Chris - Most of the UTC filing looks like a recitation of the interrogative from the Commission. Although they reliedheavily on their standing, there really is nothing substantiveand if rules for amateurs based on ERP and distance canremove the technical possibility for any "interference" toPLC systems on 137 kHz it is clear that similar considerationscan be effectively employed on 472 kHz as well. Chris - I cant help but think that your characterizationof Mr Kilbourne's filing in terms of a 'hail mary' is spot-ongiven how it is devoid of technical details other than thosethat originated with the FCC or the ARRL such as 1 watt ERP, 200 foot height, and 1 km. I My prayer is that the Commission rules favorably. It is was very unfortunate that the 630 meter petition never was given a number. Thank to you, Ed and the EC for thegreat effort. 73, Kermit W9XA p.s. I wonder if it does become a US band, when the firstDXCC will be achieved .....