ARLA/CLUSTER: ARRL insiste que a FCC não imponha a obrigação de notificação previa para operar os 2200 e 630 metros nos EUA

[João Costa > CT1FBF]

 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/comment/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."

The American Radio Relay League