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   August 9, 2010

   Mr. William G. Longhi

   President and CEO

   Orange and Rockland Utilities, Inc.

   One Blue Hill Plaza

   Pearl River, NY 10965

   Re: EB-10-GB-0097

   Dear Mr. Longhi:

   The Federal Communications Commission has received complaints that
   equipment operated by your utility may be causing harmful radio
   interference to an operator in the Amateur Radio Service. The complainant

   (Name withheld)

   (Address withheld)

   (Address withheld)

   Tel: (Number withheld)

   (Name withheld) has attempted unsuccessfully to work through your usual
   complaint resolution process and as a result the matter has been referred
   to our office. The Commission expects that those responsible for the
   proper operation of power lines assume their responsibilities fairly. This
   means that your utility company should locate the source of any
   interference caused by its equipment and make necessary corrections within
   a reasonable time.

   Under FCC rules, most power-line and related equipment is classified as an
   "incidental radiator." This term is used to describe equipment that does
   not intentionally generate any radio-frequency energy, but that may create
   such energy as an incidental part of its intended operation. To help you
   better understand your responsibilities under FCC rules, I have enclosed
   some of the more important rules relating to radio and television
   interference from incidental radiators.

   According to (name withheld), this problem was first reported to Rockland
   & Orange in April of 2008. Based on the direction of Rockland & Orange,
   (name withheld) then began reporting the problem to the main 800 telephone
   number in April through June 2009. A subsequent investigation conducted by
   the ARRL on November 10, 2009 confirmed and located two significant
   sources of noise. I also understand these sources were conclusively
   identified as causing the reported harmful interference to (name
   withheld's) equipment by signature analysis. Furthermore, the actual
   source on one structure was then further pinpointed during the ARRL's
   investigation. A copy of the ARRL report is enclosed for your reference.

   Subsequent to the ARRL report, I understand that Rockland & Orange
   conducted a second investigation into this matter. According to the ARRL,
   Rockland & Orange's investigation revealed that the two previously
   identified sources were actually systematic of a specific hardware
   configuration on several nearby support structures. Specifically, the
   problematic hardware configuration involves three insulators in a
   tee-shaped arrangement. For your reference, this arrangement is depicted
   in Figure 4, Source #2, of the ARRL report. It appears that structure
   numbers 35, 36 and 51 also have this configuration.

   The Commission has the responsibility to require that utility companies
   rectify such problems within a reasonable time if the interference is
   caused by faulty power utility equipment. As the record shows, it has been
   now over two years since (name withheld) first reported this problem to
   Rockland & Orange. Furthermore, the specific sources that were identified
   in the ARRL investigation also remain unresolved after seven months. While
   I can appreciate the fact that 69 kV transmission line repairs can require
   additional consideration and time, including a planned shutdown of the
   line, I am concerned by the lack of progress that is being made in this
   matter, especially when the complainant, ARRL and apparently your own
   resources have all identified specific sources of interference.

   (Name withheld) reports that at the time of this letter, the noise
   continues with no obvious remedial work to any of the source structures.
   Furthermore, he has had no communication from Rockland & Orange to him
   concerning the repairs, if any, or the planned work schedule.

   Please be advised that this problem, if unresolved, could be a violation
   of Commission rules and could result in a monetary forfeiture for each
   occurrence. Generally in these situations the Commission encourages the
   involved parties to voluntarily resolve such matters without Commission
   intervention. If however it became necessary to facilitate a resolution,
   the Commission can and may investigate possible rules violations and
   address appropriate remedies, including monetary forfeiture.

   Please advise this office in writing as to what steps your utility company
   is taking to correct this reported interference problem within thirty days
   of the receipt of this letter. Include the following details:

    1. Will a shutdown of the line be required to correct this problem? If
       so, please provide a firm date for this shutdown. If a firm date has
       not yet been established, please suggest a general timeframe as to
       when this decision will be made.

    2. If a planned shutdown is required, please provide details on any
       temporary fix that help abate the noise until the planned shutdown. In
       particular, what is the scheduled timeframe for such a fix if one is
       being considered?

    3. If a shutdown is not required to correct this problem, please provide
       a schedule for the repairs.

    4. Please include any additional details or background in this case that
       you feel pertinent.

   After the initial response to this letter, please continue to update this
   office every thirty days,  regardless of any anticipated or planned
   changes, until the repairs are completed. In particular, please provide
   updates on the schedule with an explanation for any changes. If you have
   any questions about this matter, please contact me in writing at: 1270
   Fairfield Road, Gettysburg, PA 17325 or via phone at 717-338-2577. Thank
   you for your cooperation.


   Laura L. Smith, Esq.

   Special Counsel

   Enforcement Bureau

   cc: New York Field Office

   Northeastern Regional Director