NOT FOR ATTRIBUTION ODV, Late Thursday I met with Ed Hare W1RFI (ARRL volunteer consultant) and George Spatta W1GKS (ARRL Lab) to discuss the likelihood of harmful interference to Radio Amateur communications if the SMC proposal is adopted without modification. Their conclusion is that the changes to the FCC Part 90 technical rules, as proposed and if used at their maximum, most definitely have the potential to cause harmful interference in the Amateur bands between 2-25 MHz. Ed has drafted a technical analysis explaining the basis for the harmful interference conclusion. We intend for this analysis to be attached to and discussed in the body of ARRL’s comments. I also want to note that as of this morning, there already were more than 650 comments filed at the FCC addressing this petition, many by licensed amateurs that include their call sign on their filing. Knowing that you are receiving an increasing number in inquiries, and now that we know the facts that will inform ARRL’s comments, below are suggested responses to queries about ARRL’s views on the petition. The below points can be used by directors as you wish, but should be used without attribution to source (other than to you as a director) given that the ARRL has not yet filed written comments with the FCC. Please feel free to speak or email me if you have any questions. 1. Since May the ARRL lab has been reviewing the technical rules proposed in SMC’s petition from the stand point of potential interference to Amateur Radio communications. 1. A technical analysis has been prepared for submission to the FCC. 1. The ARRL analysis demonstrates that the rules as proposed in SMC’s petition, if adopted, would pose a clear potential for interference into the Amateur bands. 1. SMC proposes out-of-band emission limits for bands between 2 and 25 MHz that, coupled with other changes proposed by SMC (including 20,000 watts output power, 50 kHz signal bandwidth and data transmissions) would allow substantial power to be radiated into neighboring HF Amateur bands that would cause harmful interference to Amateur communications. 1. It may be possible for high-power HF transmissions to co-exist with Amateur communications, but not with the technical rules proposed by SMC. 73, Dave K3ZJ David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.