Chris, As usual, excellent work on this document. Hopefully if the UTC does not wish to cooperate by not providing information about the location of their potentially affected lines, that hams are not mandated to report ALL potential operations on MF and LF. In other words, if UTC does not wish to provide the data, the ham (IMHO) should have no reporting requirement prior to beginning operations. I wonder if this could be conditioned as such. I think the PLC’s are not going to provide the data to a private entity (ARRL) or to the public, with the excuse of a terrorism threat. We all know that the FCC wouldn’t want that burden either. ’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 30, 2015 10:16 AM To: arrl-odv Subject: [arrl-odv:24709] Docket 15-99, LF and MF Bands at 2200 and 630 Meters; Reply Comments Greetings. I have just now filed ARRL's Reply Comments, due today, in the above docket proceeding. We replied only to the Utilities Telecom Council (UTC) because that was the only comment that questioned the two new bands or the service rules with respect to either. No comment addressed the ocean buoys at 1900-2000 kHz, so we got off a bit easy here so far. These Reply Comments address each of UTCs (frankly, poorly argued) points. It is not clear whether UTC is saving its ammo for its own reply comments or whether they have effectively given up, but so far the record is entirely favorable to us. Thanks to the Executive Committee for its oversight and thanks especially to President Craigie, Dave Sumner, Ed Hare and Brennan Price for helpful input and edits. 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