[Lf] [Fwd: LF: US FCC NOTICE OF PROPOSED RULE MAKING, Comments]

[Andre Kesteloot]

"'Geri' Kinzel, DK8KW" wrote:

> 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)