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ARRL General Bulletin ARLB010 (2016)

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ARLB010 ARRL Urges FCC Not to Impose Overbroad Notification
Requirement to Operate on 2200 and 630 Meters

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ARRL Bulletin 10  ARLB010
From ARRL Headquarters  
Newington CT  March 11, 2016
To all radio amateurs 

SB QST ARL ARLB010
ARLB010 ARRL Urges FCC Not to Impose Overbroad Notification
Requirement to Operate on 2200 and 630 Meters

In an ex parte statement, available at
http://apps.fcc.gov/ecfs/comment/view?id=60001498728 , filed March 10
with the FCC, the ARRL has asked the Commission not to adopt "an
overbroad" requirement for notification of utilities in advance of
intended Amateur Radio operation on the pending 2200 and 630 meter
bands. The statement in ET Dockets 12-338 and 15-99 supplemented the
League's earlier comments in the proceeding. The FCC is expected to
provide Amateur Radio with access to both bands and to spell out
service rules and operational requirements, sometime within the
first quarter of 2016. Regulatory provisions under consideration
have included a possible notification requirement by some radio
amateurs to utilities that operate PLC systems in that region of the
spectrum, prior to their starting operation on either new band.
Utilities use unlicensed PLC systems to control parts of the
electrical power grid.

"ARRL does not object to such a notification requirement, provided
that it is appropriately circumscribed, not overbroad in its
applicability, and not overly burdensome for radio amateurs to
comply with," the League's statement asserted.

The ARRL noted that comments filed by the Utilities Telecom Council
(UTC) called for a system of "quasi-coordination" by radio amateurs
before commencing operation on 2200 meters (135.7-137.8 kHz). In its
remarks to the FCC, the ARRL pointed out, however, that the UTC has
not volunteered any information with respect to how a notification
process might work nor offered any PLC database information to the
ARRL or to the amateur community so prospective users of the band
could determine if their operation might be problematic.

The ARRL expressed concern that "this vague reference" to a
notification procedure by UTC might lead the FCC to adopt an
overbroad notification requirement for radio amateurs intending to
operate in either the 2200 or 630 meter band. The League further
pointed out that PLC systems operating between 9 and 490 kHz are not
subject to protection from licensed services.

The League reiterated its willingness to accept distance-separation
criteria between amateur stations operating on either band and
PLC-carrying transmission lines making use of frequencies in either
band, and a notification process in the few instances in which an
amateur station intends to operate on either band within close
proximity to a transmission line with a PLC using the same
frequencies. The League said interference potential to PLC systems
from Amateur Radio operation on 2200 or 630 meters is very low, with
the possible exception of amateur operation within 1 kilometer of an
existing transmission line carrying co-channel PLC signals - a very
unlikely circumstance.

"It would be an unreasonable regulatory burden to require more than
this, and there is no record justification for a requirement that
all radio amateurs who wish to operate in these bands to have to
participate in a notification process," the ARRL said in its ex
parte statement. In any event, the League added, notification should
not be required for any PLC system that comes on line after the
effective date of the Report and Order granting Amateur Radio access
to 135.7-137.8 kHz or to 472-479 kHz.

Radio amateurs are sufficiently technically sophisticated to
identify a transmission line that might be carrying PLC and to
determine whether their station is closer than 1 kilometer to that
line, the League asserted, adding that it would be able to assist
hams in making such determinations.

Once notification has been made, the ARRL continued, the burden
should be on the utility to demonstrate quantitatively within a
reasonable time that the proposed operation would cause harmful
interference to PLC operations that existed before the effective
date of any Report and Order in the proceeding.

Any sort of blanket notification requirement prior to transmitting
on 2200 or 630 meters "would be clear regulatory overkill," the ARRL
concluded. Neither would it be reasonable to require
across-the-board notification even by amateur stations located
within 1 kilometer of a transmission line, because the chances that
a particular transmission line is carrying PLC, and makes use of
either band are "extremely small."
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