[Lowfer] Simple check list for Part 5 idea...

[John Davis]

May I encourage a more thoughtful approach...maybe not all ideas on the
table, right up front, all in one weekend?

I suspect it may lead the same kind of excess expectations and hasty
reactions that we used to see out of the SHMRG: "Just who is this $#@%
'Coast Guard' and why are they stealing OUR frequencies?"  Brainstorming is
good in some circumstances, but maybe not when getting ready to deal with
the FCC.  Considerable deliberation and even some legal counsel are likely
to achieve better results.

In my role as self-appointed wet blanket--not to be argumentative or
discouraging, but only to serve as a reality check--here are some thoughts:

>1: Freqs 135.7kc-137.8kc & 160-180kc

Not sure I see the justification.  We know there's not going to be a ham
band at 160-180 for probably quite some time after there's one at 137kHz.
So there needs to be a better reason for asking for that 20kHz than "we
wanna play old time radio" as has turned out to be the reality with some
Part 5 licensees.  Is there some demonstrable need for SSB, for instance?

>2: Power out of amp 500w

Roughly in the right range, though again there needs to be some realistic
justification.  We have reason to believe that if there ever is a real ham
band, that 100W cap will come back again.  That's not to say there's no
value in experimenting with higher power, but there needs to be a case made
for it.


>3: ERP 2w


Do-able if there's some reason for it that doesn't amount to reinventing the
wheel.  All the SHMRG and one or two others have proven so far is that with
hundreds of watts of TPO, it's possible to duplicate the feats that have
been accomplished by LowFERs at one watt TPO or aerobeacons at 25W.

And bear in mind that 2W regular ERP is roughly three times the power of the
1W EIRP that had the power companies wetting themselves.

>4: Antenna under 200� height unlimited horizontal dimensions

Better to simply leave it at any antenna which will not require a full
aeronautical study or lighting, as there are some locations where even 199
feet would require both.  The SHMRG application provides a good guide to how
this can be handled.

Antennas (of less than commercial size, anyway) are one of the few topics
that remain experimental in any sense at these frequencies, and could be
used in part to justify the license, providing actual measurements will be
made.

>5: Any digital or analog mode of operation

What analog modes might that be, apart from SSB?  All modes to be used will
have to be described with some degree of specificity, although it appears
they have given more latitude on digital modes so far.  If SSB is proposed,
for instance, what indicates voice modes to be appropriate for serious
communication at these frequencies.

>6: Authority to communicate with other services and Part 5 license holders

Don't count on it.  This Commission is just plain not as flexible as its
predecessors.  Despite the staff recommendation to apply for Part 5
licenses, that doesn't mean they're going to let Part 5 licensees be the
spectrum equivalent of Sooners, settling the territory before it's
officially open.

I'm willing to bet cash money that they will flatly refuse international ham
communication!  Communication between Part 5 licensees--maybe, but I expect
BOTH licenses would have to be modified to permit it.

>7: 5 year license duration and be renewable

Not really the licensee's call.  Renewal depends on demonstration that an
experimental objective is actually being accomplished.  There are supposed
to be regular reports to the Commission on the results.  The SHMRG may fall
down badly on this.

>8: Fixed stations in any US state

Judging by the SHMRG model, do-able.

>9: Ability to add or delete stations either by submitting an amendment to
>the license or keeping a log of added stations and pertinent data about the
>stations by the administrator of the license.


Modification to the license upon application, perhaps.  But you've seen
first-hand how efficiently that works.  There will be no ability on the part
of the licensee to do it on their own...you can count on that.

John D.