[CW] Part 15 Alert

[Donald Chester]

I checked the final comments on Docket 02-98 last night, before starting on 
my reply comments. It looks like the greatest threat to
amateur radio right now is NOT shortwave broadcasters or 
commercial/government interests who may want to reallocate our frequencies 
to other radio services. Actually, HF seems pretty deserted these days, so 
you would think there would be loads of spectrum available to us. The 
existing WARC bands could be expanded, and more new bands could be created 
all over the HF spectrum.

The threat I now see is the proliferation of unlicensed Part 15 devices. 
Amongst the comments, Part 15 interests are expressing concern about ALL 
THREE of the proposed new bands; this includes the proposed 2400-2402 mHz, 
60m and 135.7-137.8 kHz allocations. We all know about the power industry 
and power line carrier systems, but yet another industry is opposing us on 
60m. They are trying to establish home delivery of high speed data over 
power lines. Evidently they reached some agreement with the FCC that they 
could operate if they filter out ham frequencies, but they are moaning and 
groaning about the existing systems that already use the 5 mHz spectrum, 
both because of potential interference from hams and the fact that they 
would have to shut down systems that cause harmful interference to amateur 
communication on the new band. A similar concern comes from some outfit that 
is using the UHF/microwave spectrum for some other Part 15 gadget.

Part 15 devices are, by definition, supposed to operate with the prior 
understanding that they are completely unprotected. The industry knew from 
the beginning that if there is a problem from licensed services, 
satisfactory resolution is completely in their lap. But now they are trying 
to gain protection through the FCC, saying that since there so many users of 
these devices, including individuals as well as electric power distributors, 
that it would be in the public interest to extend FCC protection to 
unlicensed devices because Part 15 users are so much more numerous than 
hams. If this stuff continues to proliferate, the entire non-broadcast radio 
spectrum will eventually become tied up. There will be no need for EPCA, 
because you won't be able to receive anything through the buzzies from all 
this rubbish anyway.

Use of the radio spectrum under Part 15 began with the clear understanding 
that these devices had no government protection whatever. Now unlicensed 
interests are seeking minimal protection through the FCC. It doesn't take a 
rocket scientist to figure out that as this technology expands, they will 
continue asking for more frequencies and more protection. I am already 
hearing non-powerline interference in the lower frequency shortwave 
broadcast bands and in between. How much longer before unlicensed interests 
begin lobbying to trash the ham bands as well? If nothing is done to 
discourage this pollution of the radio spectrum, it will eventually end up 
worse than LORAN ever was on 160.

Don K4KYV



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