[600MRG] ARRL Reiterates Call for FCC to Allocate 630 Meters, Okay Rules for 2200 Meters

[Ralph Wallio, W0RPK]

ARRL Reiterates Call for FCC to Allocate 630 Meters, Okay Rules for 2200 
Meters

10/01/2015

The ARRL has again urged the FCC to go forward with a proposed new 
Amateur Radio allocation at 472-479 kHz (630 meters) and to establish 
service rules for Amateur Radio operation at 135.7-137.8 kHz (2200 
meters). The League reiterated its August 31 arguments in favor of 
flexible FCC Part 97 regulations it its September 30 reply comments to 
the FCC's April Report and Order, Order, and Notice of Proposed 
Rulemaking (R&O/NPRM) in ET Docket 15-99. That R&O/NPRM raised several 
questions regarding how Amateur Radio might coexist with PLC systems 
used to control the power grid. Targeting comments filed by the 
Utilities Telecom Council (UTC), the ARRL called on the Commission to 
ignore UTC's call not to allocate 630 meters to Amateur Radio. It asked 
the FCC to implement a notification procedure for amateur stations 
within 1 kilometer (0.62 miles) of a transmission line carrying PLC and 
where the PLC system is operating on frequencies within or which overlap 
the 2200 or 630 meter bands.

"The comments of UTC, without the benefit of any technical component or 
argument, oppose the allocation of the 630 meter band to the Amateur 
Service, and suggest overly and unnecessarily conservative regulation of 
Amateur operation in the 2200 meter band," the ARRL told the FCC. 
"Whatever protection criteria are ultimately deemed to be necessary with 
respect to the 2200 meter band, those criteria would be applicable and 
sufficient as well with respect to the 630-meter band," the ARRL said. 
"There is no technical justification offered by UTC for withholding the 
630 meter allocation."

The ARRL also urged the FCC to reject what it called "UTC's inchoate 
proposal" to elevate the unlicensed status of PLCs operating between 9 
and 490 kHz, purportedly to protect them from interference "caused by 
amateur operations," while not making any accommodations to address PLC 
interference to Amateur Radio operations. "UTC cannot have it both ways: 
It cannot enjoy the benefits of unlicensed operation under Part 15 of 
the Commission's rules as a carrier-current, unintentional emitter and 
at the same time claim the protection afforded an allocated, licensed 
radio service," the ARRL argued.

While the UTC has offered to work with the FCC, the ARRL characterized 
the UTC's comments as "distinctly unhelpful" in terms of providing 
information regarding the prevalence and location of PLCs that need 
protection, the interference potential from Amateur Radio operation and 
notification requirements, and just how much protection the PLCs 
actually need. "They are not responsive at all to the plethora of 
questions asked by the Commission in the Notice," the ARRL continued, 
"and those points that UTC makes are unsubstantiated."

The ARRL said that PLCs are not nearly as prevalent in the 630 band as 
the UTC has suggested, and that, in any case, such systems already 
operate as unlicensed Part 15 services that must not cause interference 
to licensed services and must accept interference from them. The League 
has indicated that any rules applicable to 2200 meters should also 
suffice for 630 meters. Nonetheless, the League said, it's willing to 
work with utilities in setting up a notification procedure to address 
the unlikely possibility that Amateur Radio operations in the two bands 
might interfere with critical PLC systems.

"In order to implement this, UTC should be called upon to provide to 
ARRL or to the general public a list of transmission lines carrying PLC 
which make use of either of the two subject bands, thus to facilitate 
notification," the ARRL reply comments said. "This would have the double 
benefit of encouraging a complete PLC database while permitting accurate 
determinations of which transmission lines are carrying PLC which have 
any potential at all of adverse interaction with amateur stations." Once 
notification is made, though, the burden should shift to the utility to 
establish that there would be harmful interference, the ARRL said.

"The likelihood of an amateur station conducting operations in the 2200 
or 630 meter bands from a fixed station located less than 1 kilometer 
from a PLC-carrying transmission line upstream from a distribution 
substation is exceptionally low," the ARRL asserted. "Many transmission 
power lines do not carry PLC at all. Most PLC systems do not use the 
very small amateur allocations at 2200 or 630 meters."

The League concluded by calling on the FCC to allocate 630 meters to 
Amateur Radio, as proposed in the Notice, reject UTC's proposal to 
elevate the status of PLCs, and implement a notification procedure for 
amateur stations within 1 kilometer of a transmission line carrying PLC 
in or near the two bands, and to make the LF and MF allocation changes 
in Part 2 and the Part 97 service rule changes, "as proposed by ARRL and 
not otherwise."