[600MRG] Special event Nov. 13-14

[Frederick Raab]

June 6, 2015

Gentlemen:

     In filing comments with the FCC, we need to keep
two things in mind:

(1)  It is very important that we get the new band,
even with restrictions.  Ridiculous restrictions can be
removed later much more easily than we can restart the
process for getting a new band.

(2)  The FCC now thinks that amateurs and PLC can
co-exist.  This is a huge change from last time they
considered the 137 kHz band and concluded otherwise.

     Their proposed mechanism for co-existance is

(a)  Making us secondary to PLC so we can't complain and
have to QRT if there is a problem,

(b) A minimum distance (TBD) from the amateur to the line, and

(c) No mobile (portable) operation which would make things
unpredictable.

     My recommendation is that we "play along" with this
approach.  Taking issue with it may make them reconsider.
Ultimately, if we play our cards right, we should have a
band without restrictions and without PLCs in-band.
So here is what I recommend saying in your comments:

(I)  If you are an experimental operator, you could say
something like...  "I have operated WX2XXX sincd 20xx
on xxx to xxx kHz with xx W ERP.  I have made about XX
hours of transmissions.  (If applicable) There is an HV
transmission line only 1 mi from my location.  There
have been ZERO problems to date."  I plan to file
something like this for the WD2XSH stations.

(II)  Any thing you can say about their co-existence
plan that is positive or quantitative, or suggests
workable administrative procedures, how we can avoid
interference, etc.  For example, instead of saying the
distance requirement is ridiculous, tell them why it
should be 1/2 km instead of 1 km.

(III)  Save arguments such as WA1ZMS and I have made
(if grid is safe from terrorists and pranksters, then
how can it be vulnerable to amateurs) for the rebuttal
period.


     I will be checking with the ARRL to get their
thoughts, and will pass them on.


73, Fritz, W1FR, Experiment Coordinator

Frederick H. (Fritz) Raab, Ph.D.
GREEN MOUNTAIN RADIO RESEARCH COMPANY
1183 Jonquil Lane
Boone, Iowa  50036  USA
Tel:  +1 (515) 275-2141
Cell: +1 (802) 598-9527
E-mail:  f.raab at ieee.org
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