I support RM-11843. The VHF-LOW 30-50 mHz portion of the HF spectrum is ill-suited to many radio services due to it's 
low frequency making it subject to sporadic-E propagation as well as by F layer propagation during parts of the sunspot cycle. This results in severe interference for users of this part of the spectrum. 

The Amateur Radio Service can make use of this type of propagation and instead of experiencing interference we can turn it into a learning experience as well as a band where long distance communications can be conducted. 

In order to be able to follow the MUF as it rises above 29.7 mHz the Amateur Radio service should have allocations at or near 35, and 45 mHz as well. 

Typically, land mobile and fixed stations use this band for local communications but in reality such stations would be better served in the VHF and UHF parts of the radio spectrum so that they are not subject to interference from stations
a long distance away, when the band opens up. 

The part 97 Amateur Radio service was created for the following reasons. 

97.1   Basis and purpose.
The rules and regulations in this part are designed to provide an amateur radio service having a fundamental purpose as expressed in the following principles:

(a) Recognition and enhancement of the value of the amateur service to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications.

(b) Continuation and extension of the amateur's proven ability to contribute to the advancement of the radio art.

(c) Encouragement and improvement of the amateur service through rules which provide for advancing skills in both the communication and technical phases of the art.

(d) Expansion of the existing reservoir within the amateur radio service of trained operators, technicians, and electronics experts.

(e) Continuation and extension of the amateur's unique ability to enhance international goodwill.



An allocation in the VHF low portion of the radio spectrum will help with fulfilling each of the principles listed above
in 97.1 in the Part 97 rules. 

Additional spectrum for providing emergency communications. An additional band will allow for another channel of communications in areas of high density radio activity. Communications could be conducted on 10 meters, 6 meters, and with the allocation of 8 meters, 8 meters as well and all simultaneously from the same location without interference. 8 meters, due to it's lower frequency will allow for greater range than VHF-UHF communications and thus could be very important in emergency communications. 

We do not currently have an ability to experiment between 29.7 and 50 mHz. The 40 mHz allocation will provide that thus allowing for increased knowledge of propagation in this part of the radio spectrum, this will aid in 97.1 subpart b. 

VHf low is an interesting part of the radio spectrum with characteristics of VHf and of HF. At times it will be a challenging band and learning how to deal with the challenges is goes along with 97.1 (c)

More spectrum and new spectrum is likely to attract people who have been inactive as well as people who may want to experiment with weak signal work in the vhf-low spectrum thus contributing to the fulfillment of subpart D of 97.1

As other countries follow our example, communication worldwide on 40 mHz will help fulfill subpart E, enhancing international goodwill. 

Please approve RM-11843. 

Thank you very much.