[Lowfer] Last Chance on 136 kHz Rulemaking

[craig wasson]

Excellent discussion!   I read through all of the comments and replies
submitted so far - focusing on the ones submitted by the power
industry.  It does seem that even the utilities would be in favor of a
600M allocation so that is some good news.  I may suggest some
temporary restrictions such as limits on mobile operation and reduced
erp within 1km of 100kv lines .  We may even want to make the ham
allocation secondary to existing part 15 PLC operations although that
could open a big can of worms.   I may get flamed for giving too much
away, but as long as these restrictions are temporary - until existing
systems can be moved or made more immune to interference or prove to
not be affected - it should be OK.  I also plan to emphasize the
benefit of consolodating all of the activity in a few narrow bands
rather than a bunch of part 5 licenses which could operate anywhere.
By only replying to previous comments I think it becomes a more
powerful statement.

There was an interesting comment talking about the need to limit
antennas as well as power - which the erp limit would do
automatically.   It is pretty clear that nobody wants to include hams
in the existing PLC frequency coordination done by UTC.ORG, but that
may be part of the answer.

What I'm doing is cutting/pasting the relevant comments previously
filed into my document so I can use them as a reference for my reply.
 The goal for me is to protect existing PLC operations, encourage them
to upgrade to more resilient systems over the next 10 years and
establish some narrow slices of spectrum.

One question for the part 5 operators - does your licence include
anything about coordinating with or being secondary to existing PLC
operations?  Did you have to get your location and frequency cleared
by UTC.ORG?  Do the licenses include any restrictions to protect PLC
communications since part 5 operations are often at more than 1W erp?

Craig - N6IO


On Mon, Mar 25, 2013 at 3:22 PM, JD <listread at lwca.org> wrote:
>>>> John:
>>>> What is the FCC address for reply comments?
>>>> Searched for it on their web site but no joy.....
>>>> Perry
>
>
> The best way to get there, as I outlined in the news story at lwca.org, is
> through the Comment Search link (below).  Enter 12-338 at the top for the
> Docket Number, then scroll all the way to the bottom to click.  On this
> form, you won't need to fill in anything else.  The reason I suggest going
> in this way is so that you'll be able to read some of the existing Comments
> and Replies for yourself, and get a sense for how they should be done.  Some
> are formal filings in legal form, and others are informal.  Try to view some
> examples of both.
>
> (Notice that not all the filings are about 136 kHz.  This is a very big
> docket that includes many topics.  If you stick with some names you
> recognize from this reflector, though, you'll probably get ones pertaining
> to our interests.)
>
> When you are ready to submit your own reply, there are links at the upper
> left of the Comments list.  One is "Submit a Filing," and that's the one to
> use if you plan to upload your comments as a word processor file.  Be sure
> to fill out all the required parts of that submission form before attaching
> the document, though.
>
> ---Important Note:  There is a box in that form titled Type of Filing.  It
> defaults to COMMENT, but since the deadline for those has passed, you want
> to select REPLY from the dropdown list instead, and be sure you mainly
> address comments already made in the proceeding.
>
> If you only want to submit a few paragraphs and don't want to duplicate all
> the legal boilerplate, instead use the "Submit a Filing (Express)" link.
> This one takes you to a page listing current dockets.  If 12-338 isn't
> listed there (it wasn't, last time I looked) there is a "click here" link
> near the top.  That takes you to a form where you can put in the number.  In
> this one, there is a little information to fill out, but you don't have to
> attach a word processor document, though.  You can simply type or
> copy-and-paste plain text into the appropriate box.
>
> In any case, be sure to reply to some other commenter's observations, and
> keep it respectful to both the FCC and the other person involved.  I think
> we have the facts on our side this time, supporting the idea that this ham
> band can work for the benefit of all, and that's what we want to emphasize.
>
> http://apps.fcc.gov/ecfs/comment_search/
>
>
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