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Re: LF: US FCC NOTICE OF PROPOSED RULE MAKING, Comments

To: [email protected]
Subject: Re: LF: US FCC NOTICE OF PROPOSED RULE MAKING, Comments
From: "James Moritz" <[email protected]>
Date: Mon, 20 May 2002 12:59:00 +0100
In-reply-to: <[email protected]>
References: <[email protected]>
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Dear Andre, LF Group,

Regarding ERP and so on, significant points that can be drawn from European experience on LF are:

Measurements by several people have shown that the efficiencies achieved by typical amateur LF antennas are rarely better than 0.1%, and normally rather less. So a 100W PEP TX power limit in practice would limit EIRP to less than 0.1W for the vast majority of amateur stations - experience shows that to get 1W EIRP with 100W transmit power probably requires a favourably located antenna around 30m high. Even with unlimited transmitter power available, EIRP greater than 1W would be difficult to achieve from many amateur locations due to electrical breakdown of the antenna. Only a small minority of European stations approach our 1W ERP limit, in spite of the fact that transmitter powers are normally well over 100W. A TX power limited to 100W seems unnecessarily restrictive. In Europe, the availability of higher transmit powers means that less well-off amateurs can generate usable signal levels without having to acquire large tracts of real estate for antennas!

It is certainly possible to make consistent measurements of ERP, although difficult for the average amateur station. However, an estimate can easily be made from a knowledge of the antenna geometry (effective height or area) and a measurement of the antenna current. The actual ERP determined by field strength measurements is invariably lower than the figure given by this estimate by an amount depending on environmental factors, usually in the range 0-10dB. So a safely conservative (from the regulatory point of view) estimate of ERP can be made from very simple measurements.

In the European context, signal levels are present in the range of kilowatts to megawatts ERP from numerous broadcast and utility transmitters throughout the LF frequency range. There seems to be little interference caused to the operation of other electronic systems by breakthrough of these high level signals, which are obviously vastly greater than any feasible amateur signal level. Short range RF tagging systems using the 125kHz and 134kHz frequencies seem to be successfully in use over here, in spite of these large signal levels, so amateur LF operation would seem to pose little threat to these systems. I don't know if the power utilities in Europe use the same type of LF PLC systems (perhaps that is what the "Watford Whistle" carrier on 136.647kHz I D/F'ed to some power lines a while ago is.)

The other side to the above is that, because they are relatively of extremely low power, amateur LF signals experience high levels of unintentional interference from numerous sources - for instance noise sidebands and intermodulation from high power LF transmitters (especially Loran), and switching noise from a wide range of mains driven appliances. These are often a severe limitation on amateur operation at LF, and would be considerably more of a problem with the proposed US power limits.

Do you think it would be useful to send this type of comment directly to the FCC, or would it be better to do it via AMRAD/LWCA/ARRL etc?

Cheers, Jim Moritz
73 de M0BMU



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