The ARRL has told the FCC that Amateur Radio operation in the new 135.7-137.8 kHz (2200 meters) and 472-479 kHz (630 meters) bands should be as unfettered as possible from a regulatory standpoint. The League spelled out its case August 31 in detailed comments (also attached below) that argue in favor of flexible FCC Part 97 regulations in light of the exceptionally low interference potential to unlicensed power line carrier (PLC) systems that utilities use to manage the power grid. In its April Report and Order, Order, and Notice of Proposed Rulemaking (R&O/NPRM) in ET Docket 15-99, the FCC had raised several questions regarding how Amateur Radio and PLC systems might coexist. The ARRL said, in its view, there is little to no evidence that Amateur Radio operation would be incompatible on the LF spectrum, where the great majority of PLC systems are deployed, and that few, if any, PLCs operate in the MF band.

“The allocation of the 2200 meter band, together with the proposal to adopt flexible rules for the use of that first LF allocation, and the proposal to allocate the 630 meter band for amateur use, when implemented, will complete at least a basic complement of Amateur Radio allocations in all portions of the radio spectrum domestically,” the ARRL told the FCC. “It is readily apparent from the record…that there can most assuredly be compatible operation by amateur stations in both the 2200 and 630 meter bands without adverse interaction with PLCs.”

The League asserted that “well-established notification procedures conducted entirely in the private sector” as well as the sharing of available database information should facilitate compatible operation. “Notification procedures will be necessary only in those predictably few instances in which geographic proximity and co-channel or overlapping channel operation occurs,” the ARRL added.

The League requested that the FCC finalize service rules for 2200 meters that the ARRL outlined, and that it create the proposed 630 meter allocation. Operation on 2200 meters would be limited to 1 W EIRP, and operation on 630 meters held to 5 W EIRP, in both cases with an absolute EIRP transmitter output limit of 1500 W PEP and a 200 foot maximum antenna height. Assuming continued PLC compliance with Part 15 rules, the ARRL argued, “there is no significant interference potential to PLC systems operated on an unlicensed basis in that very small segment of the 9-490 kHz band that is available for PLC operation, even at separation distances of less than 1 kilometer from the transmission line. At distances of 1 kilometer or more, there is no chance of interference to a PLC line whatsoever, and no restrictions on Amateur operation outside of that distance need be imposed.”

The ARRL said PLCs that might be operating in the two bands should be frequency agile enough to relocate to frequencies falling outside the proposed allocations, making additional regulations unnecessary. The League has conducted a lengthy and ongoing experimental operation (WD2XSH) on 630 meters. It pointed out that it was “unaware of any reports of interference to PLC systems arising from that operation conducted pursuant to numerous Part 5 experimental licenses…in the large band utilized by PLCs.”

The League agreed with the FCC’s proposal to make both 2200 and 630 meters available to Amateur Extra, Advanced, and General licensees. The ARRL also said the FCC should provide “maximum flexibility with emission types” emissions throughout the 630 and 2200 meters, including CW, RTTY, data, and even phone and image, the last “especially at 630 meters.”

The ARRL also commented on the FCC’s proposal to amend its Part 80 rules to permanently authorize radio buoy operations on the “open sea” under a ship station license in the 1900-2000 kHz band, which the Commission recently elevated to primary for Amateur Radio. The League said there is “no evidence of compatibility” between Amateur Radio operation in the band and the “heretofore illegal” ocean buoy operations there.

“[S]hould the Commission proceed with its proposal…to make the 1900-2000 kHz band available to commercial fishing vessels for use by radio buoys on the open sea and to include them in the equipment authorized as part of a ship station license, it should not do so by means of a primary allocation for these devices in ITU Regions 2 and 3 as proposed,” the League said. “The entitlement to utilize radio buoys should be on a secondary basis to the Amateur Service (and other radio services operating in the 1900-2000 kHz band), and the buoys should be prohibited from causing harmful interference to Amateur stations without qualification.”

In a footnote, the ARRL said, “The record is silent heretofore as to the need to use radio buoys in this frequency range. There is no information as to the necessary path distances for these devices and why a band with very long distance propagation is necessary for these buoys rather than VHF or some other suitable alternative.”