[Lowfer] Last Chance on 136 kHz Rulemaking

Mon Mar 25 18:06:53 EDT 2013

My license is good for 500 watts erp and there is no coordination with PLCs included in the license requirements.

Pat
WG2XLP

Warren K2ORS <k2ors at verizon.net> wrote:

>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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