[arrl-odv:24410] LF and MF Docket 15-99-Comments
Chris, Like Greg, I do not feel qualified to fully respond to this memo, as I do not have the technical acumen to do so. I also share his concern about how a part 15 unlicensed service should be protected from a licensed service. This appears to go against the entire premise of part 15. I would not want to open a “can of worms” to ask the FCC to make this situation consistent with their rules, as we know that didn’t work in the past, and would probably backfire. Starting with our elevation to primary status on the 1900-2000 kHz band, bravo. In terms of these licensed/unlicensed/not appropriately licensed buoys, it looks like there are several opportunities. Interestingly, if the FCC decides to give them a 100 kHz allocation in the MF range (not ours!) and let the current grandfathered buoys be removed as they age, become defective, and are removed from service, that is a win-win. It won’t be immediate, but in the long run, would be a good thing for amateur radio. I think we should encourage the FCC to proceed along this route. I’m not sure if that will be acceptable to the company who wants more bandwidth, but even EPIRBs have gone digital, so there is a possibility for more effective use of spectrum by the buoys. If MF is the way to go and our 472-479 kHz frequencies are not affected, the PLC’s would have to push for regulation of the buoys when near land, rather than us. I don’t know about how far the ships are away from the buoys, but the characteristics of MF on the ocean are apparently the same night and day, Winter and Summer. I would think this would be a plus, although there will most likely be push-back from the manufacturer due to design changes. If 1900-2000 kHz for the buoys is ultimately decided upon, we have to be fairly direct as to limiting power limits of the buoys near land. I know we have to aggressively combat any encroachment on our bands, but I wonder how much of a problem exists in the 1900-2000 kHz segment currently. Most of my 160 operation is on the lower part of the 1800-1900 kHz segment, so I have very little personal experience. Now to the LF and MF allocations proposed for us. I think it goes without saying that the FCC is trying to have every question answered, so that they can develop rules that will not require their future intervention at all. Comments from the PLC will be overly restrictive, and hopefully ours will “push the envelope” so that over regulation will not discourage our use of the bands. The separation distance is one example of a deal-killer. We did specify a 1 km distance in the past when we were “reaching” for the FCC to think about allocating the spectrum. Now that they have come forward to offer, is a 1 km distance even necessary? What would happen at 0.5 km? As far as power, due to inefficiency in that area of the spectrum, 1 watt may be the maximum obtainable. However, according to the memo, we have experimental evidence up to 20 W ERP. We should look to see if the experimental licenses “broke” any PLC system, and use whatever information we receive to our benefit. Although I don’t remember this type of wording in FCC rules, could there be an automatic increase in power or decrease in distance over a set time period in the absence of interference documentation? After initial implementation, could the power level be increased by a set number of watts ERP/year absent of interference complaints? Regardless, I would expect the PLC carriers to produce documentation as to the location of their power lines that would be affected, perhaps via a web application, searchable by address. There might be a push-back from them in regards to security/terrorism concerns. I would think, then, that they could provide the information to ARRL HQ that would allow cross-checking of a QTH that might fall in within whatever distance that is finally indicated by the FCC. The easiest solution is for the PLC to avoid our future frequencies entirely, which would lead to more expansive use of the new bands, allow more power and not have to deal with distance requirements. From what Chris has told us, the 472-479 kHz band should not be a problem due to very few PLC systems in that region. As far as 135.7-137.8 kHz, that is a whopping 2.1 kHz. I don’t know if a guard band is necessary, but over time, can the FCC restrict those few kHz to amateur only, and have a progression time wise to moving PLC out of that narrow frequency range? So, those are a few thoughts, and may be very naïve in terms of content. In the end, I believe the FCC is in the “set and forget” mode, where they desire to set up the rules to be self-sustaining, and require minimal to no intervention on their part in the future. I would think the easiest path would be for them to move the beacons to MF, outside of our allocations, and move the PLC unlicensed part 15 systems out of our anticipated bands, with appropriate guard bands, if necessary. Minimal to no regulation would be required of them in this scenario. That may be dreaming, however. I am very interested in the new frequencies, and have a lot of reading to do. I live on a city lot which will be somewhat restrictive, though. I have the first edition of “LF Today” published by the RSGB, and have just ordered the current 3rd edition from our bookstore which discusses 472-479 KHz in addition to the 135.7-137.8 kHz bands. I have radios that will be able to use those bands, with appropriate amplifiers and probably loop antennas. ’73 de JIM N2ZZ Director – Roanoke Division Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections ARRL – The National Association for Amateur Radio™ From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Thursday, July 02, 2015 10:17 AM To: arrl-odv Subject: [arrl-odv:24398] LF and MF Docket 15-99 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
Jim, thanks to you and Greg for the very helpful and thoughtful input. This is precisely what we need and I am grateful for it. Ed Hare and Brennan Price and Dave Sumner and I will be putting a draft together early on after the Board meeting, and this is the kind of input that helps us be sure that we are not missing anything. It is clear to me that we have to be careful in our discussion in the comments about protecting Part 15 devices. The normal paradigm that Part 15 devices are not protected from interference from licensed radio services certainly enough is the law where Part 15 devices are deployed in a band in which the licensed service already has an allocation. But as we found out the last time we sought a LF allocation, FCC is not going to just ignore widespread deployment of Part 15 devices where a new licensed service is asking for an allocation for the first time. This causes FCC some conceptual angst because they don't want to elevate unlicensed RF devices to any sort of allocation status but at the same time they can't simply ignore the fact that there are significant (though not specifically determined) numbers of PLC systems in use that, for better or worse, contribute to the regulation of the power grid. So as the newcomer, we can't just say "well, they are Part 15 devices so therefore they have to be ignored". For FCC to accept that could potentially be to create an interference problem that doesn't now exist. That is why this somewhat tedious NPRM is revisiting the same issues that were on the table in comments on our Petitions. And you make good points on the buoys as well. That is a bit of a double cross, it seems to me because they have been illegally operated and marketed for years. That too requires extensive discussion in our comments. While I consider this docket to be a big win (so far) we have to do a good job to bring home* all* of the bacon that is being dangled in front of us. Again, thanks to you and Greg for great input. 73, Chris W3KD On Fri, Jul 3, 2015 at 10:20 PM, James F. Boehner MD <jboehner01@yahoo.com> wrote:
Chris,
Like Greg, I do not feel qualified to fully respond to this memo, as I do not have the technical acumen to do so. I also share his concern about how a part 15 unlicensed service should be protected from a licensed service. This appears to go against the entire premise of part 15. I would not want to open a “can of worms” to ask the FCC to make this situation consistent with their rules, as we know that didn’t work in the past, and would probably backfire.
Starting with our elevation to primary status on the 1900-2000 kHz band, bravo. In terms of these licensed/unlicensed/not appropriately licensed buoys, it looks like there are several opportunities. Interestingly, if the FCC decides to give them a 100 kHz allocation in the MF range (not ours!) and let the current grandfathered buoys be removed as they age, become defective, and are removed from service, that is a win-win. It won’t be immediate, but in the long run, would be a good thing for amateur radio. I think we should encourage the FCC to proceed along this route. I’m not sure if that will be acceptable to the company who wants more bandwidth, but even EPIRBs have gone digital, so there is a possibility for more effective use of spectrum by the buoys. If MF is the way to go and our 472-479 kHz frequencies are not affected, the PLC’s would have to push for regulation of the buoys when near land, rather than us.
I don’t know about how far the ships are away from the buoys, but the characteristics of MF on the ocean are apparently the same night and day, Winter and Summer. I would think this would be a plus, although there will most likely be push-back from the manufacturer due to design changes.
If 1900-2000 kHz for the buoys is ultimately decided upon, we have to be fairly direct as to limiting power limits of the buoys near land.
I know we have to aggressively combat any encroachment on our bands, but I wonder how much of a problem exists in the 1900-2000 kHz segment currently. Most of my 160 operation is on the lower part of the 1800-1900 kHz segment, so I have very little personal experience.
Now to the LF and MF allocations proposed for us. I think it goes without saying that the FCC is trying to have every question answered, so that they can develop rules that will not require their future intervention at all. Comments from the PLC will be overly restrictive, and hopefully ours will “push the envelope” so that over regulation will not discourage our use of the bands.
The separation distance is one example of a deal-killer. We did specify a 1 km distance in the past when we were “reaching” for the FCC to think about allocating the spectrum. Now that they have come forward to offer, is a 1 km distance even necessary? What would happen at 0.5 km? As far as power, due to inefficiency in that area of the spectrum, 1 watt may be the maximum obtainable. However, according to the memo, we have experimental evidence up to 20 W ERP. We should look to see if the experimental licenses “broke” any PLC system, and use whatever information we receive to our benefit.
Although I don’t remember this type of wording in FCC rules, could there be an automatic increase in power or decrease in distance over a set time period in the absence of interference documentation? After initial implementation, could the power level be increased by a set number of watts ERP/year absent of interference complaints?
Regardless, I would expect the PLC carriers to produce documentation as to the location of their power lines that would be affected, perhaps via a web application, searchable by address. There might be a push-back from them in regards to security/terrorism concerns. I would think, then, that they could provide the information to ARRL HQ that would allow cross-checking of a QTH that might fall in within whatever distance that is finally indicated by the FCC.
The easiest solution is for the PLC to avoid our future frequencies entirely, which would lead to more expansive use of the new bands, allow more power and not have to deal with distance requirements. From what Chris has told us, the 472-479 kHz band should not be a problem due to very few PLC systems in that region. As far as 135.7-137.8 kHz, that is a whopping 2.1 kHz. I don’t know if a guard band is necessary, but over time, can the FCC restrict those few kHz to amateur only, and have a progression time wise to moving PLC out of that narrow frequency range?
So, those are a few thoughts, and may be very naïve in terms of content. In the end, I believe the FCC is in the “set and forget” mode, where they desire to set up the rules to be self-sustaining, and require minimal to no intervention on their part in the future. I would think the easiest path would be for them to move the beacons to MF, outside of our allocations, and move the PLC unlicensed part 15 systems out of our anticipated bands, with appropriate guard bands, if necessary. Minimal to no regulation would be required of them in this scenario. That may be dreaming, however.
I am very interested in the new frequencies, and have a lot of reading to do. I live on a city lot which will be somewhat restrictive, though. I have the first edition of “LF Today” published by the RSGB, and have just ordered the current 3rd edition from our bookstore which discusses 472-479 KHz in addition to the 135.7-137.8 kHz bands. I have radios that will be able to use those bands, with appropriate amplifiers and probably loop antennas.
’73 de JIM N2ZZ
Director – Roanoke Division
*Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections*
*ARRL – The National Association for Amateur Radio™*
*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] *On Behalf Of *Christopher Imlay *Sent:* Thursday, July 02, 2015 10:17 AM *To:* arrl-odv *Subject:* [arrl-odv:24398] LF and MF Docket 15-99
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
-- 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
Just to clarify, and in response to Kermit's well-reasoned and well-articulated note, when I raised the Part 15 issue, I was in no way suggesting that we shouldn't accept a new allocation because of that. Chris's point about whether there is an incumbent licensed service vs. a new added service is very important here, and it is plain that the practicalities of the situation make it impossible to displace the PLC folks. That said, we can't just ignore a cavalier attitude by the Commission toward conferring rights on Part 15 users. From Chris' e-mail, I am convinced that our response will be suitably forthright on that point. 73, Greg, K0GW On Monday, July 6, 2015, Christopher Imlay <w3kd.arrl@gmail.com> wrote:
Jim, thanks to you and Greg for the very helpful and thoughtful input. This is precisely what we need and I am grateful for it. Ed Hare and Brennan Price and Dave Sumner and I will be putting a draft together early on after the Board meeting, and this is the kind of input that helps us be sure that we are not missing anything.
It is clear to me that we have to be careful in our discussion in the comments about protecting Part 15 devices. The normal paradigm that Part 15 devices are not protected from interference from licensed radio services certainly enough is the law where Part 15 devices are deployed in a band in which the licensed service already has an allocation. But as we found out the last time we sought a LF allocation, FCC is not going to just ignore widespread deployment of Part 15 devices where a new licensed service is asking for an allocation for the first time. This causes FCC some conceptual angst because they don't want to elevate unlicensed RF devices to any sort of allocation status but at the same time they can't simply ignore the fact that there are significant (though not specifically determined) numbers of PLC systems in use that, for better or worse, contribute to the regulation of the power grid. So as the newcomer, we can't just say "well, they are Part 15 devices so therefore they have to be ignored". For FCC to accept that could potentially be to create an interference problem that doesn't now exist. That is why this somewhat tedious NPRM is revisiting the same issues that were on the table in comments on our Petitions.
And you make good points on the buoys as well. That is a bit of a double cross, it seems to me because they have been illegally operated and marketed for years. That too requires extensive discussion in our comments. While I consider this docket to be a big win (so far) we have to do a good job to bring home* all* of the bacon that is being dangled in front of us.
Again, thanks to you and Greg for great input.
73, Chris W3KD
On Fri, Jul 3, 2015 at 10:20 PM, James F. Boehner MD <jboehner01@yahoo.com <javascript:_e(%7B%7D,'cvml','jboehner01@yahoo.com');>> wrote:
Chris,
Like Greg, I do not feel qualified to fully respond to this memo, as I do not have the technical acumen to do so. I also share his concern about how a part 15 unlicensed service should be protected from a licensed service. This appears to go against the entire premise of part 15. I would not want to open a “can of worms” to ask the FCC to make this situation consistent with their rules, as we know that didn’t work in the past, and would probably backfire.
Starting with our elevation to primary status on the 1900-2000 kHz band, bravo. In terms of these licensed/unlicensed/not appropriately licensed buoys, it looks like there are several opportunities. Interestingly, if the FCC decides to give them a 100 kHz allocation in the MF range (not ours!) and let the current grandfathered buoys be removed as they age, become defective, and are removed from service, that is a win-win. It won’t be immediate, but in the long run, would be a good thing for amateur radio. I think we should encourage the FCC to proceed along this route. I’m not sure if that will be acceptable to the company who wants more bandwidth, but even EPIRBs have gone digital, so there is a possibility for more effective use of spectrum by the buoys. If MF is the way to go and our 472-479 kHz frequencies are not affected, the PLC’s would have to push for regulation of the buoys when near land, rather than us.
I don’t know about how far the ships are away from the buoys, but the characteristics of MF on the ocean are apparently the same night and day, Winter and Summer. I would think this would be a plus, although there will most likely be push-back from the manufacturer due to design changes.
If 1900-2000 kHz for the buoys is ultimately decided upon, we have to be fairly direct as to limiting power limits of the buoys near land.
I know we have to aggressively combat any encroachment on our bands, but I wonder how much of a problem exists in the 1900-2000 kHz segment currently. Most of my 160 operation is on the lower part of the 1800-1900 kHz segment, so I have very little personal experience.
Now to the LF and MF allocations proposed for us. I think it goes without saying that the FCC is trying to have every question answered, so that they can develop rules that will not require their future intervention at all. Comments from the PLC will be overly restrictive, and hopefully ours will “push the envelope” so that over regulation will not discourage our use of the bands.
The separation distance is one example of a deal-killer. We did specify a 1 km distance in the past when we were “reaching” for the FCC to think about allocating the spectrum. Now that they have come forward to offer, is a 1 km distance even necessary? What would happen at 0.5 km? As far as power, due to inefficiency in that area of the spectrum, 1 watt may be the maximum obtainable. However, according to the memo, we have experimental evidence up to 20 W ERP. We should look to see if the experimental licenses “broke” any PLC system, and use whatever information we receive to our benefit.
Although I don’t remember this type of wording in FCC rules, could there be an automatic increase in power or decrease in distance over a set time period in the absence of interference documentation? After initial implementation, could the power level be increased by a set number of watts ERP/year absent of interference complaints?
Regardless, I would expect the PLC carriers to produce documentation as to the location of their power lines that would be affected, perhaps via a web application, searchable by address. There might be a push-back from them in regards to security/terrorism concerns. I would think, then, that they could provide the information to ARRL HQ that would allow cross-checking of a QTH that might fall in within whatever distance that is finally indicated by the FCC.
The easiest solution is for the PLC to avoid our future frequencies entirely, which would lead to more expansive use of the new bands, allow more power and not have to deal with distance requirements. From what Chris has told us, the 472-479 kHz band should not be a problem due to very few PLC systems in that region. As far as 135.7-137.8 kHz, that is a whopping 2.1 kHz. I don’t know if a guard band is necessary, but over time, can the FCC restrict those few kHz to amateur only, and have a progression time wise to moving PLC out of that narrow frequency range?
So, those are a few thoughts, and may be very naïve in terms of content. In the end, I believe the FCC is in the “set and forget” mode, where they desire to set up the rules to be self-sustaining, and require minimal to no intervention on their part in the future. I would think the easiest path would be for them to move the beacons to MF, outside of our allocations, and move the PLC unlicensed part 15 systems out of our anticipated bands, with appropriate guard bands, if necessary. Minimal to no regulation would be required of them in this scenario. That may be dreaming, however.
I am very interested in the new frequencies, and have a lot of reading to do. I live on a city lot which will be somewhat restrictive, though. I have the first edition of “LF Today” published by the RSGB, and have just ordered the current 3rd edition from our bookstore which discusses 472-479 KHz in addition to the 135.7-137.8 kHz bands. I have radios that will be able to use those bands, with appropriate amplifiers and probably loop antennas.
’73 de JIM N2ZZ
Director – Roanoke Division
*Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections*
*ARRL – The National Association for Amateur Radio™*
*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org <javascript:_e(%7B%7D,'cvml','arrl-odv-bounces@reflector.arrl.org');>] *On Behalf Of *Christopher Imlay *Sent:* Thursday, July 02, 2015 10:17 AM *To:* arrl-odv *Subject:* [arrl-odv:24398] LF and MF Docket 15-99
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 <javascript:_e(%7B%7D,'cvml','W3KD@ARRL.ORG');>
-- 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 <javascript:_e(%7B%7D,'cvml','W3KD@ARRL.ORG');>
Hello Greg - Thank you, I am likewise concerned about the Commission'sregulatory treatment of fishnet buoys in the same manner as theCB "deregulation". It seems that although the US cannot regulatethe operation of the fishnet buoy operation on the high seas, theycertainly can regulate stateside manufacturing, marketing, importation and sales. It is really a sad state of affairs when the Commissionreacts to illegal spectrum usage in a compliant manner. http://snlcorp.com/SNL/CommercialTackle/radiobuoys.aspxhttp://commercialfish.... 73, Kermit W9XA From: G Widin <gpwidin@comcast.net> To: Christopher Imlay <w3kd.arrl@gmail.com> Cc: arrl-odv <arrl-odv@arrl.org> Sent: Monday, July 6, 2015 10:06 AM Subject: [arrl-odv:24422] Re: LF and MF Docket 15-99-Comments Just to clarify, and in response to Kermit's well-reasoned and well-articulated note, when I raised the Part 15 issue, I was in no way suggesting that we shouldn't accept a new allocation because of that. Chris's point about whether there is an incumbent licensed service vs. a new added service is very important here, and it is plain that the practicalities of the situation make it impossible to displace the PLC folks. That said, we can't just ignore a cavalier attitude by the Commission toward conferring rights on Part 15 users. From Chris' e-mail, I am convinced that our response will be suitably forthright on that point.73, Greg, K0GW On Monday, July 6, 2015, Christopher Imlay <w3kd.arrl@gmail.com> wrote: Jim, thanks to you and Greg for the very helpful and thoughtful input. This is precisely what we need and I am grateful for it. Ed Hare and Brennan Price and Dave Sumner and I will be putting a draft together early on after the Board meeting, and this is the kind of input that helps us be sure that we are not missing anything. It is clear to me that we have to be careful in our discussion in the comments about protecting Part 15 devices. The normal paradigm that Part 15 devices are not protected from interference from licensed radio services certainly enough is the law where Part 15 devices are deployed in a band in which the licensed service already has an allocation. But as we found out the last time we sought a LF allocation, FCC is not going to just ignore widespread deployment of Part 15 devices where a new licensed service is asking for an allocation for the first time. This causes FCC some conceptual angst because they don't want to elevate unlicensed RF devices to any sort of allocation status but at the same time they can't simply ignore the fact that there are significant (though not specifically determined) numbers of PLC systems in use that, for better or worse, contribute to the regulation of the power grid. So as the newcomer, we can't just say "well, they are Part 15 devices so therefore they have to be ignored". For FCC to accept that could potentially be to create an interference problem that doesn't now exist. That is why this somewhat tedious NPRM is revisiting the same issues that were on the table in comments on our Petitions. And you make good points on the buoys as well. That is a bit of a double cross, it seems to me because they have been illegally operated and marketed for years. That too requires extensive discussion in our comments. While I consider this docket to be a big win (so far) we have to do a good job to bring home all of the bacon that is being dangled in front of us. Again, thanks to you and Greg for great input. 73, Chris W3KD On Fri, Jul 3, 2015 at 10:20 PM, James F. Boehner MD <jboehner01@yahoo.com> wrote: Chris, Like Greg, I do not feel qualified to fully respond to this memo, as I do not have the technical acumen to do so. I also share his concern about how a part 15 unlicensed service should be protected from a licensed service. This appears to go against the entire premise of part 15. I would not want to open a “can of worms” to ask the FCC to make this situation consistent with their rules, as we know that didn’t work in the past, and would probably backfire. Starting with our elevation to primary status on the 1900-2000 kHz band, bravo. In terms of these licensed/unlicensed/not appropriately licensed buoys, it looks like there are several opportunities. Interestingly, if the FCC decides to give them a 100 kHz allocation in the MF range (not ours!) and let the current grandfathered buoys be removed as they age, become defective, and are removed from service, that is a win-win. It won’t be immediate, but in the long run, would be a good thing for amateur radio. I think we should encourage the FCC to proceed along this route. I’m not sure if that will be acceptable to the company who wants more bandwidth, but even EPIRBs have gone digital, so there is a possibility for more effective use of spectrum by the buoys. If MF is the way to go and our 472-479 kHz frequencies are not affected, the PLC’s would have to push for regulation of the buoys when near land, rather than us. I don’t know about how far the ships are away from the buoys, but the characteristics of MF on the ocean are apparently the same night and day, Winter and Summer. I would think this would be a plus, although there will most likely be push-back from the manufacturer due to design changes. If 1900-2000 kHz for the buoys is ultimately decided upon, we have to be fairly direct as to limiting power limits of the buoys near land. I know we have to aggressively combat any encroachment on our bands, but I wonder how much of a problem exists in the 1900-2000 kHz segment currently. Most of my 160 operation is on the lower part of the 1800-1900 kHz segment, so I have very little personal experience. Now to the LF and MF allocations proposed for us. I think it goes without saying that the FCC is trying to have every question answered, so that they can develop rules that will not require their future intervention at all. Comments from the PLC will be overly restrictive, and hopefully ours will “push the envelope” so that over regulation will not discourage our use of the bands. The separation distance is one example of a deal-killer. We did specify a 1 km distance in the past when we were “reaching” for the FCC to think about allocating the spectrum. Now that they have come forward to offer, is a 1 km distance even necessary? What would happen at 0.5 km? As far as power, due to inefficiency in that area of the spectrum, 1 watt may be the maximum obtainable. However, according to the memo, we have experimental evidence up to 20 W ERP. We should look to see if the experimental licenses “broke” any PLC system, and use whatever information we receive to our benefit. Although I don’t remember this type of wording in FCC rules, could there be an automatic increase in power or decrease in distance over a set time period in the absence of interference documentation? After initial implementation, could the power level be increased by a set number of watts ERP/year absent of interference complaints? Regardless, I would expect the PLC carriers to produce documentation as to the location of their power lines that would be affected, perhaps via a web application, searchable by address. There might be a push-back from them in regards to security/terrorism concerns. I would think, then, that they could provide the information to ARRL HQ that would allow cross-checking of a QTH that might fall in within whatever distance that is finally indicated by the FCC. The easiest solution is for the PLC to avoid our future frequencies entirely, which would lead to more expansive use of the new bands, allow more power and not have to deal with distance requirements. From what Chris has told us, the 472-479 kHz band should not be a problem due to very few PLC systems in that region. As far as 135.7-137.8 kHz, that is a whopping 2.1 kHz. I don’t know if a guard band is necessary, but over time, can the FCC restrict those few kHz to amateur only, and have a progression time wise to moving PLC out of that narrow frequency range? So, those are a few thoughts, and may be very naïve in terms of content. In the end, I believe the FCC is in the “set and forget” mode, where they desire to set up the rules to be self-sustaining, and require minimal to no intervention on their part in the future. I would think the easiest path would be for them to move the beacons to MF, outside of our allocations, and move the PLC unlicensed part 15 systems out of our anticipated bands, with appropriate guard bands, if necessary. Minimal to no regulation would be required of them in this scenario. That may be dreaming, however. I am very interested in the new frequencies, and have a lot of reading to do. I live on a city lot which will be somewhat restrictive, though. I have the first edition of “LF Today” published by the RSGB, and have just ordered the current 3rd edition from our bookstore which discusses 472-479 KHz in addition to the 135.7-137.8 kHz bands. I have radios that will be able to use those bands, with appropriate amplifiers and probably loop antennas. ’73 de JIM N2ZZDirector – Roanoke DivisionServing ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sectionsARRL – The National Association for Amateur Radio™ From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Thursday, July 02, 2015 10:17 AM To: arrl-odv Subject: [arrl-odv:24398] LF and MF Docket 15-99 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 -- 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
participants (4)
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Christopher Imlay -
G Widin -
James F. Boehner MD -
Kermit Carlson