SB QST @ ARL $ARLB022 ARLB022 ARRL rebuts late-filed power industry arguments in LF proceeding ZCZC AG22 QST de W1AW ARRL Bulletin 22 ARLB022 From ARRL Headquarters Newington CT March 31, 1999 To all radio amateurs SB QST ARL ARLB022 ARLB022 ARRL rebuts late-filed power industry arguments in LF proceeding The ARRL has rebutted assertions that amateur LF allocations at 136 and 160 kHz could lead to interference with utility-operated power line carrier (PLC) systems. The unallocated and unlicensed Part 15 PLC systems are used by electric utilities to send control signals, data and voice. At the same time, the League urged the FCC to issue a Notice of Proposed Rulemaking to open the LF bands up to amateurs. Last October, the League petitioned the FCC to create low-frequency Amateur Radio allocations at 135.7 to 137.8 kHz and 160 to 190 kHz. The ARRL proposed permitting CW, SSB, RTTY/data, and image emissions at a maximum power level of 2 W effective isotropic radiated power. The utilities' PLCs operate between 10 and 490 kHz. The comments in question--from four parties including Commonwealth Edison and Mark Simon--arrived at the FCC well beyond the December 23, 1998, comment and the January 7, 1999 reply comment deadlines. They also appear to be the only comments filed on behalf of the power industry. The League has requested that the FCC strike the late comments from the record, but it also rebutted their substance in case the FCC decides to accept them anyway. The League debunked Simon's suggestion that ham interference could lead to dire consequences to unlicensed PLC systems. The League said Simon fails to explain why a marginal-level amateur signal would cause problems ''where loud static crashes in the same bands do not.'' The League said PLC systems already have been shown to operate effectively ''in an environment of extremely high power government stations using thousands of watts of EIRP.'' The League also took ComEd to task for suggesting that hams be obliged to protect PLC systems against interference. The ARRL pointed out that PLCs have ''no incumbent allocation status'' and are not entitled to protection from licensed systems. The ARRL acknowledged existence of the PLC systems in its October petition and provided a technical analysis indicating that amateur interference to PLCs was unlikely. The League suggested that the utilities make available an industry database of PLC operating parameters that hams could consult as a guide to avoid interference. It concluded that the FCC should not make allocations decisions ''based in whole or in part on the presence or absence of Part 15 devices in a particular band segment'' since the devices have no inherent allocation status. The League said it remains willing to address any interference cases that might arise and urged the FCC to issue a Notice of Proposed Rulemaking on the ARRL's request ''without further delay.'' NNNN /EX