[Lowfer] Deadline for 2200m Comments Fast Approaching

[JD]

As of tonight, a week from filing deadline, there are 59 comments (including 
a couple of replies) on the FCC's Notice of Proposed Rulemaking which 
includes the possible allocation of 135.7-137.8 kHz.  I have just gotten 
done reading them all.

Of those 59, only 17 mention 2200 meters whatsoever.

Of those 17, three are from power companies vigorously opposing the 
allocation, predicting dire consequences and moaning about the cost of their 
utterly losing the 10.1 kHz that would be affected.  Two comments are from 
hams Nickolaus E. Leggett and James Whedbee (who also has one reply to the 
power companies' comments), and unfortunately, both of those propose a 
variety of convoluted complications that could well doom the whole process, 
IMO.  ("If it's going to take THAT much effort to make everybody happy with 
an LF ham allocation, let's stuff this idea back in the closet for another 
hundred years," sez the FCC to itself.)  A couple of other comments are from 
hams involved in emergency communication, but their comments were pretty 
general in their support from the band, not positing specific benefits from 
having it.

Perhaps most depressing of all were the ones that gushed on urgently at 
great lengths about what is probably the least controversial part of the 
rulemaking (primary status for hams at 160m), and then as an afterthought 
added this vague, generalized form letter wording--and I kid you not, it's 
word for word the same in nearly all of them:

"The need for a 137 kHz. allocation is less obvious, but opens up 
possibility for new forms of experimentation using a part of the spectrum 
otherwise unkown to Amateurs since the very early days of radio.
I urge the Comission to adopt both measures."

Gentlemen, I submit we had better MAKE the need for a 137 kHz allocation a 
heck of a lot MORE obvious to the Commission, or it's not going to happen!

If we don't win an allocation this time due to further Nervous Nellie 
concerns the power industry might scare up, there could perhaps yet be 
another chance later, as there was this time.  But if we lose it through 
seeming LACK OF INTEREST and/or the absence of specific, practical, 
realistically do-able common sense proposals for mitigating risk to PLCs, I 
fear we just might never get another chance in our lifetimes.

It's clear to me that the utilities want no other users at LF, and their 
remarks to the FCC are predicated on the bogus idea that we can't possibly 
co-exist.  Well, of course we can.  It's just basic engineering.  I'm still 
working on my own comments in that regard, and will file them later this 
week, before the deadline on the 25th.  However, nothing will get the 
Commissioners' attention, and get them considering the proposal seriously, 
like having comments from those who have actually been USING the band 
successfully for the past several years.

I have high hopes that some of you are already working on that very thing, 
as I know there are some very eloquent folks among us.

The only suggestions I might offer are to keep it (a) factual, and (b) 
practical--meaning, please, such things as don't suggest the Commission get 
even more federal agencies involved in dealing with the power companies, and 
avoid ideas like assigning dozens of specific bandwidths and specific power 
levels for specific classes of licensee in specific nitpicky little parts of 
the band.  The more straightforward the process, the more likely something 
good might come from it.

73
John