Well, Jim, they have a fait accompli; the FCC already decided to allocate the 135 kHz band to us in the Report and Order part of the docket. The NPRM part was just to establish the service rules for that allocation. However, the Report and Order never dealt with the 472-479 kHz band. That was in our Petition that never got a file number. So this is the first time they have had to deal with the 472-479 kHz allocation. They are playing catch-up on 630 meters though because the FCC already proposed to allocate it to us (as they should do pursuant to the final acts of WRC-12). So it is a hail mary for them to try to keep us out of 630 meters but they are going down swinging. Lamely, but swinging. Which is why we had to pull out all the stops in this set of comments. I think we have beaten them on paper, largely due to Ed Hare's good work, but we can't take anything for granted in this docket until we see the Second R&O. 73, Chris W3KD P.S. Brennan will have to answer why PLCs are still at LF and MF at this point. I have always assumed that it was just the momentum of deployed infrastructure but I don't know. On Wed, Sep 2, 2015 at 5:48 PM, James F. Boehner, MD <jboehner01@yahoo.com> wrote:

Does it seem odd that they are not opposing granting us in an allocation in the 135 KHz band where they state there are fifty utilities affected, but opposing the 472-479 KHz allocation where practically NO PLC’s are represented?

Perhaps they realize that Hams have had experimental licenses in the LF band with no interference recorded, while there is less experience with the MF band? I suppose they feel they can use the “not enough known as to interference potential” card on MF, and would have to resort to proposing heavy restrictions of our operations on LF.

This is indeed “whiney”. I hope the FCC has the good sense to tell UTC that a total of less than 10 KHz of the available 481 kHz of spectrum available to PLC’s is an insubstantial amount, and have them develop frequency agility and mitigation technology needed to accommodate other users (licensed ones, in particular). They are well funded, after all.

Just a question I should have asked Brennan in the past-Why is the US still on LF and MF for smart grid technology anyway?

’73 de JIM N2ZZ

Director – Roanoke Division

*Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections*

*ARRL – The National Association for Amateur Radio™*

*From:* arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] *On Behalf Of *Christopher Imlay *Sent:* Wednesday, September 02, 2015 5:09 PM *To:* arrl-odv *Cc:* <ehare@arrl.org> *Subject:* [arrl-odv:24650] Docket 15-99, LF and MF bands;

Shortly after my last e-mail to you about this docket our comments finally showed up in the ECFS. Since then, just now, UTC's comments showed up as well. Not unexpected but their 10 pages of largely whiny comments were startlingly insubstantial. They argue against any allocation at 472-479 kHz; they suggest a firm 1 km separation between PLCs and amateur stations, and argue for an elevation in priority of PLCs in the 2200-meter band and coordination by amateurs.

The UTC comments are attached for your review. Do yoga before reading them. We will have to file reply comments in this proceeding, again not unexpectedly.

--

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

-- 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

Jim and all, I was on PTO for most of last week, and am just now getting the opportunity to address this: "Just a question I should have asked Brennan in the past-Why is the US still on LF and MF for smart grid technology anyway?" I find that the utility industry tends to classify any communication or telemetry system it can as "smart grid" purely for branding and public relations purposes, even if the technology is older than dirt. There is an ITU-R report on Smart Grid which cites some PLC standards, but emphasizes the need for wireless components of a robust smart grid system. If one really cares to read the report, one can find it in both PDF and Word here: http://www.itu.int/pub/R-REP-SM.2351-2015 The very first drafts of this report were generated in the waning days of the BPL industry by one Jeff Krauss, a longtime nemesis on BPL issues who worked for Current (and has since moved onto other things). Krauss's work was little more than a puff piece for BPL and all things PLC, and Jon Siverling and I leaned on State Department hard (with some sucess) to remove his extensive denigration of all non-powerline technologies from what the United States sent to ITU. What survives in the final report from the pages and pages of batsqueeze that Krauss wrote is the following paragraph: "An early candidate for consideration was power line telecommunications (PLT) following on from the simplistic rationale that the electricity supply lines themselves provide ubiquitous connectivity across all parts of the electricity supply grid and that the necessary data signals could be sent end-to-end over the power lines themselves. This ignored some important points such as attenuation and noise along the power lines and how to route signals around the grid network, and crucially the integrity of the data." While the report goes on to cite some PLC standards that seek to address these issues, it emphasizes the necessity--and arguably the primacy--of a wireless component to smart grid. UTC gets the importance of this too. At the recent CITEL meeting in Ottawa, Brett Klbourne was one of four representatives present from UTC, all advocating for future work on harmonized spectrum within the mobile service for use by utilities. Short answer: The term "Smart Grid" is a marketing term, which utilities will attach to anything they want to protect. UTC's use of the term here is expected. We'll hit back. Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League PO Box 3470 Oakton VA 22124-9470 Tel +1 860 594-0247 ________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of arrl-odv Sent: Wednesday, September 02, 2015 17:48 To: Imlay, Chris, W3KD Cc: arrl-odv Subject: [arrl-odv:24651] Docket 15-99, LF and MF bands; Does it seem odd that they are not opposing granting us in an allocation in the 135 KHz band where they state there are fifty utilities affected, but opposing the 472-479 KHz allocation where practically NO PLC’s are represented? Perhaps they realize that Hams have had experimental licenses in the LF band with no interference recorded, while there is less experience with the MF band? I suppose they feel they can use the “not enough known as to interference potential” card on MF, and would have to resort to proposing heavy restrictions of our operations on LF. This is indeed “whiney”. I hope the FCC has the good sense to tell UTC that a total of less than 10 KHz of the available 481 kHz of spectrum available to PLC’s is an insubstantial amount, and have them develop frequency agility and mitigation technology needed to accommodate other users (licensed ones, in particular). They are well funded, after all. Just a question I should have asked Brennan in the past-Why is the US still on LF and MF for smart grid technology anyway? ’73 de JIM N2ZZ Director – Roanoke Division Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections ARRL – The National Association for Amateur Radio™ From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Christopher Imlay Sent: Wednesday, September 02, 2015 5:09 PM To: arrl-odv Cc: <ehare@arrl.org> Subject: [arrl-odv:24650] Docket 15-99, LF and MF bands; Shortly after my last e-mail to you about this docket our comments finally showed up in the ECFS. Since then, just now, UTC's comments showed up as well. Not unexpected but their 10 pages of largely whiny comments were startlingly insubstantial. They argue against any allocation at 472-479 kHz; they suggest a firm 1 km separation between PLCs and amateur stations, and argue for an elevation in priority of PLCs in the 2200-meter band and coordination by amateurs. The UTC comments are attached for your review. Do yoga before reading them. We will have to file reply comments in this proceeding, again not unexpectedly. -- 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<mailto:W3KD@ARRL.ORG>