Zero Retries Guide to Submitting Federal Communications Commission (FCC) Comments and Reply Comments
By Steve Stroh N8GNJ
Amateur Radio is offered only occasional opportunities to comment on pending actions within the Federal Communications Commission (FCC) that affect Amateur Radio. Thus most Amateur Radio Operators don’t know what to say, or how to say it to offer effective and salient Comments / Reply Comments to the Commission. What follows is a highly personal perspective on “what to say” and “how to say it” to the Commission.
Last updated: 2025-07-28 - Draft 1, reflecting FCC Docket SB 25-201 in July 2025. This initial draft is dedicated to “M” because they specifically asked to see it.
Next update: Screenshots of examples!
This will be a work in progress for some time.
These are personal notes and preferences and lessons learned from submitting a number of Comments / Reply Comments to the Federal Communications Commission in 2024 and 2025.
I do not claim to have any professional, legal, etc. background to offer the following opinions and suggestions.
Other Perspectives / Guidelines on Submitting Comments / Reply Comments
If I find other articles / pages to recommend (or others tell me about them), I’ll provide them here.
The Meta of Going to the Trouble of Submitting Comments / Reply Comments to the Federal Communications Commission
Originally from Zero Retries 0193:
… if I didn’t speak out, I’d be complicit in US Amateur Radio’s collective apathy about this issue.
You’d be correct to observe that this is seemingly interminable and opaque process by the FCC and commercial interests. But, such process isn’t designed to accommodate the amateur (as in non-professional) nature of Amateur Radio. AR is a tiny, bit player in such actions in the 21st century. Such issues are battled out between (very well paid) communications law firms and FCC staff.
But there are openings in the process…
Do Your Comments / Reply Comments Matter?
The cynical among us, especially in Amateur Radio, say no. From their perspective, by the time the Commission puts out a Request For Comments / Reply Comments, it’s merely a required formality, and the submitted Comments / Reply Comments have no significant bearing on the Commission staff’s recommendations and the decisions of the Commissioners.
But consider, if there aren’t enough… or good enough… Comments / Reply Comments submitted in favor or in opposition of a change by the Commission, then such a Commission decision de facto ends up being decided purely internally by the Commission.
I don’t know if, in the end, individual Comments / Reply Comments from Amateur Radio Operators to the Commission actually matter. Perhaps they don’t. But I can absolutely state that not submitting Comments / Reply Comments really doesn’t matter.
I prefer the “benefit of the doubt” perspective, that submitting Comments / Reply Comments, especially good ones, can influence a Commission decision.
Steve Stroh N8GNJ Comments as Examples
I don’t hold my Comments / Reply Comments to the Commission as stellar examples of great Comments / Reply Comments. But at minimum, when the Commission puts out a Request For Comments that involve Amateur Radio, I’m trying to show up, with reasonably written, and reasoned Comments / Reply Comments.
If you want to read my (Steve Stroh N8GNJ) Comments / Reply Comments to the Commission, click here.
Comment and Reply Comment Deadlines Are Important, But…
A Comment or Reply Comment is likely to be read and considered (Disseminated) if it’s submitted by the stated deadline. Whether it will be considered… only the Commission staffers know what actually gets passed on to the five Commissioners for them to consider whether to make a change in Commission regulations, or not.
If you miss a Comment / Reply Comment deadline by a day or two, go ahead and submit anyway. I’ve been told, by several people with reasonable background, that such “close to the deadline” submissions will likely be received and “Disseminated”. But if you miss the deadline by a week, then your submission is unlikely to be “Disseminated”.
If you miss a Comment deadline by more than a day or two, then just submit your Comment as a Reply Comment (see below).
Comments Versus Reply Comments
Comments and Reply Comment periods begin at the same time. Reply Comment periods extend past the Comment Period - and that length is variable. I’ve seen Reply Comment periods of ten days, two weeks, and if memory serves even one month beyond the Comment period.
I haven’t seen (but haven’t looked very hard) guidance as to what the content of a “Reply Comment” should be… other than the name.
I’ve been told, again by several people with reasonable background, that the original intent of Reply Comments was to be “only be able to reference Comments”. Basically, if a Comment was completely wrong, the Reply Comment period is an opportunity to point out specifically how a particular Comment (or Comments) is wrong. This probably makes more sense (and there were probably longer Reply Comment periods) when all the submissions were on paper and filed in person (messenger) or by mail / package service. But now we have the Interwebs, and we can see the Comments within a day or few of them being submitted to the Commission.
But, yet again I’ve been told, again by several people with reasonable background, that you don’t have to reference a Comment when you’re submitting within the Reply Comment period.
Thus, you can treat the Reply Comment period as an extended Comment period. The only difference is that if you’re going to file a Comment in the Reply Comment period (and aren’t referencing another Comment), be sure to label your submission as a Reply Comment for it to be considered as having been submitted within the deadlines.
Formal vs Informal
If you look at ARRL’s Comments and Reply Comments to the Commission, they’re very structured and formal. That’s because they’re filed by a law firm, composed with resources to be able to do in-depth research, and the Commission expects submissions from law firms to be “up to snuff” of the Commission’s expected standards. With a law firm’s resources they can quote chapter and verse and regulation, etc. I don’t have such resources, so I don’t try.
That said, there are going to be those that file Comments / Reply Comments from deep engineering or legal backgrounds. Unfortunately, in a contentious issue, there can be thousands of Comments / Reply Comments, and those good ones aren’t easy to find.
Pro Tip: To find “authoritative” Comments / Reply Comments in a quick scan, look for Standard Filing. Those attach a document, rather than an Express Comment (fill in the form, no document attached).
Thus when I submit Comments / Reply Comments, I do so from my perspective… what I want the Commission to know about how a proposed change is going to affect Amateur Radio from my perspective. In short, I say to the Commission what I think they really need to know that isn’t obvious in the change that’s being proposed. I try to speak to them as I would be explaining a situation relating to Amateur Radio with an FCC staffer over a couple of beers (which… in a former life, I have actually done).
Standard Filing Or Express Comment
This is not to discourage… in any way… individuals or groups from submitting Express Commentsto the Commission.
Express Comment is the easiest - just fill out the form, type in your comments or copy / paste in your Comments / Reply Comments, and you’re done.
But, in an Express Comment, all formatting other than a space between sentences is stripped out. No paragraphs, no bullet points, etc. making for a confusing jumble of words to read through.
That’s why a lot of longer Comments / Reply Comments compose a document and do a Standard Filing and attach a document.
The formatting of your document is preserved, you can incorporate letterhead and graphics, etc. What I really like about PDF is that if the PDF is exported from the Commission website, the “metadata” is still available (assuming that you incorporate it - see Formatting, below).
Although it’s acceptable to upload file types of .docx, .doc, .pdf, .xlsx, .xls, .txt, .pptx, .ppt, or .rtf… in my opinion, it’s always best to make your document a PDF because it’s the most universally readable. Save your document in its native format (I happen to use Pages on Mac), and then Export your document to PDF.
My recommendation for submitting a document as a PDF is that most web browsers display a PDF easily. With the other formats, the browser passes the file over to a helper app - Microsoft / Open Office apps (if present), text editor, etc. That’s annoying and time consuming (compared to viewing a PDF).
Standing
In submitting Comments or Reply Comments, about Amateur Radio, I feel it’s important to establish that I have some standing to comment somewhat authoritatively as someone who would be affected by a proposed change to spectrum that’s used by Amateur Radio. I don’t think it’s necessary, or helpful, to brag about one’s long list of accomplishments and titles in Amateur Radio, unless doing so can add to your “Standing” that’s relevant to your Comment or Reply Comment.
I think it’s important to say that you’re an Amateur Radio Operator, and drop in your callsign, including in the name blank (see Formatting).
If you’re submitting Comments / Reply Comments on behalf of a group, then that’s significant, and in my opinion, the group’s name should be in the name blank (see Formatting).
If you have some relevant specific expertise that gives you a unique perspective for your Comment / Reply Comment, then definitely mention that.
But otherwise, in my opinion, in a matter regarding Amateur Radio your primary Standing is that you’re an Amateur Radio Operator.
Basic Knowledge Is Important
One mistake, or lack of knowledge, I see in a lot of Amateur Radio Comments / Reply Comments is that they state that a particular band is an “Amateur Radio band”. Example - 420-450 MHz is not an “Amateur Radio band”. In the US, 420-450 MHz isn’t allocated to Amateur Radio as Primary. In the US, the Primary use for 420-450 MHz is the US Government - see NTIA’s document 420-450 MHz (PDF). Amateur Radio is a secondary user of 420-450 MHz when its usage doesn’t conflict (cause Harmful Interference) with the Primary user.
Another “basic knowledge” issue I saw was in Comments / Reply Comments from unlicensed users of the 902-928 MHz band (Meshtastic) positing that their usage of 902-928 MHz was for emergency communications… and posited that was sufficient justification for the Commission to continue to allocate 902-928 MHz for unlicensed use. But emergency communications is not one of the identified, intended uses of 902-928 MHz, so the Commission isn’t likely to be too sympathetic to such statements.
Ideally, “some entity” would be able to offer a primer for Amateur Radio comments on each of the Commission’s Request for Comments in reasonable time to help individuals submit informed, cogent Comments / Reply Comments.
Individual Or Group
This is not to discourage… in any way… individuals from submitting Comments / Reply Comments to the Commission.
Very generally, from reading many Comments / Reply Comments, I think Comments / Reply Comments from groups / organizations have just a bit more gravitas within Commission Comments / Reply Comments. Comments / Reply Comments can stand out in an avalanche of individual Comments / Reply Comments.
Thus if you can get a group / organization Comment / Reply Comment together of individuals willing to sign their name to a Comment / Reply Comment from an existing group, whatever it is, then that’s ideal.
But, if you don’t have an existing group / organization, but there is at least a “loose affiliation, or ad hoc” group of individuals interested in submitting Comments / Reply Comments, (solely in my opinion), I think it’s acceptable to create a group - as long as the individuals are willing to sign their names.
That said, don’t masquerade your individual comments as an imaginary group. That won’t have any credibility.
And, if you have a “group” or other entity, like I do with Zero Retries, I think that’s equally acceptable when submitting Comments / Reply Comments.
A number of people have commented on my Comments / Reply Comments that my not mentioning that I’ve been doing Zero Retries as a newsletter for 4+ years now, with 2800+ subscribers, is a false modesty. I have some “gravitas” from Zero Retries and I should leverage that in my Comments / Reply Comments. Other examples:
Random Wire Newsletter, Ham Radio Workbench podcast, KM6LYW Radio YouTube channel.
What the FCC Wants to Hear About (Cares About)
A trusted advisor provided me with this short, pithy, realistic, and a bit brutal “reality check” list of the real priorities of the FCC in considering issues such as Docket 24-240:
Innovation
Creating new tax paying businesses
Unserved and underserved populations
Native Americans
People with disabilities
Schoolchildren
Emergency communications
Broadband communications
Revenue to the US government (spectrum auctions)
Cellular Telecommunications & Internet Association (CTIA)
National Association of Broadcasters (NAB)
This adviser consistently offers “distilled wisdom” on matters relating to the FCC, and I am very grateful for his input such as this.
From my perspective of having previously dealt with the Commission in my earlier writing career, this is a realistic list of priorities of the Commission in the 2020s.
This isn’t to say that Amateur Radio (as a service the Commission is chartered to administer) doesn’t matter to the Commission… but it’s not one of the Commission’s priorities.
However… note that innovation and emergency communications do matter to the Commission, so “looping those in” when submitting Comments / Reply Comments may achieve some additional notice.
To this adviser’s points, I would add:
Addressing the shortage of the Spectrum Workforce as outlined in the Biden-Harris Administration’s National Spectrum Strategy (https://www.ntia.gov/issues/national-spectrum-strategy) to expand the workforce of of those knowledgeable about radio technology to create new radio technology systems and build and maintain radio technology systems.
STEM education (we need more techies, not just programmers)
US national and regional security, including (radio systems) cybersecurity
US national economic activity / impact (not necessarily just paying taxes)
Just as software development, electronics experimentaiton, 3D printing, and robotics / drones are important ways to self-educate in skills highly relevant to the 21st century, I believe Amateur Radio, especially when combined with Software Defined Radio and localized Machine Learning (example - FreeDV RADE, Teacher’s Institute on Wireless Technology) can be portrayed as relevant to the Commission when submitting Comments / Reply Comments.
Formatting / Composing / Tone Notes
If you do submit Comments / Reply Comments as a group / organization… creating a “letterhead” in your document also helps you to stand out. (I need to create “letterhead” for Zero Retries.)
Precedent is significant at the Commission. Comments / Reply Comments from years, even decades ago may well be relevant in a new Commission Proceeding. So write so that your Comments / Reply Comments will hold up in a decade or more. (Don’t use current cultural references like “recent California wildfires” - state a specific name / durable reference.)
I’ve been told, by several people with reasonable background, that the terminology “The Commission” or just “Commission” is preferred to the terminology “FCC”.
Of course, don’t be abusive or an idiot in your language. If you disagree with something or someone, just state that you disagree (and back up why you disagree).
Please spell / grammar check your document (or your cut and past text) before submitting. Once you submit your Comments / Reply Comments, it’s in the public record, misteaks and all, forever. That’s another reason I prefer to compose my Comments / Reply Comments in a real word processor because such tools are built-in. If you don’t have a word processor, Google Docs is pretty good.
I like using footers in my Commission Comments / Reply Comments. Example:
FCC SB Docket No. 25-201 | Page of 14 | Steven K. Stroh N8GNJThe Commission, and law firm filings, love footnotes… but they’re really tedious to read through and parse, so I don’t use them in my Comments / Reply Comments.
Because there’s a significant possibility that Comments / Reply Comments will be printed, I don’t do inline hyperlinks such as Zero Retries. Instead, my preferred format is:
Zero Retries - https://www.zeroretries.org
That way, if my Comment / Reply Comment is printed, the name is preserved.
I haven’t previously done so, but the spelled out hyperlink probably ought to be hyperlinked for convenience when you’re viewing a PDF, and you can just click instead of copy and paste into a browser window.When inserting hyperlinks, don’t be tempted to use a hyperlink shortener like goo.gl, as those are “fragile” and could be discontinued. Then the Commission and readers are left with no clue.
Pro Tip 1 - If an online article is really critical to your Comment / Reply Comment, save it as a PDF and upload it with your document.
Pro Tip 2 - If an online article is really critical to your Comment / Reply Comment, make sure it gets saved into the Internet Archive’s Wayback Machine - Go to https://web.archive.org and use Save Page Now.
To see comments filed to date (with 25-201 as an example):
In the Proceeding(s) field, type:
25-201A pop up will appear:
25-201 SPACE BUREAU ACCEPTS FOR FILING AST & SCIENCE, LLC MODIFICATION APPLICATIONClick on that.
25-201 will appear in the Proceeding(s) field.
Scroll down and click on the big blue SEARCH button.
Pro Tip 1: The list of Comments defaults to 25 at a time. Selecting 100 at a time (click the 100 at the top of page) is much more efficient to scan through the list of Commenters.
Pro Tip 2: If you’re a user of RSS, you can get a unique RSS feed of Comments available in a proceeding. Follow the procedure above, then at the top of the results, to the right of Filings, there will be a link for RSS.
To File Your Own Comments / Reply Comments via Standard Filing (You’ve Composed a Document):
FCC Electronic Comment Filing System - FILING - Standard Filing.
In the Proceeding(s) field, type:
25-201A pop up will appear:
25-201 SPACE BUREAU ACCEPTS FOR FILING AST & SCIENCE, LLC MODIFICATION APPLICATIONClick on that.
Law Firm(s) field can be ignored
File Number field can be ignored
Report Number field can be ignored
Bureau ID Number field can be ignored
Fill in all the applicable blanks. For name, in Comments / Reply Comments, I suggest adding your callsign, as this field will be shown in the index of Comments / Reply Comments. Example:
Steven K. Stroh N8GNJ
Solely in my opinion, including an address makes the comment more… or at all… credible.
To File Your Own Comments / Reply Comments via Express Comments (Fill in the Blanks, Copy / Paste):
FCC Electronic Comment Filing System - FILING - Express Comment.
In the Proceeding(s) field, type:
25-201A pop up will appear:
25-201 SPACE BUREAU ACCEPTS FOR FILING AST & SCIENCE, LLC MODIFICATION APPLICATIONClick on that.
Fill in all the applicable blanks. For name, in Comments / Reply Comments, I suggest adding your callsign, as this field will be shown in the index of Comments / Reply Comments. Example:
Steven K. Stroh N8GNJ
Solely in my opinion, including an address makes the comment more… or at all… credible.
Aftermath of Filing Comments / Reply Comments
Once one’s Comment / Reply Comment is accepted and processed (Disseminated), then you’ll be able to reference your Comments / Reply Comments to others with the link on the Commission web page.
Impress your fellow Amateur Radio Operators, club members, perhaps even family - You showed up to provide input to the Commission.
You’ll only know if your Comment or Reply Comment was read and considered by the Commission if it’s cited in a formal Report and Order. (It does happen, but rarely, so don’t be disappointed if nothing seems to happen from your hard work preparing a well thought out Comment / Reply Comment.)
The End! (Thanks for reading this far!)
Feedback / Comments / Suggestions - steve@zeroretries.net