Greetings. With a lot of help from CEO Dave Sumner, President Craigie, CTO Brennan Price, Ed Hare and the entire Executive Committee, we have finally gotten these comments filed today. The argument is principally that the Amateur Service is ill-suited to a "harm claim threshold" (HCS) which is an ascertained level of minimum receiver performance that determines as a threshold matter whether or not an interference victim can or cannot complain of the interference to FCC. There is a great need, however, for minimum performance standards, perhaps even mandatory standards, for receivers in home electronic equipment. The FCC Technological Advisory Committee (TAC) obliquely suggested using the same standard for HCS in general that is set forth in the FCC rules in Section 15.209, which was found to be applicable to Amateur HF operation as a measure of BPL interference. It was grossly inapplicable in that context and it is grossly inapplicable as an HCT. If that standard were to be applied to Amateur receivers, there could never be another power line interference complaint that was actionable. These comments respond only to an inquiry, and not to any proposed rule. But we would like to be very careful in this proceeding to avoid any standards that might be applied to Amateur receivers, and it is past time that receiver performance standards are applied to home electronic equipment. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG