Greetings. Just now, with the quick approval of the Executive Committee, I filed the attached reply comments in the FCC's docket dealing with an LF Amateur allocation at 135.7-137.8 kHz and FCC's proposed upgrade of the secondary Amateur allocation at 1900-2000 kHz to primary status. As you will see, UTC and a number of utilities filed unsupported, non-technical objections to the LF allocation. In doing so, they fell largely into the trap set for them by Kermit Carlson, Ed Hare, Mike Gruber and Brennan Price, who jointly authored the Annex for our original comments in this proceeding. We think that we have made our case for this small LF allocation without prejudicing our 472-479 kHz petition. In fact, this record very strongly supports that MF allocation because the utilities are pretty much admitting that they don't use that higher frequency segment for PLCs. The record looks good so far, but today is the deadline for reply comments and we don't yet know what, if anything, the utilities will file. If there is anything meaningful, we will hit them with an ex parte written filing Kudos and thanks to President Craigie and Dave Sumner especially for helpful edits to these reply comments, and as well to the Executive Committee for edits and a really rapid turnaround in reviewing the drafts of this filing. 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