[Lf] [Fwd: LF: USA 136kHz proposals]

[Andre Kesteloot]

"Holger 'Geri' Kinzel, DK8KW" wrote:

> 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)
>
>