[Lowfer] Last Chance on 136 kHz Rulemaking

Warren K2ORS k2ors at verizon.net
Mon Mar 25 16:42:37 EDT 2013


Craig,

      There is nothing about PLC's or coordination with anyone at all on 
the WD2XGJ grant which is for 136-140kHz 10W ERP.

73 Warren


On 3/25/2013 4:38 PM, craig wasson wrote:
> 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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