and I am sticking with it.

What ever your opinion, I hope you will get it in before the comment period ends.