Chris, Like Greg, I do not feel qualified to fully respond to this memo, as I do not have the technical acumen to do so. I also share his concern about how a part 15 unlicensed service should be protected from a licensed service. This appears to go against the entire premise of part 15. I would not want to open a “can of worms” to ask the FCC to make this situation consistent with their rules, as we know that didn’t work in the past, and would probably backfire. Starting with our elevation to primary status on the 1900-2000 kHz band, bravo. In terms of these licensed/unlicensed/not appropriately licensed buoys, it looks like there are several opportunities. Interestingly, if the FCC decides to give them a 100 kHz allocation in the MF range (not ours!) and let the current grandfathered buoys be removed as they age, become defective, and are removed from service, that is a win-win. It won’t be immediate, but in the long run, would be a good thing for amateur radio. I think we should encourage the FCC to proceed along this route. I’m not sure if that will be acceptable to the company who wants more bandwidth, but even EPIRBs have gone digital, so there is a possibility for more effective use of spectrum by the buoys. If MF is the way to go and our 472-479 kHz frequencies are not affected, the PLC’s would have to push for regulation of the buoys when near land, rather than us. I don’t know about how far the ships are away from the buoys, but the characteristics of MF on the ocean are apparently the same night and day, Winter and Summer. I would think this would be a plus, although there will most likely be push-back from the manufacturer due to design changes. If 1900-2000 kHz for the buoys is ultimately decided upon, we have to be fairly direct as to limiting power limits of the buoys near land. I know we have to aggressively combat any encroachment on our bands, but I wonder how much of a problem exists in the 1900-2000 kHz segment currently. Most of my 160 operation is on the lower part of the 1800-1900 kHz segment, so I have very little personal experience. Now to the LF and MF allocations proposed for us. I think it goes without saying that the FCC is trying to have every question answered, so that they can develop rules that will not require their future intervention at all. Comments from the PLC will be overly restrictive, and hopefully ours will “push the envelope” so that over regulation will not discourage our use of the bands. The separation distance is one example of a deal-killer. We did specify a 1 km distance in the past when we were “reaching” for the FCC to think about allocating the spectrum. Now that they have come forward to offer, is a 1 km distance even necessary? What would happen at 0.5 km? As far as power, due to inefficiency in that area of the spectrum, 1 watt may be the maximum obtainable. However, according to the memo, we have experimental evidence up to 20 W ERP. We should look to see if the experimental licenses “broke” any PLC system, and use whatever information we receive to our benefit. Although I don’t remember this type of wording in FCC rules, could there be an automatic increase in power or decrease in distance over a set time period in the absence of interference documentation? After initial implementation, could the power level be increased by a set number of watts ERP/year absent of interference complaints? Regardless, I would expect the PLC carriers to produce documentation as to the location of their power lines that would be affected, perhaps via a web application, searchable by address. There might be a push-back from them in regards to security/terrorism concerns. I would think, then, that they could provide the information to ARRL HQ that would allow cross-checking of a QTH that might fall in within whatever distance that is finally indicated by the FCC. The easiest solution is for the PLC to avoid our future frequencies entirely, which would lead to more expansive use of the new bands, allow more power and not have to deal with distance requirements. From what Chris has told us, the 472-479 kHz band should not be a problem due to very few PLC systems in that region. As far as 135.7-137.8 kHz, that is a whopping 2.1 kHz. I don’t know if a guard band is necessary, but over time, can the FCC restrict those few kHz to amateur only, and have a progression time wise to moving PLC out of that narrow frequency range? So, those are a few thoughts, and may be very naïve in terms of content. In the end, I believe the FCC is in the “set and forget” mode, where they desire to set up the rules to be self-sustaining, and require minimal to no intervention on their part in the future. I would think the easiest path would be for them to move the beacons to MF, outside of our allocations, and move the PLC unlicensed part 15 systems out of our anticipated bands, with appropriate guard bands, if necessary. Minimal to no regulation would be required of them in this scenario. That may be dreaming, however. I am very interested in the new frequencies, and have a lot of reading to do. I live on a city lot which will be somewhat restrictive, though. I have the first edition of “LF Today” published by the RSGB, and have just ordered the current 3rd edition from our bookstore which discusses 472-479 KHz in addition to the 135.7-137.8 kHz bands. I have radios that will be able to use those bands, with appropriate amplifiers and probably loop antennas. ’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: Thursday, July 02, 2015 10:17 AM To: arrl-odv Subject: [arrl-odv:24398] LF and MF Docket 15-99 Greetings. Attached is a memo I sent early in June to the Executive Committee and, I believe, at President Craigie's request I circulated it to the entire Board, soliciting input. Not having received much, and because the Federal Register publication of this very important NPRM is now complete and we have an August 31 comment date, President Craigie asked that we remind you that your input on this subject is welcome. The attached memo lists issues that are to be resolved by FCC. There is time to discuss this at the upcoming Board meeting if necessary but the policy issues seem clear and we want to get the draft of comments going in plenty of time for review, editing and filing. So let's hear from you about the specifics of this, folks. Thanks. 73, Chris W3KD -- 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