[Lowfer] Last Chance on 136 kHz Rulemaking

[Neil Klagge]

I just finished filing my comments.

Neil Klagge
w0yse, Layton Utah


On Sun, Mar 24, 2013 at 6:21 PM, JD <listread at lwca.org> wrote:

> 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
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