While I also welcome thinking out of the box, as a practical matter, the users of the primary services at 136 and 475 kHz would never consent to PLC being accommodated anywhere other than Part 15. Positioning this issue is going to be one of the more challenging tasks for those of us drafting this. My initial thinking is that we should (rightly) call fixed-only operation and advance coordination an unprecedented accommodation of an application that, by rule, is not entitled to protection. It's a practical reality that we have to make such an accommodation to win, but we don't have use the word "protection" in doing so. 73 de Brennan YO/N4QX Sent from my BlackBerry 10 smartphone on the Verizon Wireless 4G LTE network. From: Imlay, Chris, W3KD Sent: Monday, July 6, 2015 16:51 To: Williams, Dale, WA8EFK Cc: Carlson, Kermit, W9XA; arrl-odv Subject: [arrl-odv:24418] Re: LF and MF Docket 15-99 Thinking out of the box is good, Dale. But let me ask you how that would work: PLCs operate under Part 15 throughout the LF and low MF range. If we were to ask that those which operate in the 135 kHz segment that we are asking for access to be licensed (temporarily) under Part 90 (which is land mobile service rules rather than fixed service rules) what would we propose for the regulatory paradigm for the remainder of the LF and MF PLCs? It seems to me that we don't want to create, even temporarily, regulatory parity with PLCs in any segment, much less risk having them elevated to an allocated, licensed service across the entire LF and low MF range. Recall that one of our biggest fears in the BPL docket was that BPL might be elevated to a licensed service. Fortunately, FCC didn't go there. I don't know what the chances are of carving out (for purposes of establishing a sunset date) the tiny 135 kHz segment that we want but FCC is not used to regulating one segment of PLC by one set of service rules and to create an allocation for them and leave the surrounding segment as Part 15 unlicensed systems. 73, Chris W3KD On Mon, Jul 6, 2015 at 9:03 AM, Dale Williams <dale.wms1@frontier.com<mailto:dale.wms1@frontier.com>> wrote: I must agree with Kermit's conclusion about the PLC vs Part 15 use of 137 kHz. We are unlikely to win a battle with the utilities. Perhaps this is a little out-of-the-box, but could we consider a modification to the Part 90 rules and amend the Power Radio Pool to allow continued use of the existing 137 kHz systems for another 10-15 years on a non-renewable basis? In other words, the FCC adds 137 kHz to the Part 90 radio service Power frequencies (IW) on a shared shared basis, using the existing Part 15 emission limits, and for a time limited period. This allows the use of the frequency until the utilities can transition to fiber, eliminates the conflict about creating an undesired precedent in Part 15, and sets an end date to the frequency sharing with the Amateur Service This could be done in conjunction with the authorization of 137 kHz to the Amateur Service. (OK, so it is a lot out-of-the-box) 73, Dale WA8EFK On 7/5/2015 11:02 PM, Kermit Carlson via arrl-odv wrote: Hello Greg et al; I have just returned to the land of reliable connectivity and have just read Greg's comment on Docket 15-99. There are four main components of Docket 15-99 that affects amateur 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 that would favor our interest; and the addition of two new bands at 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 number was 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 conjunction with 1-watt ERP to present a signal, coupled into the lines in a configuration allowing maximum strength which to the PLC system would have less signal strength than the system noise floor of the PLC system on the transmission line established in adverse weather conditions. In other words, it is a fact of engineering that an amateur transmitter with 1-watt ERP at 1 km cannot 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. The second related limitation would be to limit vertical antennas to 200 ft, here again, the maximum radiated field would present an ERP in the range of 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 coordination is 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 require protection based in the science of the coupling to the PLC systems from external fields and/or coordination for amateur operation at close-spaced distances. It would be optimal to see the power-line industry give way on these two small slices of spectrum for 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 spectrum sharing, 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 PLC operations 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><mailto:gpwidin@comcast.net> To: Christopher Imlay <w3kd.arrl@gmail.com><mailto:w3kd.arrl@gmail.com> Cc: arrl-odv <arrl-odv@arrl.org><mailto: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<mailto: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. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG> _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG>