Today at my request Chris Imlay sent the attached letter to FCC OET Chief Julius Knapp. Here is some background. Old Timers will recall that after World War II, for many years 160 meters was subject to severe frequency and power restrictions in order to protect the LORAN-A radionavigation system from interference. Once LORAN-A ceased operation in this part of the world, in 1983 the FCC allocated 1800-1900 kHz to the amateur service on an exclusive basis. At the same time 1900-2000 kHz was allocated to the amateur service on a secondary basis and to the radiolocation service on a primary basis, the latter in order to reaccommodate radiolocation operations that the Commission anticipated would be relocated from 1605-1705 kHz when the AM Broadcasting band was expanded. In the international Table of Frequency Allocations the amateur allocation was and is co-primary with some other services, including radiolocation, at 1850-2000 kHz in Region 2. GPS technology rendered those MF radiolocation operations obsolete, and in 2012 the FCC proposed in ET Docket No. 12-338 to return 1900-2000 kHz to exclusive amateur use on a primary basis in the United States in recognition of the fact that no radiolocation stations in fact had been relocated as had been anticipated. The Commission's proposal was not perfect. Inexplicably, the Commission proposed to maintain an obligation that its amateur stations not interfere with, and accept interference from, stations in other countries operating in accordance with the international Table of Frequency Allocations. In our comments in the proceeding the ARRL argued strongly that amateurs' obligations are no greater under the international Radio Regulations than are the obligations of the stations in other services with whom we are co-primary. We fully expected the matter to be settled in our favor because our position was and is entirely consistent with the principle of "equality of right to operate" that is enshrined in the international Radio Regulations. ET Docket 12-338 dealt with a number of other subjects, primarily with regard to the implementation of WRC-07 allocation decisions, including our pending LF allocation at 135.7-137.8 kHz. More than two years have passed since the NPRM was released but we were not too concerned about the delay with regard to 1900-2000 kHz because the status quo was that we were secondary to a service that was not using, and had no plans to use, the allocation. We were more concerned about the LF allocation and our petition to open the 472-479 kHz band that was allocated at WRC-12. However, this changed a couple of weeks ago when a very powerful radiolocation signal appeared, centered on 1915 kHz. The source was traced to Hartlen Point, Nova Scotia, near Halifax. Doug Grant, K1DG researched and confirmed that it is a high-frequency surface-wave radar (HFSWR) system, developed by Raytheon Canada for the Canadian military. It is intended to detect ships up to 200 miles from the country's coast to protect against terrorists, smugglers, and unauthorized fishing vessels as well as locate vessels in distress. The present system has been detected at 1915, 3250, 4400, and 5300 kHz. Doug was advised that the system is undergoing testing and that it normally will operate on the other frequencies and not 1915 kHz, but if and when it does operate on that frequency (or elsewhere in the 1850-2000 kHz band) it will be a massive interference source to amateurs. Interestingly, while he is out of the office today Julie Knapp has already responded informally to Chris's letter: "Hi Chris, Dave and Kay: I know this has taken quite a bit longer than I told you I expected, primarily because there were several other issues in the proceeding that we needed to resolve. While it has taken some time, I believe we now have a much better product. We are in the final stages of coordinating the draft order and I anticipate action early next year. We'll keep you posted on how things are progressing. In the meantime, I hope you all have a wonderful holiday season. Regards, Julie" 73, Dave Sumner, K1ZZ