Greetings. With the approval of the Executive Committee and with helpful input from Ed Hare, Dave Sumner, Tom Frenaye and Brennan Price, I have prepared, edited and just now filed the attached comments in FCC's Docket 15-99. The Docket implements the Final Acts of WRC-07 and proposes to adopt rules implementing WRC-12 Final Acts. This is a huge, wide-ranging proceeding but for us, it proposes to restore a primary allocation for Amateurs at 1900-2000 kHz; to allow radio buoys in that same band; to allocate to the Amateur Service our first LF band at 135.7-137.8 kHz and to allocate the MF band 472-479 kHz as well. We are hopeful that FCC will not enact preclusive rules for the LF and MF band allocations in order to protect Power Line Carrier (PLC) systems that operate between 9-490 kHz. We are also hopeful that we might steer the radio buoys out of the 1900-2000 kHz band. However, with respect to these, FCC is using the 27 MHz CB plan: where there is illegal, unlicensed operation that FCC can't control, just legalize it so the agency doesn't look toothless. Not good. As you will see, we are taking a hard line on this so as to expose FCC's lame strategy. We are hampered by an inability to quantify the illegal buoy operation, as you will see from our argument, but neither does the FCC have any record evidence to justify authorizing the buoys. Let me know any questions you have and thanks to all contributors to this. 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