[Lowfer] Whew! Now we wait for the decision.

[JD]

Just by way of update for those who may not have been following the 136 kHz 
rulemaking on a daily basis...and frankly, that included me for a few days 
after the 27th.  It was a very draining process, both following what was 
going on and trying to get my own thoughts and responses in order.

The Reply to Comments period is now over.  As with the original comments a 
month ago, ARRL's reply to the Utilities Telecom Council and power company 
filings was admirably thorough.  UTC also filed a reply, bringing the Edison 
Electrical Instutute into it this time, which my blood pressure was finally 
under sufficient control today to attempt to read.

Once again, they flatly asserted--still without any supporting evidence or 
analysis--that there is "no mechanism" to prevent interference from 
amateurs.  They quibbled over ARRL's understanding of the CENELEC standards 
for PLC operation, but NOT ONCE did they even mention the NTIA study that 
clearly shows signals of 1 W EIRP simply will not and _do_not_ interfere 
with co-channel PLC devices at a separation of 950 meters or greater (it was 
not only a theoretical analysis but an empirical study as well).  The FCC 
had mentioned it, I mentioned it in my original comments, and ARRL did a 
much more rigorous analysis--but the power folks continue to pretend they've 
never heard of it.

(Well, almost never.  In UTC's original comments, they did acknowledge that 
the FCC was aware a 950 m separation would do the trick, but made an 
incredibly lame attempt to cast doubt on the reliability of the numbers.  In 
a footnote, they cited a study by an IEEE subcommittee for the previous 
rulemaking attempt that said a separation of 1.34 km would be required for 
the 2 W radiated power limit that was being proposed at that time.  They 
were at least honest enough to state that separation was for 2 W, but they 
prefaced the remark with a "however" that was clearly intended to foster 
uncertainty.  Of course, 1.35/0.95 = 1.41, which is exactly the ratio you 
would expect for a 3 dB power difference!  And of course, I made it a point 
in my reply to take note of that fact, and said it should be comforting that 
engineers on both sides agree on the basic science!)

While the vast majority of us who supported the amateur cause in this matter 
expressed willingness to cooperate and make spectrum sharing work, the power 
companies dug in their heels even harder this time, without exception.  I 
hope the very harshness of that attitude will backfire this time, and that 
the lack of ANY supporting technical analysis from the utilities will not be 
lost on the Commission!

[At this point I feel obliged to apologize for the quality of my own reply 
filing.  Even though I haven't had the heart to read it yet and see whether 
I embarrassed myself too badly with glaring typos from last-minute edits 
followed by inadequate proofreading time, there is one big shortcoming I'm 
thoroughly aware of.  Unexpected work obligations at deadline precluded 
writing the conclusion that I hoped would tie together all the disparate 
points I was responding to.  I'd intended to point out that (1) the only 
known mechanism for either co-channel or adjacent-channel interference was 
clearly established, and that a combination of separation and, in limited 
cases, coordination requirements could address that concern completely; (2) 
amateur operators have long been accustomed to similar regulations, such as 
coordination with/spacing from AMTS facilities at 1.25 meters, power limits 
near PAVEPAWS locations, and the quiet zones around radio astronomy sites 
and FCC monitoring stations in certain bands; and, (3) all the transmission 
lines and substations that use the affected frequencies, taken together, 
occupy a very tiny fraction of the land mass of the United States, leaving 
enormous areas where spectrum sharing will work just fine with no 
coordination at all.  Fortunately, ARRL picked up on that last point and the 
first one, and we may hope Commission staff are already well aware of the 
second.]

Before I close, I should mention something of interest to the 160 meter 
operators in this group.  Changing the amateur allocation to primary status 
in the 1900-2000 kHz should have been the least controversial part of the 
whole NPRM.  And indeed it appeared to be, until ITM Marine, an importer of 
marine beacon buoys, filed comments.  They claim the reason the FCC found no 
non-federal licensed users was because--and get this, they offered two 
explanations--the fishing fleet operators figured they didn't need a 
license, being in international waters, or else the operation was covered by 
the license for their shipboard radio equipment.  The latter is simply not 
true, and the first one is ludicrous on so many levels that it must have 
provoked great laughter at ARRL when they tore that one apart.  The illegal 
fishing buoys that refuse to recognize FCC jurisdiction are now seeking its 
protection from licensed users on land who have been there all along?  Give 
us a break!

73
John D