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

ZCZC AG10
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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/
omment/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."

NNNN
/EX

)\/(ark

Always Mount a Scratch Monkey

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 * Origin:  (1:3634/12.73)