Comments: Paragraphs 13-19 deal with the WRC-07 allocation of 135.7-137.8 kHz. There are several questions posed in paragraphs 17-19 to which we will want to respond. Paragraphs 20-24 deal with upgrading the amateur service allocation at 1900-2000 kHz to primary. We were told a couple of years ago that this was in the works in recognition of the fact that GPS had overtaken the radiolocation technology previously used in the 1605-1705 kHz band, so radiolocation had never been implemented in the replacement band of 1900-2000 kHz. This is a very positive proposal, but the proposed language for Section 97.303(g) on page 109 is not quite right. Internationally the amateur service allocations between 1800 and 2000 kHz are on a primary basis. ITU Radio Regulation 4.8 states that where a band is allocated to different services of the same category in adjacent Regions or sub-regions, "the basic principle is of equality of right to operate. Accordingly, the stations of each service in one Region or sub-Region must operate so as not to cause harmful interference to services in the other Regions or sub-Regions." Thus "..., and must accept interference from,..." is incorrect. The provision is adequately covered by Section 97.303(a), and 97.303(g) should be deleted. Paragraph 168 corrects an earlier oversight with regard to the 10.0-10.5 GHz band. The remainder of the 130-page document is not of direct interest to us although paragraphs 42-43 regarding 420-450 MHz may be of passing interest. 73, Dave K1ZZ