[Lowfer] Last Chance on 136 kHz Rulemaking

[JD]

I certainly agree, Neil.  Warren's reply to the FCC in conection with 
comments from UTC and the utilities was, I think, a very sound document.  He 
cited the thousands of hours of operation conducted without interference, 
frequently at licensed power levels greater than being proposed for the 
Amateur Service.
I believe it would be helpful to have a few more folks refuting the various 
questionable and sometimes downright wrong points of "logic" in UTC's 
remarks.

Somehow, though, UTC does not seem to make a critical connection.  Their 
suggestion is for the FCC simply to continue issuing Part 5 licenses to 
those interested in experimenting in this band.  If that's not a problem for 
them, then just WHAT sort of operation are they assuming would go on under 
Part 97 that doesn't go on under Part 5?

Do they envision thousands of hams driving around, willy-nilly, with big 
linear amplifiers and dangerous corona discharges emanating from their 
mobile antennas in a vain attempt to achieve 1 W EIRP, calling CQ through 
badly distorting speech processors???

Ain't a-gonna happen.  I think all of us here recognize that fact, but we 
may need to make sure the FCC sees it.  With a band no wider than a single 
voice channel, on which _neither_ voice nor high speed data will be 
permitted anyway, there's certainly going to be no mass influx of casual 
operators.  If there's a genuine concern about the possibility of someone 
keying up while parked under a high-voltage transmission line--surely MY 
idea of a great spot to hear another station on LF, I can tell you 
(not!)--then the fix is simple and obvious: prohibit mobile operation in 
that band.  (But we also want to be sure they don't prohibit portable 
operation of emergency, DXpedition, or Field Day type, subject to the 
condition it be conducted a safe distance from transmission lines.)

In regard to the distinction between transmission lines (the ones running 
between substations, on which PLCs are used) and distribution lines (the 
ones that bring power to the customers' premises), the UTC seems to argue 
that Europe has escaped problems from amateur LF operation because PLCs 
operate on distribution lines there, where interference is less critical 
than it would be on long-distance transmission lines.  It would be great if 
we had input from our overseas colleagues on this claim!  Does anyone know 
someone who could give us more details quickly, particularly about whether 
there have been ANY claimed interference issues?

On the face of it, though, this assertion doesn't seem very relevant to this 
rulemaking because (1) no one, including the NTIA study of GWEN's 
interference prospects, has observed or even suggested that RF coupling into 
the local distribution lines has any effect whatsoever on the other side of 
the substation transformers, and (2) in the absence of any known 
interference problems on the distribution side either in Europe, or from 
Part 5 licensees here, that only tends to support the idea that coexistence 
IS possible!

So, I hope a few folks will examine the UTC comments for themselves and find 
one or more of their key points worth replying to before the deadline 
Wednesday afternoon.  It's difficult to keep my sense of irony in check when 
replying to this particular document, but I think the facts are on our side 
this time if we make the case well enough.  The story on the rulemaking at 
lwca.org gives the link for looking up filings in Docket 12-338, and from 
that page you can also access the form for leaving replies.

73
John