03/10/2016
In an ex parte statement[1] 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[2] 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."
[1] http://apps.fcc.gov/ecfs/comment/view?id=60001498728
[2] https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-50A1.pdf
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