[Lowfer] Enabling Smart-Grid Communications in Rural Regions

[JD]

>>> Is PLC being revived??

Yes.  This is the real reason the utilities still absolutely oppose any 
amateur allocation at 630 meters.  Existing PLC usage on transmission lines 
is a smokescreen, a red herring, the camel's nose in the tent with all this 
new RF pollution waiting to sneak its way in to our neighborhoods on 
DISTRIBUTION lines.

They were very underhanded in the current proceeding.  In their initial 
comments, UTC made no reference at all to two very important issues: the 
nature of coordination as they envisioned it, and the impact of allocations 
on "smart grid" applications.  They studiously avoided any mention beyond 
acknowledging that the FCC had asked about them.  Instead, they improperly 
waited until the end of the reply period to put forth their ideas, so no one 
could comment upon them.  J'accuse!

If you haven't read the UTC reply filing, you need to...and read ever so 
slightly between the lines, because it's all in there.  While nominally 
paying lip service to the proposed 1 W EIRP/200 ft antenna cap/1 km 
separation distance, they turn around and make a mockery of that framework 
by insisting that coordination with the utilities should be required of 
_all_ new amateur LF installations, not just ones that are of questionable 
spacing. More than that, they insist there should be no time limit on their 
decision, and no operation until they have rendered that decision. 
J'accuse!

They took great pains to set up a straw man, faulting ARRL's analysis for 
supposedly ignoring latency concerns, and emphasizing how critical that is 
for protection of TRANSMISSION lines...which increasingly DON'T rely on PLC 
because of that very concern...but then turned around and applied that 
reasoning as an excuse for holding up any action at 630 m there's no track 
record of coexistence there.  Ludicrous on the face of it.  But when you 
read their reply comments closely, you realize they're actually talking 
about NEW "smart grid" systems on DISTRIBUTION lines, which supposedly are 
covered by all current Part 15 restrictions.  But they don't want them to be 
thus limited.  J'accuse!

That latter point is the real reason for their desire to have PLC systems 
(from context, evidently ALL of them, not just the existing transmission 
line systems) elevated to the same status as the amateur radio service. 
They claim it's because amateurs could otherwise bump them off "their" band 
by filing interference complaints, but the FCC has already said that's not 
going to be allowed.  First, it's not clear how that elevated status could 
even be achieved without making them an allocated and licensed service; and 
they certainly don't want "outside" regulation from the FCC.  They've 
already been able to keep new users off the band for decades under the 
weight of their existing special status, so why ask for elevated status now? 
Only one possible reason stands out: the anticipated new uses, which they 
sneakily declined to identify as new and/or acknowledge the currently 
limited status thereof under Part 15.  And because they declined to address 
it either in original comments or earlier in the reply period, the rest of 
us have no chance to reply.  J'accuse!

Someone might read UTC's filings and take everything there at face value and 
come away less cynical than I am at the moment.  But you'd have to bury your 
head pretty deeply in the sand not to have suspicions that they were being 
far less than candid in their filings!

Their grudging tone toward 2200m and their insistence on keeping us off 630m 
entirely until they have their new stuff grandfathered in place make it very 
clear that they bear us NO good will whatsoever. Thus, I find it quite 
ironic that the petitioner who was previously urging us all to be so 
conciliatory toward the utilities completely failed to use his own 
late-filed reply to address any of these points.  Can he really still 
believe appeasement will work?

Anyway, it's in the FCC's hands now.  I'm sure the staff see what's going 
on, but the question will be how much of UTC's fearmongering the 
Commissioners are willing to buy into.

John