Does it seem odd that they are not opposing granting us in an allocation in the 135 KHz band where they state there are fifty utilities affected, but opposing the 472-479 KHz allocation where practically NO PLC’s are represented? Perhaps they realize that Hams have had experimental licenses in the LF band with no interference recorded, while there is less experience with the MF band? I suppose they feel they can use the “not enough known as to interference potential” card on MF, and would have to resort to proposing heavy restrictions of our operations on LF. This is indeed “whiney”. I hope the FCC has the good sense to tell UTC that a total of less than 10 KHz of the available 481 kHz of spectrum available to PLC’s is an insubstantial amount, and have them develop frequency agility and mitigation technology needed to accommodate other users (licensed ones, in particular). They are well funded, after all. Just a question I should have asked Brennan in the past-Why is the US still on LF and MF for smart grid technology anyway? ’73 de JIM N2ZZ Director – Roanoke Division Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections ARRL – The National Association for Amateur Radio™ From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Wednesday, September 02, 2015 5:09 PM To: arrl-odv Cc: <ehare@arrl.org> Subject: [arrl-odv:24650] Docket 15-99, LF and MF bands; Shortly after my last e-mail to you about this docket our comments finally showed up in the ECFS. Since then, just now, UTC's comments showed up as well. Not unexpected but their 10 pages of largely whiny comments were startlingly insubstantial. They argue against any allocation at 472-479 kHz; they suggest a firm 1 km separation between PLCs and amateur stations, and argue for an elevation in priority of PLCs in the 2200-meter band and coordination by amateurs. The UTC comments are attached for your review. Do yoga before reading them. We will have to file reply comments in this proceeding, again not unexpectedly. -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG