[Lowfer] Fw: FCC ET Docket 12-338

[K2ORS]

All,
     Below are my comments to the ARRL concerning the FCC's proposal for a 
137khz ham band.
I was led to believe that the ARRL Exec Committee was taking up the issue 
last evening, however that was not correct.
I received a reply from the ARRL president which I will forward in a 
separate e-mail.
73 Warren


Subject: FCC ET Docket 12-338



To:ARRL Executive Committee
From:Warren Ziegler, K2ORS

Date:11/29/2012
Re:136kHz NPRM
Comments:
 I am writing concerning FCC  concerning a proposal for an amateur 
allocation at 136kHz. Based on the language in the docket, I am concerned 
that the FCC will promulgate overly restrictive regulations for the new 
band. The FCC proposes limiting the power to 1W EIRP, and perhaps 
restricting amateurs to specific frequencies. I would like to share some 
points based my personal experience and the experience of other amateurs 
already operating on this band under FCC issued experimental licenses:


·         I have been operating an experimental LF Station WD2XGJ since 2003 
under part 5 of the FCC rules. WD2XGJ is licensed for 136-140kHz with 10 W 
ERP (~16W EIRP). WD2XGJ has a maximum measured ERP of 4W (6.5W EIRP). 
WD2XGJ's transmitting antenna is 900' from a high tension power line with an 
active PLC on 197kHz with no interference issues to date. It has been my 
experience that even with state of the art narrowband data modes 1W EIRP 
would been insufficient for dx communications on an inter-continental basis.

·         WE2XEB operated by Robert Raide W2ZM has been operating with 10W 
ERP intermittently for the past three years without interference.

·         Other U.S. amateurs have been operating on 137kHz  over the past 
decade, including Laurence Howell KL7UX (experimental licenses WD2XDW and 
WE2XPQ), John Andrews W1TAG (WD2XES), Jay Rusgrove W1VD (WD2XNS), Dexter 
McIntyre W4DEX (WD2XKO), David Curry  WD4PLI (WD2XFJ), Mike Reid WE0H 
(WD2XGI), Ted Holdahl KC3OL (WD2XYW), and others. These stations typically 
operate at or above 1W ERP (1.6W EIRP).  There have been no interference 
problems despite a cumulative operating time of tens of thousands of hours 
using many different operating modes.

·         The FCC is apparently concerned about interference to PLC systems 
for control of components connected to the power grid. PLCs operate under 
Part 15 and as such should not be protected against interference. It is now 
more than ten years since 9/11 and if the grid is still vulnerable to low 
power amateur operations then it could easily be brought down by terrorists. 
I would think that the FCC would not want to restrict amateur operations on 
LF which would have the side effect of advertising to the public the 
vulnerability of the grid.

·         I respectfully request that the ARRL Executive Committee work with 
the amateurs who have been using the 137kHz band and use the data developed 
by them in crafting a response to Docket No. 12-338.