[Lowfer] Whew! Now we wait for the decision.

[Laurence KL1 X]

 John and others - thanks for  all the input for FCC 12-338. Ive cringed at my typos and really had no excuse save for mis autocorrection, being British and lack of oxygen flying at 430 :-)

Ive been digging into the specs of some of the current PLC trip/guard specs and came up with

http://www.pulsartech.com/pulsartech/html/DynaPage.asp?PageID=10

Some nice details on how and whys - and some of the sensitivities - 5mV and some of the filtering and FSK rates, power typically 1W push to 10W, key by "frequency changes"- I should have read this and commented originally.  I see one chap has added late comments on the technical specs on some of the current offerings

It appears that the power/utilities and their councils are completely ignoring what is known would/will/wont cause issue with fingers hard pressed in their ears and eyes tightly closed. 

No  rebuttal on the part 5 operations that have taken place either. 

I too hope the FCC sees the plainly positive attitude from our camp, true life testing and infield experiences, and technical calcs all of which will allow 137kHz band here in the USA.. I dont mind who I share my bandwidth with and we are, as you say, quite used to successfully working that way - Im used to sharing as the primary with hams \Now off to shoot me a dog fence system... Laurence KL 1 X
 > From: listread at lwca.org
> To: lowfer at mailman.qth.net
> Date: Sun, 31 Mar 2013 14:15:36 -0500
> Subject: [Lowfer] Whew! Now we wait for the decision.
> 
> Just by way of update for those who may not have been following the 136 kHz 
> rulemaking on a daily basis...and frankly, that included me for a few days 
> after the 27th.  It was a very draining process, both following what was 
> going on and trying to get my own thoughts and responses in order.
> 
> The Reply to Comments period is now over.  As with the original comments a 
> month ago, ARRL's reply to the Utilities Telecom Council and power company 
> filings was admirably thorough.  UTC also filed a reply, bringing the Edison 
> Electrical Instutute into it this time, which my blood pressure was finally 
> under sufficient control today to attempt to read.
> 
> Once again, they flatly asserted--still without any supporting evidence or 
> analysis--that there is "no mechanism" to prevent interference from 
> amateurs.  They quibbled over ARRL's understanding of the CENELEC standards 
> for PLC operation, but NOT ONCE did they even mention the NTIA study that 
> clearly shows signals of 1 W EIRP simply will not and _do_not_ interfere 
> with co-channel PLC devices at a separation of 950 meters or greater (it was 
> not only a theoretical analysis but an empirical study as well).  The FCC 
> had mentioned it, I mentioned it in my original comments, and ARRL did a 
> much more rigorous analysis--but the power folks continue to pretend they've 
> never heard of it.
> 
> (Well, almost never.  In UTC's original comments, they did acknowledge that 
> the FCC was aware a 950 m separation would do the trick, but made an 
> incredibly lame attempt to cast doubt on the reliability of the numbers.  In 
> a footnote, they cited a study by an IEEE subcommittee for the previous 
> rulemaking attempt that said a separation of 1.34 km would be required for 
> the 2 W radiated power limit that was being proposed at that time.  They 
> were at least honest enough to state that separation was for 2 W, but they 
> prefaced the remark with a "however" that was clearly intended to foster 
> uncertainty.  Of course, 1.35/0.95 = 1.41, which is exactly the ratio you 
> would expect for a 3 dB power difference!  And of course, I made it a point 
> in my reply to take note of that fact, and said it should be comforting that 
> engineers on both sides agree on the basic science!)
> 
> While the vast majority of us who supported the amateur cause in this matter 
> expressed willingness to cooperate and make spectrum sharing work, the power 
> companies dug in their heels even harder this time, without exception.  I 
> hope the very harshness of that attitude will backfire this time, and that 
> the lack of ANY supporting technical analysis from the utilities will not be 
> lost on the Commission!
> 
> [At this point I feel obliged to apologize for the quality of my own reply 
> filing.  Even though I haven't had the heart to read it yet and see whether 
> I embarrassed myself too badly with glaring typos from last-minute edits 
> followed by inadequate proofreading time, there is one big shortcoming I'm 
> thoroughly aware of.  Unexpected work obligations at deadline precluded 
> writing the conclusion that I hoped would tie together all the disparate 
> points I was responding to.  I'd intended to point out that (1) the only 
> known mechanism for either co-channel or adjacent-channel interference was 
> clearly established, and that a combination of separation and, in limited 
> cases, coordination requirements could address that concern completely; (2) 
> amateur operators have long been accustomed to similar regulations, such as 
> coordination with/spacing from AMTS facilities at 1.25 meters, power limits 
> near PAVEPAWS locations, and the quiet zones around radio astronomy sites 
> and FCC monitoring stations in certain bands; and, (3) all the transmission 
> lines and substations that use the affected frequencies, taken together, 
> occupy a very tiny fraction of the land mass of the United States, leaving 
> enormous areas where spectrum sharing will work just fine with no 
> coordination at all.  Fortunately, ARRL picked up on that last point and the 
> first one, and we may hope Commission staff are already well aware of the 
> second.]
> 
> Before I close, I should mention something of interest to the 160 meter 
> operators in this group.  Changing the amateur allocation to primary status 
> in the 1900-2000 kHz should have been the least controversial part of the 
> whole NPRM.  And indeed it appeared to be, until ITM Marine, an importer of 
> marine beacon buoys, filed comments.  They claim the reason the FCC found no 
> non-federal licensed users was because--and get this, they offered two 
> explanations--the fishing fleet operators figured they didn't need a 
> license, being in international waters, or else the operation was covered by 
> the license for their shipboard radio equipment.  The latter is simply not 
> true, and the first one is ludicrous on so many levels that it must have 
> provoked great laughter at ARRL when they tore that one apart.  The illegal 
> fishing buoys that refuse to recognize FCC jurisdiction are now seeking its 
> protection from licensed users on land who have been there all along?  Give 
> us a break!
> 
> 73
> John D 
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