[Lowfer] Rulemaking Ruminations - ONE: Permanent Fixed Location?

[JD]

This is probably a good time to get discussion reactivated on the MF and LF 
ham proposals.  Although I continue not to see publication of the NPRM in 
the Federal Register as yet, the FCC EFCS Web page for the proceeding is 
open and accepting filings.  Until FR publication, we won't know the closing 
dates for comments and replies, but you can already see what's been going 
at:
http://apps.fcc.gov/ecfs/proceeding/view?name=15-99

Although I've been awfully tied up with other things recently, my reading 
thus far brings to mind three points I believe we really, earnestly need to 
address with the Commission.  This proceeding will set the exact rules for 
2200 m, and very probably also 630 m, so it behooves us to make the best 
case we can, now, right up front.  If the initial rules are too restrictive 
on amateur activity, it could be very difficult and time consuming to get 
them changed.  Here are my initial concerns, split into three parts to make 
threaded discussion of each part easier..

* ONE:  In paragraph 168, the FCC states that in addition to separation 
distances and power limits, "we propose to limit amateur stations to 
operations at fixed locations only to ensure that this separation distance 
can be maintained reliably."  That's stricter than it may first sound.  The 
FCC's actual proposed wording for § 97.303(g)(1), for both 2200 and 630 m, 
is: "Amateur stations are restricted to use at permanent fixed locations." 
Permanent fixed locations.  That goes way beyond my suggestion that mobile 
operation be prohibited.  It explicitly precludes temporary fixed operation, 
such as Field Day activities, or tests of ground characteristics for future 
potential antenna sites, or other legitimate short-term experiments.   In my 
view, this is needlessly restrictive, and could also open the door to 
full-fledged coordination requirements that might allow the utilities to 
paint us into a corner, figuratively speaking, at our original QTHes.

We need to make a strong case that hams are able to identify and keep 1 km 
(or other specified distance) away from transmission lines.  This also 
relates to comments the FCC seeks in par. 176: "Amateur licensees will have 
to determine the location of transmission lines in their vicinity to 
determine if they are permitted to operate stations using these frequency 
bands. .... High voltage transmission lines are typically attached to large 
steel towers that are easy to identity. However, lower voltage transmission 
lines are typically attached to wooden poles. Although the wooden poles used 
for transmission lines are usually taller than the wooden poles used for 
distribution lines, we recognize that distinguishing the two types may not 
always be straightforward. We seek comment on whether amateur licensees will 
be able to identify the transmission lines in their locality."

Obviously, just glancing around from a proposed operation location and 
saying, "nope, I don't see a transmission line from here" is not enough. 
But I think we're smart enough to do responsible surveys of all lines within 
a mile or so in all directions, identify any substation locations, and tell 
which poles have customer connections (practically the definition of 
distribution lines) and which don't (assumed to be transmission lines).  We 
need to convince the FCC that we can tell the difference.

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