Chris -

         Most of the UTC filing looks like a recitation of the

interrogative from the Commission.  Although they relied

heavily on their standing, there really is nothing substantive

and if rules for amateurs based on ERP and distance can

remove the technical possibility for any "interference" to

PLC systems on 137 kHz it is clear that similar considerations

can be effectively employed on 472 kHz as well.

         Chris - I cant help but think that your characterization

of Mr Kilbourne's filing in terms of a 'hail mary' is spot-on

given how it is devoid of technical details other than those

that 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 the

great effort. 

                                                 73, Kermit W9XA

p.s. I wonder if it does become a US band, when the first

DXCC will be achieved .....