Tuesday, 2 June 2015
U.S. LF Bands - Rulemaking Ruminations (Part 1)
John Davis of the Longwave Club of America has been doing a good job of keeping us informed of the present 2200/630m application status for U.S. amateurs. It seems that although the NPRM has not yet been published in the Federal Register, the FCC website is open for comments on this issue. I would urge all amateurs with an interest in LF operation to file comments that address the FCC's Notice Of Inquiry (NOI), particularly if you have been operating an experimental station. As well, Canadian LFers operating on either band should consider filing comments as well, describing your system and overall operating results. You can read a full review of the FCC's concerns in three of my earlier blogs:
John's latest information points out what he believes are three crucial points that deserve serious thought. As he indicates, if we don't 'get it right' the first time, it might be very difficult to make any changes after the fact. Please give serious thought to John's information and to filing your own comments at the link provided.
In John's own words:
This is probably a good time to get discussion reactivated on the MF and LF ham proposals. Although I continue not to see publication of the NPRM in the Federal Register as yet, the FCC EFCS Web page for the proceeding is open and accepting filings. Until FR publication, we won't know the closing dates for comments and replies, but you can see what's already been going on at:
While I've been awfully tied up with other things recently, my reading of
the proposal thus far brings to mind three points I believe we earnestly
need to address with the Commission. This proceeding will set the exact US
rules for 2200 m, and very probably also 630 m, so it behooves us to make
the best case we can, now, right up front. If the initial rules are too
restrictive on amateur activity, it could be very difficult and time
consuming to get them changed. Here are my present concerns.
* ONE: In paragraph 168, the FCC states that in addition to separation
distances and power limits, "we propose to limit amateur stations to
operations at fixed locations only to ensure that this separation distance
can be maintained reliably." That's stricter than it may first sound. The
FCC's actual proposed wording for § 97.303(g)(1), for both 2200 and 630 m,
is: "Amateur stations are restricted to use at permanent fixed locations."
Permanent fixed locations. That goes way beyond my suggestion that mobile operation be prohibited. It precludes temporary fixed operation, such as Field Day activities, or tests of ground characteristics for future potential antenna sites, or other legitimate short-term experiments. In my view, this is needlessly restrictive, and could also open the door to more rigid coordination requirements that might paint us into a corner, figuratively and literally, at our original QTHes.
We need to make a strong case that hams are able to identify electric
transmission lines and maintain 1 km separation (or other specified
distance) from them. This further relates to comments the FCC seeks in par. 176: "Amateur licensees will have to determine the location of transmission lines in their vicinity to determine if they are permitted to operate stations using these frequency bands. .... High voltage transmission lines are typically attached to large steel towers that are easy to identity.
However, lower voltage transmission lines are typically attached to wooden poles. Although the wooden poles used for transmission lines are usually taller than the wooden poles used for distribution lines, we recognize that distinguishing the two types may not always be straightforward. We seek comment on whether amateur licensees will be able to identify the transmission lines in their locality."
Obviously, just glancing around a proposed operating site and saying "nope, I don't see a transmission line" is not enough. But I think we're smart enough to do responsible surveys of all lines within a mile or so in all directions, identify any substation locations, and determine which sets of poles have customer connections (practically the definition of distribution lines) and which don't (therefore assumed to be transmission lines). We need to convince the FCC that we can tell the difference.
... to be cont'd