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Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
RM - ________________ )
Amendment of Parts 2 and )
97 of the Commissions Rules )
to Create a Low Frequency )
Allocation for the Amateur )
Radio Service )
To The Commission:
PETITION FOR RULE MAKING
The following is a formal petition by Nickolaus E. Leggett, N3NL an
Amateur Extra Class radio operator with over three decades of experience.
This petition requests that Amateur Radio Service operation be allowed on
135.7 to 137.8 kHz and 160 to 190 kHz. In addition, the operators
currently using 160 - 190 kHz under the Part 15 rules should be allowed
to continue their use of 160 - 190 kHz.
1.0 Amateur Radio Service
An amateur radio allocation at 135.7 to 137.8 kHz would allow operators in
the United States to communicate with amateurs in Europe who have recently
been allocated this frequency band. Transatlantic communication using a
few watts of output power will help in the exploration of the low
frequencies and their uses. Similar exploratory benefits will result
from operation in the 160 to 190 kHz band. An additional benefit is the
potential for less radio frequency interference due to the substantial
separation between these frequencies and the frequencies used by
most home entertainment equipment and wireless phones.
1.1 160 to 190 kHz Operation Under Part 15 Rules
At the present time, unlicensed experimenters operate on the 160 to 190 kHz
under the Part 15 rules (Section 1.217). These rules allow a 1 watt
transmitter (input power to the final RF stage) and an antenna,
transmission line, and ground up to 15 meters in length. As the American
Radio Relay League (ARRL) has pointed out, the signal from these
transmitters is really tiny. This is due to the very low efficiency
of the antenna. Despite this, the Part 15 experimenters have established
communications over hundreds of miles.
These experimenters are achieving good results on the 160 to 190 kHz band
and they should be specifically allowed to continue even after amateur
radio operation is authorized on the band. In addition, these
experimenters should be allowed to communicate with amateur radio
operators operating in this band.
If the Commission decides that the Part 15 operators must be encouraged to
become amateur radio operators, then the Part 15 operators should be given
at least a five year grace period to accomplish this change in status.
Respectfully Submitted,
Nickolaus E. Leggett
N3NL Extra Class Amateur Radio Operator
1432 Northgate Square, Apt. 2A
Reston, VA 20190-3748
Phone (703) 709-0752
Date: November 23, 1998
Reply 1: Hi, Nick. I, for one, appreciate the intent of your petition. However, I find myself concerned that Part 15 operation is raised to such a high profile in it. When dealing with the FCC, it is sometimes wiser to be inconspicuous, lest they decide to look at one's service more closely and come up with new ways to "help" it into the modern age, whatever they perceive that to be. Ask AM radio broadcasters about NRSC, or the majority of TV broadcasters about DTV. They'd have been a lot happier without the FCC's "help" in these matters.
The ARRL petition remained silent about the future of Part 15, except for discreet mention of coexistence with non-allocated services (i.e., us). It did not propose any changes to the Part 15 rules whatsoever, thus not subjecting us to the FCC's "helpful" scrutiny at this time.
I fear the proposal to allow communication between licensed and unlicensed services --unprecedented in the history of US radio regulation-- will indeed raise eyebrows, drawing unanticipated attention to your idea of phasing out Part 15 use over time.
This is analogous to what happened when the NAB petitioned to require AM stations to use an NRSC-compliant audio preemphasis and filtering. With Tinkerbell optimism, NAB's chief scientist publicly pooh-poohed my objection that the FCC was in the business of regulating RF, not audio processing. No, no, he assured everyone..they won't impose new RF emission standards. Guess what we got? Tighter RF emission masks, and an expensive mandatory annual measurement process.
It may be that nothing bad at all will happen this time. But as the saying goes, "once bitten, twice shy." I invite reader comment and discussion on this matter. -John
www.lwca.org
potrzebie