[Lowfer] 136 kHz Rulemaking and Daytime Tests?

[JD]

Haven't seen any discussion here yet of the comment filing period for the 
FCC's Notice of Proposed Rulemaking on a 2200 meter ham band.  Deadline is 
later this month (see http://lwca.org if you weren't aware of that).  There 
is one point in particular I'd like to bring to the Commission's attention, 
but it would help to have some more supporting evidence.

One of the things they mentioned three times in the NPRM is that they're 
willing to consider whether some other band such as 472-479 should be 
allocated INSTEAD of the CEPT band.  This would be an easy way out for them, 
rather than dealing with the ongoing headache of PLCs.  It's no easy feat to 
keep pretending that PLCs have no official allocation status, while out of 
practical necessity, simultaneously protecting them as though they do! 
That's a contortion act akin to having your cake and eating it, on top of 
believing 10 impossible things every day before breakfast.  But hey, the 
tough job is why they make the big bucks, so I'm not willing to let them off 
the hook.  No sleight of hand, no bait and switch here, please!  Let's have 
an honest evaluation of the band on its own merits.

I think the amateur service should have _both_ bands available in the U.S. 
The point I'd like to make to the Commission is that the two are not 
equivalent and are not substitutes for each other, especially in terms of 
propagation and daytime communications potential.  While groundwave 
propagation is much better at 630 m than 160 m, it doesn't hold a candle to 
2200 m, provided you can get a signal in the air at all.  Most everyone here 
probably knows that I can see MP at high noon any day of the year that we 
don't have storms nearby.  The recent times that Jay conducted mid-day QRSS 
tests were eye-opening, as was the early afternoon sign-on by Warren a 
weekend or two ago.

These instances lead me to believe that the band's well known nighttime 
potential has obscured the fact that it can still cross half the continent 
in the daytime under favorable conditions, too, which makes it valuable to 
the amateur service.  But I'd like to have more documentation before filing 
my comments.

Would anyone care to do some daytime operating over the next couple of weeks 
for this purpose?  And, do you reckon it would be possible for some of it to 
be on weekdays?  According to the forecasts, we're apparently entering a 
period of increased precipitation around here (much needed) which will limit 
the times when I can be out in the field, so some weekend days will be 
impossible for monitoring.

(And just for my own information, have any of you been in contact with out 
bethren on the RSGB list to solicit their comments on how administrations 
overseas dealt with any interference concerns?  And, what license classes do 
they permit to operate at LF, and what is their reasoning?  Those are a 
couple of other things the FCC appears particularly interested in.)

73,
John