[Lowfer] Should we make comments on 1750M?

[John Davis]

W1TAG writes:

>In the FCC's NPRM for the new amateur allocations, they invited comments on
>their exclusion of an amateur allocation at 160-190 kHz. I'm wondering how
>they would react to the following items in a counter-proposal:
> {snip}
> Also, thoughts on even turning this rock over would be
>appreciated.

I think the last point is the biggest question.  Many of you know me to be
very cautious and not inclined to be too optimistic about the FCC's decision
making.  My track record of predicting rulemaking outcomes is pretty good
when I lean slightly toward the pessimistic side.  So it's only natural for
me to urge caution in proposing something this specific which is also quite
different from what is currently under consideration.

If you'll forgive a bit of analytical thinking-out-loud, here's how I see
the downside and the upside of counterproposing.

Downside:  The Commission's focus right now is whether to do anything about
it at all.  Their present thinking is colored by the proposal already on the
table.  In such instances, counterproposals are sometimes seen as muddying
the waters; and when the rest of the actions open to them seem so clearcut,
the path of least resistance is thus to ignore counterproposals.  Sometimes
such proposals are revisited later; but other times the mere fact that one
is presented seems to prejudice its future consideration.

Also we should note that they asked only rather _generally_ for comments on
the tentative decision not to do 1750 meters.  They did ask rather
_specifically_ for comments on feasibility of making the utilities' PLC
database readily available and if it would reduce interference potential.
Those two facts, in light of all the emphasis they placed on the utilities'
arguments, give us an important clue of where their thought processes are
right now.

Upside:  The phrasing and tone of the requests for comments was a little
more open-minded than usual.  And to be perfectly candid, I think John A.
has come up with a really great idea that deserves serious consideration.

My Tentative Conclusion:  We don't want to bombard the Commission with
multiple variations of something they've tentatively decided is off the
table, and would probably be postponed to some later rulemaking at best if
there were a flurry of counterproposals.  BUT, if John A.'s proposal is
presented in the proper light as a way around the most serious objections,
which would allow real-world amateur operation as part of an interim step
toward future consideration of a more normalized 1750 meter ham band, then
it MIGHT not only stand a chance, but actually speed up the process.

Personally, I also think it's the best solution anyone has come up with for
the multiple problems of keeping the utilities happy (in their unallocated
but still highly protected status), and at the same time providing some
serious accomodation for the non-ham LowFER experimenters.

I do have a few observations on some specifics of the idea.  From the
beginning:

>1. Leave the 160-190 kHz Part 15 rules exactly as-is.


I don't think this is in doubt.  Even the ARRL was willing to leave our Part
15 status alone, although with 2W ERP, that becomes something of a moot
point.

>2. Add a secondary Amateur allocation at 160-190 kHz.  The rules would NOT
be
>the same as proposed for 136 kHz, though:
>A. No specification of antenna type or dimensions. {snip}
>B. No reference to the transmission line. This relieves the need to keep
the
>PA at the antenna base.

Actually, I would note that these two items are the _same_ as the 136 kHz
specifications, and differ only from Part 15.  The reasons John cites for
lifting these restrictions are very good points, and I endorse them
heartily!

Although as Bill A. notes, some folks may _want_ to get carried away with
antennas, I don't think we need to set any kind of restrictions beyond those
already in place on hams re: FAA requirements.  Those height limits are
serious enough impediments, and length is not a particularly good substitute
in LF transmitting antennas.  I believe it'll be a non-problem.

>C. Transmitter power OUTPUT limited to 1 watt PEP only. This is 20 dB lower
>than the power level proposed for 136 kHz, and in line with the current
Part
>15 rules. But it would permit us to use linear PA's without being penalized
>for their lower efficiency.


A couple of good points also from the standpoint of experimenters, but I
would sell this power level as being a way around the PLC problem too.   I
seem to recall the utilities claimed ARRL's interference calculations were
off by about this amount.  OK, for the interim, we give away 20 db...and
everybody's happy.  (See, I can be an optimist at times!)

>D. Emission BW should be confined to the 160-190 kHz band, but there would
>appear to be no need to preclude any reasonable mode.


I would offer one thought on this one:  What if we confined digital modes to
the lower 15 or 20 kHz of the band and allowed _only_ phone in the top
segment?  This would be another way of making life a little easier for the
pure-Part 15 operations, who (a) have naturally congregated in the top part
of the band since the GWEN days anyhow, and (b) would have a lot less
trouble getting narrowband modes through a bit of SSB from time to time, and
would be less likely to interfere with voice than with other digital
signals.

I really like the way John presents this objective:

>This would allow continuation of present Part 15 operations, and the
overlay
>of Amateur operation with improved antennas and more transmitter
>flexibility. Since most of us can gain only so many dB within the bounds of
>our real estate, I doubt that the Amateur signals could be so dominant as
to
>foul things up too badly for the unlicensed guys.


It's up to each individual's conscience as to whether or how they choose to
comment on it.  Still, this proposal looks like a potential winner to me.


John D.