Hello Greg et al; I have just returned to the land of reliable connectivity andhave just read Greg's comment on Docket 15-99. There are four main components of Docket 15-99 that affectsamateur radio. - the return to primary status for a portion of 160, which is very welcome ; the 160 meter sharing with the unlicensed fishnet buoys,which is troubling and probably without a realizable solution thatwould favor our interest; and the addition of two new bandsat 497 kHz and 137 kHz. There are a number of comments already on file with the FCC - all of them in favor with some comments, by amateurs with 137 kHz experience, giving good evidence that close spacing to PLC equipped transmission lines is definitely possible at distances closer than one kilometer. That numberwas arrived in the paper that was authored by myself and a few others, referenced in the League's filing two years ago as Appendix A. In that paper the 1-km distance was used in conjunctionwith 1-watt ERP to present a signal, coupled into the lines in a configurationallowing maximum strength which to the PLC system would haveless signal strength than the system noise floor of the PLC system on the transmissionline established in adverse weather conditions. In other words, it is a fact of engineering that an amateur transmitter with 1-watt ERP at 1 kmcannot cause interference to the PLC system. Two other methods of limiting the field were also mentioned in the paper. The first was 1 kw transmitter output power since the maximum field can be related power gain of an amateur transmitting antenna of -21 (that is minus 21 dB), most amateurs will be hard pressed to exceed that efficiency at 137 kHz. Thesecond related limitation would be to limit vertical antennas to 200 ft, hereagain, the maximum radiated field would present an ERP in the rangeof about 1 watt ERP. Greg, although I agree that PLC would be a non-licensed co-user of the spectrum, the level of public need and interest in protecting the use of those frequencies by the power-line companies for control and breaker coordinationis significant. If amateurs are to gain access to these two new bands we amateurs will need to make a solid case that amateur operation will not interfere with the ongoing use of those frequencies for PLC applications (albiet, for non-radiated purposes and uses). I would suggest that an outright opposition to obtaining access to two new amateur bands is not in the interest to amateur radio, even with given a need of protection to a class of unlicensed incumbent users. In the real world, some relay control and relay veto control will continue on the LF&MF PLC systems for the forseeable future, but the vast majority of modernized systems appear to be designed around fiber-optic pathways that are being installed in the center of the over-head grounding conductor. The LF and MF PLC use may eventually phased out, but while PLC is in use it will requireprotection based in the science of the coupling to the PLC systems from externalfields and/or coordination for amateur operation at close-spaced distances. It would beoptimal to see the power-line industry give way on these two small slices of spectrumfor amateur use entirely and exclusively, but that is highly unlikely. I would ask you to reconsider an all-out objection to the Docket based on spectrumsharing, especially considering the unusual nature of the situation. This is not a typical group of Part-15 incumbent users and without some degree of administrative protection to PLCoperations amateur radio access to those slices of spectrum is unlikely. I hope you can see that gaining the two new bands is really not coupled to setting a precedence for amateurs protection Part 15 devices. 73, Kermit W9XA From: G Widin <gpwidin@comcast.net> To: Christopher Imlay <w3kd.arrl@gmail.com> Cc: arrl-odv <arrl-odv@arrl.org> Sent: Thursday, July 2, 2015 11:18 AM Subject: [arrl-odv:24403] Re: LF and MF Docket 15-99 Chris, I skimmed your document, and in any case, I'm not qualified to provide an opinion on most of your questions. The question of buoys in 1.9-2.0 MHz is reminiscent of the CB Radio debacle, where a blatantly unenforceable situation is created on the supposition that the new users will be compliant. We know they won't be, but FCC has no means by which to ensure compliance, so it creates a new Wild West of radio in the top half of the 160m band. However, my biggest concern (which I didn't see you mention, perhaps because it has been dealt with in other filings), is that PLC, a Part 15 service, is afforded protection against a licensed service, viz. Amateur Radio. I think we have been seeing this in other services, but if this is the first NPRM to explicitly extend this protection to Part 15, I think we should strenuously oppose it. Maybe we should oppose it again, even if we have already. I don't need to say much more. I know that you are well aware of the latter issue. 73, Greg, K0GW On Thu, Jul 2, 2015 at 9:16 AM, Christopher Imlay <w3kd.arrl@gmail.com> wrote: Greetings. Attached is a memo I sent early in June to the Executive Committee and, I believe, at President Craigie's request I circulated it to the entire Board, soliciting input. Not having received much, and because the Federal Register publication of this very important NPRM is now complete and we have an August 31 comment date, President Craigie asked that we remind you that your input on this subject is welcome. The attached memo lists issues that are to be resolved by FCC. There is time to discuss this at the upcoming Board meeting if necessary but the policy issues seem clear and we want to get the draft of comments going in plenty of time for review, editing and filing. So let's hear from you about the specifics of this, folks. Thanks. 73, Chris W3KD -- Christopher D. ImlayBooth, Freret & Imlay, LLC14356 Cape May RoadSilver Spring, Maryland 20904-6011(301) 384-5525 telephone(301) 384-6384 facsimileW3KD@ARRL.ORG _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv