[600MRG] Special event Nov. 13-14

John Andrews w1tag at charter.net
Thu Oct 15 20:15:44 CDT 2015


The reply comment period has ended.

John, W1TAG

On 10/15/2015 9:12 PM, Frederick Raab wrote:
> 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
> Alt:  fraab at gmrr.biz
> Web:  www.gmrr.biz
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