[Lowfer] Deadline for 2200m Comments Fast Approaching

[Douglas D. Williams]

John is right. It would be a shame to lose this opportunity to gain an
actual amateur LF band in the USA (like much of the rest of the world has).
Those of you who have been operating Part 5 on LF for the last few years,
please turn in your comments!!

73, Doug KB4OER

On Mon, Feb 18, 2013 at 1:15 AM, JD <listread at lwca.org> wrote:

> 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
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