[Lowfer] Report and Order

[JD]

Technically, the Report and Order is the "done deal" part, and the Notice of 
Proposed Rule Making of Docket 15-99 is what we need to be commenting upon. 
We make this distinction in the story at http://lwca.org and also went into 
a lot more detail in the June LOWDOWN.  Both of these resources will also be 
summarizing all the comments and replies as the deadlines draw closer.

(The August LOWDOWN will also include a summary of power levels and spacing 
from transmission lines of many of the Part 5 licensees at 630 meters.  I 
wish we had a similarly detailed list to present for 2200 meters.  Might 
help folks make better arguments in favor of the band.)

One of the things the FCC is asking specifically is whether amateurs will be 
able to distinguish between distribution and transmission lines.  We need to 
assure them that (despite any scare tactics of the utilities to the 
contrary) we can.  We don't have to worry about identifying types of 
supports, number of conductors, size of insulators, etc.  That way lies 
confusion, and consequently, gives the indutry an excuse to argue for 
needlessly restrictive regulations.

The difference basically boils down to one simple distinction: distribution 
lines have customer service drops, and transmission lines don't.  If you 
don't see pole transformers and customer connections, you'll have to assume 
it's a transmission line.  If you see two sets of lines on the same poles, 
one of which has customer connections and another which doesn't (a situation 
we actually have here a few miles north of town), then one of those is 
likely a transmission line and would have to be treated accordingly.  Pretty 
straightforward.

It won't be enough to just glance around a proposed operating location and 
say "yup, this looks promising," though.  I've previously outlined a 
technique that can be applied to most any terrain to assure the absence of 
transmission lines within 1 km.  In areas with many obstructions, it could 
involve a few miles of driving or hiking to be sure no such line crosses the 
perimeter of the smallest publicly accessible shape that encloses the 1 km 
radius circle of interest.  In most locations, however, I believe the 
relative ease of making such a determination removes any need for the 
"permanent fixed location" requirement the FCC is proposing.

On the other hand, while I see no problem with portable operation *provided* 
that an adequate site survey is done first, I don't share Craig's optimism 
about mobile operation.  First, of course, it's not a very practical thing 
to do, from the standpoint either of transmission efficiency or of noise 
pickup while receiving .  Second, in areas of limited visibility, it would 
be much too easy to round a corner and find yourself unexpectedly staring 
straight at a substation with multiple transmission lines entering and 
leaving.  Would Craig's 100 meter separation be adequate to protect PLCs? 
My feeling is that it very well might be, but I'm afraid we'd need much more 
detailed analysis to get anything less than 1 km into the Rules at this 
time.

John