[CW] 160-190 kHz and PLC

[Donald Chester]

The FCC has chosen not to propose an amateur radio allocation in the 160-190 
kHz segment as requested by ARRL.  Here is an exerpt from Docket 02-98:

26. In declining to propose a secondary amateur service allocation for the 
160-190 kHz band, we observe that while the number
of incumbent primary users in this band has decreased over the years, the 
record and Commission staff analysis shows that
significant PLC use continues in this band in many locations.[61] The wider 
bandwidth in the 160-190 kHz band increases the
number of PLC systems potentially impacted. Further, while newer 
technologies may be implemented where possible, PLC
systems are not being replaced or retrofitted with these new technologies in 
many areas. Therefore, we continue to be concerned
about the interference potential that a secondary amateur service allocation 
would have on PLC systems...

I thought K2PG made an excellent response to this proposition in his 
comments:

...In declining to allocate 160-190 kHz to a licensed radio service, albeit 
on a secondary basis, the Commission appears to
contradict its own rules, in that it is requiring users of a licensed radio 
service to protect unlicensed devices operating on those
frequencies under Part 15. Carrying this precedent to an extreme, does that 
mean that the Commission should refrain from
licensing AM broadcast stations for operation on frequencies below 1490 kHz, 
since these frequencies may also be used by
PLCs? It is incumbent upon the users of Part 15 devices, be they individuals 
or large corporations, not to interfere with licensed
users of the frequencies in question and to accept any and all interference 
that they may receive from such licensed users...

I have another concern of vital importance, that if brought to the attention 
of the public and news media, could bring strong political pressure on the 
power companies to immediately begin phasing out PLC systems and replace 
them with more secure technology.  If the national power grid is indeed 
vulnerable to widespread outage due to incidental interference to the PLC 
system by relatively low-power amateur transmissions, that means the system 
is even more vulnerable to deliberate shutdown by malevolent forces.  Thus, 
this becomes a homeland security issue.  If a domestic or international 
terrorist group wanted to bring about widespread interruption to electric 
power distribution nationwide, setting up a number of strategically located 
and coordinated transmitters would be a much less risky venture than any 
attempt to physically sabotage transmission lines or other electric power 
infrastructure.

I see only two possibilities regarding this matter: (1) The power grid is 
indeed vulnerable to attack by deliberate interference to the PLC system, 
which would mean that this obsolete technology should be immediately phased 
out and replaced.  (2) The whole thing is a bogus proposition, in which 
case, denial of amateur privileges in 160-190 kHz is unjustified.

The FCC spells out in pretty specific details in Docket 02-98 how PLC works, 
and it wouldn't take as electronics genius to figure out how to disable it, 
if this is indeed possible.

I propose that the amateur community supply as many facts on this matter as 
we can glean from all available public sources and present this information 
to the news media, in hopes that they will alert the public and trigger the 
necessary policical response to cause PLC to  be phased out.  Apparently, 
better technology already exists, but the electric power industry is 
reluctant to spend the money to implement it.  They might be especially 
receptive to political pressure at this moment, since the last thing they 
want is yet another source of adverse publicity in light of the recent 
California fiasco and Enron scandal.

This will result in two benefits to the American public: (1) a power grid 
that is less vulnerable to terrorist attack, and (2) elimination of any 
justifyable reason to deny U.S. amateurs a 160-190 kHz allocation.

Let's roll!

73, Don K4KYV

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