[Lowfer] NPRM Filings Done

[JD]

Unless there are any paper filings yet to convert to PDF files, the public 
record in the LF/MF rulemaking proceeding is now complete.

As many observers expected, Utilities Telecom Council waited until the last 
possible second to file a Reply.  I can testify to that because one of my 
own was literally in the last possible minute, and theirs was received after 
mine.  Mine was nearly late because I am a slow typist on tiny modern 
keyboards, not because I wanted to get the last word...or tell fibs that no 
one would then have the opportunity to contradict.  I'm not saying that they 
did that, exactly, but I expect they must be experiencing some warmth in the 
trouser region today, or at least some nasal swelling.

And that nose would be camel-shaped as viewed from a tent flap, because they 
took the opportunity to introduce some topics that properly belonged in 
their original Comments on the FCC notice, where they could have been 
commented upon.  One example: Their so-called "reply" was the first mention 
by any respondent in the proceeding to the FCC's question about possible 
future use of PLC-like apparatus on _distribution_ lines, rather than 
transmission lines which already have special status under Part 15.  That 
shouldn't have even been part of this proceeding, but the FCC brought it up, 
so it would have been fair game in original comments...but not a reply, 
since no one else had mentioned it since that time.

Also, it was the first time they outlined their concept of what 
amateur-industry coordination should be like.  This too was improper, 
because it should have been in their original comments.  Basically, they 
want to REQUIRE coordination before any and all amateur LF operation from a 
new location--and WITHOUT any deadline for a response.  We decline to 
respond, you don't get to go on the air.  Problem solved.

How does that constitute spectrum "sharing?"  Alas, we don't get a chance to 
ask that formally now, so we will have to trust the FCC to sort it all out.

If you've safely digested lunch now, you can read the UTC reply and all 
others posted to date at the FCC ECFS page, or at 
http://lwca.org/Docket15-99 as well.

John 
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