[Lowfer] Rulemaking Ruminations - THREE: Don't Fence Us In

Tue Jun 2 13:43:38 EDT 2015

I think it is important to protect our rights, but not stir up a hornets
nest either:

* THREE: At 172, the FCC observes: "If we were to adopt our proposal to
permit amateur operations only when separated by a specified distance from
transmission lines, when a new transmission line is built close by an
amateur station, the station either would have to relocate farther away from
the transmission line or cease operating."

The same can be said for a new airport being built close enough to my house
to restrict my antenna.  I would have to bring down the existing antenna.
New power lines have plenty of public hearings, etc...  and ones that would
use PLC are relatively rare.  So this does not seem to be an unreasonable
restriction to me.  I guess I see this as normal, and not something we need
to write up special protections for that might get the PLCC community even
more riled up against us.

Further:

"Amateurs will not
be able to use their allocation status to force unlicensed PLC operations
out of the band."

This is also reasonable.  We may not be able to force an existing system
off now or in the future - however - if a new system is built,  I think the
existing rules would protect our licensed service.  There are about 100
4khz wide channels in use by PLCC systems.  I wouldn't think it would be
that hard to avoid the half dozen channels that overlap the proposed ham
bands.   We just need to be sure that any protection given is for existing
systems only, not new ones.

Hopefully we can utilize the existing PLCC spectrum coordination being done
by www.utc.org - that would be the best way to handle interference problems
in my opinion.  From their web site:

"In order to provide greater recognition of utility use of power line
carrier, the FCC developed rules that established an industry-operated
notification activity to help minimize mutual interference between PLC
users and licensed users (LU). The purpose of the Power Line Carrier
Notification Activity is to establish and maintain a transmission Power
Line Carrier Data Base (PLCDB) and a Authorized User Data Base (AUDB),
which will provide the information necessary for the identification and
notification of potential interference between Power Line Carrier (PLC) and
Authorized User (AU) facilities. *This Activity is established as provided
for in the FCC Rules and Regulations, Part 90.35(g)
<http://www.utc.org/sites/default/files/public/UTC_Public_files/90.35g%20PLC%20rules.pdf>(47
C.F.R. ' 90.35(g)) relative to PLC operation in the 10-490 kHz band, and
the NTIA Manual of Regulations and Procedures for Federal Radio Frequency
Management, in Part 8.3
<http://www.utc.org/system/files/UTC_private_file/NTIARedbookCHP08.pdf>,
under the heading “Notifications in the Band 10-490 kHz,” (see 47 C.F.R., *"

It kind of seems like the issue of PLCC and licensed users has already been
addressed.  Maybe this database is why the FCC had suggested use at only
fixed locations - so the licensed ham transmitter sites can get put into
this database...  ?

Craig - N6IO

On Sun, May 31, 2015 at 5:44 PM, JD <listread at lwca.org> wrote:

> * THREE: At 172, the FCC observes: "If we were to adopt our proposal to
> permit amateur operations only when separated by a specified distance from
> transmission lines, when a new transmission line is built close by an
> amateur station, the station either would have to relocate farther away
> from
> the transmission line or cease operating."  Scary, huh.  But they go on to
> ask: "How should our rules address the potential for new transmission lines
> to be constructed closer than the specified distance to pre-existing
> amateur
> stations? We do not want to inhibit the ability of either PLC systems or
> amateur services to grow and expand without imposing unnecessary burdens on
> either. Is it possible for utilities to refrain from geographically
> expanding their PLC operations within the relatively small portion of the
> 9-490 kHz band that we are making available for amateur operations, and is
> this something utilities would do on their own accord, given the Part 15
> status of PLC systems? Should our rules explicitly prohibit utilities from
> deploying new PLC systems in these bands?"
>
> My short answer: yes, please.  Look back at par. 26, in the WRC-07 R&O
> section where the Commission explains their basis for adding the 2200 m
> allocation:  "We intend to structure these service rules to promote shared
> use of the band among amateurs and PLC systems. Amateurs will not be able
> to
> use their allocation status to force unlicensed PLC operations out of the
> band, and utilities will have no cause to abandon or incur large costs to
> modify existing PLC systems."  Read part of that again: "Amateurs will not
> be able to use their allocation status to force unlicensed PLC operations
> out of the band."  That's the reality of the matter, but I think it also
> works in our favor.
>
> So far as I know, this is unique in the history of radio regulation.  I
> can't think of another example where an incumbent, but unlicensed and
> unallocated, user of radio spectrum has been afforded such protection from
> any allocated and licensed service.  However, most of us who commented in
> the 2013 proceeding DID AGREE with the Commission that PLC technology has
> been a special case for a long time, and most recognized that acceptance of
> its existence would be the only way to move the discussion off dead center
> and get to the point where we are now.
>
> But I maintain this coin has two sides.  If we in a licensed, allocated
> service accept that we will not displace existing PLCs now or in the
> future,
> then it is ONLY FAIR that the unlicensed, unallocated users should not be
> able to displace the licensed ones, either...now or in the future.  Letting
> someone use a resource only until you decide you want it for
> yourself...that's not sharing.
>
> The only way I can see to guarantee such protection to the licensed users
> is
> to modify Part 15 to impose a formal freeze on any changes in power,
> transmission mode, route of existing PLC systems, or installation of new
> ones, within a reasonable guard band encompassing and immediately adjacent
> to the new amateur allocations.  That achieves the stated goal of not
> displacing existing systems or burdening the utlities by forcing any
> changes, while only removing two small slices of spectrum for consideration
> for future installations.  That seems an entirely reasonable compromise to
> me.
>
> Your comments welcome--and necessary!
>
> 73
> John D
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