In an ex parte statement filed March 10 with the FCC, the ARRL has asked the Commission not to adopt “an overbroad” requirement for notification of utilities in advance of intended Amateur Radio operation on the pending 2200 and 630 meter bands. The statement in ET Dockets 12-338 and 15-99 supplemented the League’s earlier comments in the proceeding. The FCC is expected to provide Amateur Radio with access to both bands and to spell out service rules and operational requirements, sometime within the first quarter of 2016. Regulatory provisions under consideration have included a possible notification requirement by some radio amateurs to utilities that operate PLC systems in that region of the spectrum, prior to their starting operation on either new band. Utilities use unlicensed PLC systems to control parts of the electrical power grid.
“ARRL does not object to such a notification requirement, provided that it is appropriately circumscribed, not overbroad in its applicability, and not overly burdensome for radio amateurs to comply with,” the League’s statement asserted.
The ARRL noted that comments filed by the Utilities Telecom Council (UTC) called for a system of “quasi-coordination” by radio amateurs before commencing operation on 2200 meters (135.7-137.8 kHz). In its remarks to the FCC, the ARRL pointed out, however, that the UTC has not volunteered any information with respect to how a notification process might work nor offered any PLC database information to the ARRL or to the amateur community so prospective users of the band could determine if their operation might be problematic.
The ARRL expressed concern that “this vague reference” to a notification procedure by UTC might lead the FCC to adopt an overbroad notification requirement for radio amateurs intending to operate in either the 2200 or 630 meter band. The League further pointed out that PLC systems operating between 9 and 490 kHz are not subject to protection from licensed services.
The League reiterated its willingness to accept distance-separation criteria between amateur stations operating on either band and PLC-carrying transmission lines making use of frequencies in either band, and a notification process in the few instances in which an amateur station intends to operate on either band within close proximity to a transmission line with a PLC using the same frequencies. The League said interference potential to PLC systems from Amateur Radio operation on 2200 or 630 meters is very low, with the possible exception of amateur operation within 1 kilometer of an existing transmission line carrying co-channel PLC signals — a very unlikely circumstance.
“It would be an unreasonable regulatory burden to require more than this, and there is no record justification for a requirement that all radio amateurs who wish to operate in these bands to have to participate in a notification process,” the ARRL said in its ex parte statement. In any event, the League added, notification should not be required for any PLC system that comes on line after the effective date of the Report and Order granting Amateur Radio access to 135.7-137.8 kHz or to 472-479 kHz.
Radio amateurs are sufficiently technically sophisticated to identify a transmission line that might be carrying PLC and to determine whether their station is closer than 1 kilometer to that line, the League asserted, adding that it would be able to assist hams in making such determinations.
Once notification has been made, the ARRL continued, the burden should be on the utility to demonstrate quantitatively within a reasonable time that the proposed operation would cause harmful interference to PLC operations that existed before the effective date of any Report and Order in the proceeding.
Any sort of blanket notification requirement prior to transmitting on 2200 or 630 meters “would be clear regulatory overkill,” the ARRL concluded. Neither would it be reasonable to require across-the-board notification even by amateur stations located within 1 kilometer of a transmission line, because the chances that a particular transmission line is carrying PLC, and makes use of either band are “extremely small.”
The Monitor Sensors 630m Transverter enables any Amateur Radio Station, equipped with a conventional HF transceiver, immediate, all mode, access to the new 472-479 kHz, 630m band.
$660USD + freight To order, email: email@example.com
|RF frequency range||472 to 479 kHz|
|IF frequency range||1802 to 1809 kHz (others available in the 160m band)|
|Transmission mode||CW, SSB, WSPR, and all other data modes|
|Output Power||50 Watts Continuous, 100% duty cycle @13.8V supply|
|Input and Output Impedance||50 Ohms|
|Supply voltage||13.8 VDC @ 15 Amps nominal, 10-16 VDC operational|
|Rx Noise Floor||-125 dBm (500Hz bandwidth)|
|Rx 3dB compression point||+15 dBm (Rx attenuator out)|
|Rx IF rejection||better than 75dB|
|Rx conversion gain||+6dB nominal|
|Roofing filter in-band ripple||+/- 1.5dB|
|Tx 3rd order IMD||-33 dB below PEP, typical at 50W output|
|Tx 5th order IMD||-45 dB below PEP, typical at 50W output|
|Tx harmonics and spurii||All better than -50dB|
|Tx conversion gain||+10dB nominal|
|Power input connector||2 x Anderson PP15/45|
|RF connectors||3 x SO239|
|PTT connectors||2 x RCA|
The Monitor Sensors 630m Transverter enables any Amateur Radio Station, equipped with a conventional HF transceiver, immediate, all mode, access to the new 472-479 kHz, 630m band. The receiver design incorporates a 7 pole Chebyshev filter, 7kHz wide roofing filter and a 5 pole Chebyshev filter in cascade before the double balanced, commutating mixer, fed by an ultra stable, temperature compensated, extremely low phase noise, MEMS local oscillator.
The mixer is followed by a Chebychev band pass filter into an ultra linear, low noise, current feedback, IF amplifier. A CW signal at -130dBm is readable at the output and yet the onset of compression is not reached until +11dBm. A front end 20dB attenuator can be switched in for even higher signal handling. Overall receiver gain is set to +6dB, or -14dBm with the attenuator active.
The transmitter input circuit incorporates a 0-14 dB switched step attenuator to prevent over driving. The same mixer and local oscillator are used on the transmit side. The PA uses 6 rugged lateral FETs in class AB push-pull to easily achieve the 50 watts rated output.
Lateral FETs are inherently linear and temperature stable. The transmitter can be run at full power, indefinitely, into a short or open circuit without any damage to the FETs. Transmit-receive switching is automatic with user selectable VOX delay. Alternatively the PTT line may be used. The Transverter employs extensive and accurate metering. Power input and output, SWR, Frequency, Attenuation in use, Temperature, Supply Voltage, Current and Resistance are displayed.
Transmission is inhibited if frequencies outside the 472-479 kHz band are detected. A tuning screen may be selected which displays SWR in digital and graphical form for easy antenna adjustment. The menu system is self explanatory and users report no manual is needed, although one is supplied.
A USB socket is provided for future code upgrades (free of charge) from the Monitor Sensors web site. The Transverter has been designed for the best possible protection against accidental mishaps. It will survive reverse polarity supply and the injection of 100 watts of HF into any of its ports whether in transmit or receive mode. If supply current exceeds 20 Amps, the supply is cut in 2 microseconds.
This electronic breaker can be reset by simply switching off and on again. The transmitter will shut down in the unlikely event that the internal heat sink reaches 100°C. The cooling fan is under the proportional control of the microcomputer and begins operation above 35°C. Any unusual operation will cause the screen to turn red and an appropriate warning will be displayed.
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