Many of us here are Amateur Radio operators, and have filed comments of our own in response to the Notice of Inquiry. By the time I got mine in -- I waited too long and rushed it, so there are typos and other errors -- over 1600 comments had been filed. Reply Comments are now being taken; deadline 6 August.
In general, it appears that proponents claim they can deliver a much needed service (probably true - if it works) and either that compliance with the Rules as now exist will not produce complaints (and THAT, I believe none of us could support without perjuring ourselves) or that by notching out frequencies where complaints are likely, they could be ruled out. However, there are other users of the HF (and up to 80 MHz is mentioned) range, Amateur Radio operators being only some of them, and this too I consider on the far side of plausibility. Many brief comments merely state opposition to the proposal. Others give reasons, and a few give measurements, simulations and calculations too. There seems no way proponents could legally deploy the proposed broadband service except by raising or ignoring the existing limits -- which I think already too high to protect narrow band users such as the SW broadcast, aviation, marine, and Amateur services, and the non-FCC regulated suers such as government and defense HF radio. The Commissioners are not a technical body; they are a political one, but that doesn't mean they don't recognize a hammer when it hits their thumbs, or that the people who want them to raise the emissions levels permitted do not have engineers of their own. (One of those firms recently listed an opening for an EMC engineer on a large Web help-wanted site.) The FCC some time ago bruited a proposal to change interference limits to take into account the existing electromagnetic background, and this would, I believe, have essentially the same effect as raising the limit to whatever the general interference level would be when adopted. If your industry can't meet the standards, change them, instead. The FCC has taken some rockets lately from politicians who see enforcement of Rules as obstructing progress (or the interests of their friends). When it yields to such pressure, as it must, being political, the Commission sometimes engenders a reaction, such as what we are now seeing with regard to media ownership. However, I consider it unlikely that the general public would think protecting HF spectrum worth writing their elected representatives about, especially when offered universal broadband service at the power outlet. (In all this, we are repeating what has earlier transpired in Europe. When it appeared in Germany that Power Line Communications would exceed existing radiated and conducted limits, the parliament was persuaded to raise them for PLC. In the event, it seems even the increased levels prevented using enough power for good service.) Thus, comments. Even a political body must abide by the forms of politics; the Commission -- except when directed otherwise by Congress -- must accept and consider comments in making Rules. But it takes a lot of physics to trump a politician. Cortland (KA5S) This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
