Folks, Dennis is correct, I apologize for the typo in the message yesterday. I was a bit foggy in the late afternoon yesterday in particular. I guess when a doctor tells you to not drive a car for the next 24 hours, preparing a Board memo two hours later is kind of ill-advised also. Thanks to Dennis and Jay for spotting that. 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 -----Original Message----- From: Dennis Bodson <bodsond@verizon.net> To: 'Chris Imlay' <w3kd@aol.com>; dsumner <dsumner@arrl.org>; arrl-odv <arrl-odv@arrl.org> Cc: w1rfi <w1rfi@arrl.org>; dhenderson <dhenderson@arrl.org> Sent: Mon, Feb 25, 2013 5:42 pm Subject: RE: [arrl-odv:21562] Re: Amateur Allocations at 135.7-137.8 kHz and1900-2000 kHz; Docket 12-338 Chris: Is the word “Private” correct? Should it be “Primary.” Regards, Dennis From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Monday, February 25, 2013 4:22 PM To: dsumner@arrl.org; arrl-odv@arrl.org Cc: w1rfi@arrl.org; dhenderson@arrl.org Subject: [arrl-odv:21562] Re: Amateur Allocations at 135.7-137.8 kHz and1900-2000 kHz; Docket 12-338 Darn. I can't get ANYTHING by Dave!!! 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 -----Original Message----- From: Sumner, Dave, K1ZZ, K1ZZ <dsumner@arrl.org> To: Chris Imlay <w3kd@aol.com>; arrl-odv <arrl-odv@arrl.org> Cc: Hare, Ed W1RFI <w1rfi@arrl.org>; Henderson, Dan N1ND <dhenderson@arrl.org> Sent: Mon, Feb 25, 2013 4:15 pm Subject: RE: [arrl-odv:21560] Amateur Allocations at 135.7-137.8 kHz and1900-2000 kHz; Docket 12-338 One small correction to Chris’s note: the EC meeting is March 9, not March 11. Dave K1ZZ From: arrl-odv-bounces@reflector.arrl.org [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Chris Imlay Sent: Monday, February 25, 2013 4:12 PM To: arrl-odv Cc: Hare, Ed W1RFI; Henderson, Dan N1ND Subject: [arrl-odv:21560] Amateur Allocations at 135.7-137.8 kHz and1900-2000 kHz; Docket 12-338 Greetings. Yesterday, I filed the attached comments in the FCC's docket implementing the WRC-07 Final Acts in the United States. FCC proposed a number of actions, two of which were of substantial interest to us. First, FCC considered (but did not propose) implementing domestically the WRC-07 secondary international allocation of 135.7-137.8 kHz to the Amateur Service. FCC called for comment on the extent of compatibility between Amateur LF operation and utility Power Line Carrier (PLC) systems which operate between 9 and 490 kHz. Second, FCC proposed to elevate the Amateur allocation from secondary to private at 1900-2000 kHz, which removed the "Sword of Damocles" over our heads in the top half of 160 meters, where displaced radiolocation systems were to go when the FCC created the expanded AM broadcast band at 1605-1705 kHz. While this is a good thing, FCC really fouled up the proposed rule language in the appendix to the NPRM, as you will see in the latter part of these comments (paragraphs 27 and 28). Kudos to Dave Sumner for catching this problem when the rest of us all missed it. We had some good intelligence information when putting the final version of these comments together, which helped us address counterarguments that we knew would arise. That is the good news. The bad news is that our antagonist on this, UTC, the utilities telecom council, has roused its utility members to oppose vigorously the Amateur LF proposal in this docket. It is entirely likely that UTC will similarly exhort its members to oppose our (separate) Petition for Rule Making, filed November 29, 2012, which proposes a low-MF allocation at 472-479 kHz (whenever FCC gives that Petition a file number) even though that allocation was made internationally at WRC-12. UTC is taking a hard line, apparently without any hard science to back up their interference allegations. Unfortunately for us, that worked for them in 2003 when the 135.7-137.8 kHz allocation for Amateur Radio was last considered by FCC (prior of course to WRC-07). As to the hard science(which we have and UTC apparently doesn't), please pay particular attention when reviewing this filing to the Annex A. It was expertly prepared by the EMC Committee, led by Kermit Carlson, W9XA. I think you will be impressed upon reading Annex A, as was I. Kermit and Ed Hare did a fine job on this, with help from Brennan Price and Mike Gruber. Thanks on this filing as well to Dave Sumner, President Craigie and Dick Isely for helpful edits. We will have to file strong reply comments, which are due March 27. A number of utilities have already filed in opposition to the Amateur LF allocation and the comment period closes late tonight. So expect another round of filings on this next month. The EC will be reviewing the matter at its upcoming meeting on March 11. 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