Date: Sun, 19 May 2002 01:31:46 -0400
From: "'Geri' Kinzel, DK8KW" <DK8KW@compuserve.com>
Subject: LF: US FCC NOTICE OF PROPOSED RULE MAKING, Comments
Cc: rsgb_lf_group@blacksheep.org
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Hello LF-Friends, this time especially those from Europe,

in my previous mail I gave some comments about the U.S. FCC's Notice of
Proposed Rule Making (NPRM) on the allocation of the LF band 135.7 - 137.8
kHz in the U.S. If the rules as proposed (1 Watt EIRP, 100 Watt PEP)
becomes true, it might be very difficult to find any future partner
stations for transatlantic QSOs. We in Europe have gained several years of
experience with LF antennas and we have found out that with 100 Watt PEP it
is only possible for very large antennas to radiate anything in the 1 W
EIRP range. Even in the U.S. the average amateur antenna on LF would not be
able to radiate more than 100 mW EIRP with the 100 Watt PEP restriction
(desnite maybe ham stations in Texas  ;-)

One of the major concerns of the FCC are some low-cost/low-power devices
that operate several kHz away from our allocation that are used for
identification purposes. I have such a device that cotrols my cat flap (my
cats have a special key device around their necks, and only those keys will
open the flap, so it saves us from having foreign cats in our house eating
our cat's food, btw the device is a British product) and under normal
conditions this flap will also work if I operate my 350 Watt station on LF,
despite the fact the cat flap is directly in my shack, only 1 m away of my
loading coil variometer. If those systems are operated some 10 m away from
our transmitters, I don't think that there is a risk of getting an
interference.

The FCC writes in the NPRM: "We seek comment on whether these limits on
EIRP and PEP are appropriate."

On the FCC website for electronic filing of comments
(http://www.fcc.gov/e-file/ecfs.html) I found the note:

"7/22/99
                       International users are able to submit comments via
ECFS by completing the required Mailing
                       Address and City fields found on the Cover Sheet.
Select "DC" as the state and enter "00000" in
                       the Zip Code field."

This means that also international comments are welcome. We should share
our European experience with the FCC guys. Maybe this helps to influence
the FCC decision to allow at least a higher PEP (maybe also to lift the
EIRP limitation to ERP), so that in the future we can look out for hundreds
of potential transatlantic QSO partner!


Best 73

Geri, DK8KW (W1KW)