[Lowfer] Last Chance on 136 kHz Rulemaking

[craig wasson]

The UTC comments seem to make a good case for an amateur allocation
for the following reasons:

1. They point out that they have had no problem with the part 5
stations which I believe operate at higher power than 1W ERP - so ham
use would not cause problems.
2. If we took the UTC's advice and hundreds or thousands of hams
requested part 5 licenses spread out over the entire 9-490KHz range
(I'd be filing for one) the problem would be much worse.
Concentrating these stations in a few small bands protects the
majority of systems.
3. They mention the worry about interference to hams - has anyone ever
seen a PLC signal?  With our narrowband techniques interference should
not be a problem.
4. They admit that they do not intend to prevent interference to
licensed operations - such flagrant violation of part 15 rules should
not be protected.
5. They admit that a small transmitter could shut down the power grid.
 This is a dangerous situation that threatens homeland security - so
existing PLC systems should be  immediately shut down.  (I seem to
recall a mandate from the US Department of Homeland Security that PLC
systems be upgraded to be less vulnerable - does anyone else remember
that?)
6. They say that PLC systems in Europe have not had problems - and
they use them close to homes much more often.  I don't think it is
just that these systems communicate over a short range with small
impact - have there been any documented cases of interference of any
kind?  If not this shows that PLC use near hams is not a problem.

In my opinion the UTC comments provide a strong case for 2 or 3
amateur LW bands, and the conversion of existing PLC systems to a more
secure and reliable system.

If the new band does not go through I'd appreciate some tips on how to
file for a part 5 license.  I'd also be interested in what bands in
addition to 137, 185 and 490khz I should file to use.  70khz?  Closer
to 300khz?

Craig - N6IO


On Sun, Mar 24, 2013 at 4:51 PM, JD <listread at lwca.org> wrote:
> With only three business days to go for filing of reply comments in the 136
> kHz proceeding, I wanted to remind everyone interested that time is running
> out.  It may not be feasible to review and comment upon everything the power
> companies have filed, but IMO, some of their objections do need further
> answering.  The Utilities Telecom Council summarized a lot of the key
> objections, so their comments are a good place to start.  I have more
> thoughts to offer on their remarks this evening, but for now here's some
> "light" reading you should be aware of:
>
> http://lwca.org/miscdocs/UTC_comments.pdf
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