Date: Fri, 17 May 2002 04:19:35 -0400
From: "Holger 'Geri' Kinzel, DK8KW" <DK8KW@compuserve.com>
Subject: LF: USA 136kHz proposals
To: rsgb_lf_group@blacksheep.org
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Hello LF-folks, especially across the Atlantic ocean,

reading through the FCC NOTICE OF PROPOSED RULE MAKING of May, 2nd, I am
surprised how thoroughly the FCC guys have investigated the matter of a LF
allocation in the U.S. For instance in a footnote they mention the activity
of a Dutch ham crew operating with antennas supported by a kite some years
back, thus increasing the ERP of their station to values much higher than
the 1 Watt ERP.

Also I am surprised about the FCC's position in regards to the LowFer Part
15 activity. I know that several LowFers were trying to "hush hush" about
their operations, because they feared they were making use of a gap in the
regulations, and that FCC would close that gap if they got aware about what
was going on (from the report: "Amateur radio operations in the 160-190 kHz
band under the Part 15 rules will not be affected.  Under these rules,
amateur operations must meet certain power and antenna length requirements,
but they also are allowed to build and operate some equipment of their own
design"). So it is obvious that they consider this Part 15 operation of low
power LF operation (LowFer) not only as legal, but they support it in this
proposal as a desirable way of experimenting.

What I am little bit concerned about is the restriction to 1 W EIRP (not
ERP, so a further 2.15 dB below ERP), especially with the proposed output
power limitation of only 100 W PEP. I think it is fair to say that even a
well constructed typical amateur radio antenna on LF has a "gain" of
maximum minus 30 dB, resulting in radiated powers of less than 100 mW when
using a 100 W transmitter. 

Maybe in replies to the FCC (" We seek comment on whether these limits on
EIRP and PEP are appropriate.") these European experiences should be
mentioned (an excellent website collecting a lot of antenna experience is
maintained by Rik, ON7YD, http://www.qsl.net/on7yd/136ant.htm). This should
be made known to FCC. As a holder of a US license I plan to reply to the
proposal, although I do not plan to operate LF during my frequent stays in
the U.S. (haven't really found the appropriate portable LF station for
hotel operation yet ...). I am not really sure at the moment about who may
comment (maybe someone can find out), but probably also comments from the
European ham community would help our U.S. friends a little bit here. 

Regarding bandwidth: Germany has a limitation to 800 Hz bandwidth on LF
(and 100 Hz on the 8.9 to 9 kHz band ... ;-). This bandwidth allowed
Markus, DF6NM and myself, for instance, the use of Slow-Voice mode
(reducing the speed of the voice transmission by the factor 8, thus
reducing the bandwidth from the normal 3 kHz down to 375 Hz). 100 Hz would
still allow most other non-CW modes to be used (PSK31, Hell, probably a
narrow-shift type of RTTY). 

Best regards

Geri, DK8KW (W1KW)