[Lowfer] Last Chance on 136 kHz Rulemaking

[JD]

Incidentally, there is one other point UTC makes in their filing that I 
haven't quite figured out how to address, myself.

They say that if a licensed service is authorized in the band, then they 
(the power companies) become responsible as Part 15 users for correcting 
interference to the licensed users...which they claim would be prohibitively 
expensive to correct properly, and merely shutting down the offending signal 
would be catastrophic to the safety of the power grid.

This may be the proverbial elephant in the room.  Yes, it would mean they 
are responsible--just as they are now (I forget whether it was Warren or 
James Whedbee who made this point) to the operators of Part 5 Experimental 
Service stations, or any other licensed user.  That this has not yet been an 
issue for anyone yet, however, is one factor suggesting it's not as big a 
deal as they imply.  But when you come right down to it, that IS the whole 
point of Part 15...to protect licensed spectrum users, not to prevent them!

Since it hasn't been a real issue thus far, my own original comments 
suggested that new, replacement, or relocated PLC systems should be 
prohibited within 4 k Hz either side of the proposed band, but other than 
that no action would be required of existing systems.  (The 4 kHz figure is 
not for the sake of interference to hams, but is the guard band the power 
industry says a PLC needs.)

In the long run, though, I realize there probably will come a time after 
more operators are on the band when an interference issue will actually 
arise.  What DO we do then?  If we're an allocated user, we're in the right 
automatically under Part 15, so how do we cooperate with them in resolving 
interference without giving them de facto allocation status that negates the 
whole point of Part 15?  I don't pretend to have that much wisdom, but I 
think we've got to come up with something reasonable, or the even worse 
status quo will remain.

John