The International Telecommunication Union (ITU) is seeking a frequency allocation in the High Frequency (3-30 MHz) and VHF band of the spectrum for oceanographic surface wave radar. However, the 'Sharing Studies' undertaken for this issue use some inappropriate assumptions, do not sufficiently address what will likely be the most significant interference path, and thus reach incorrect conclusions. These concerns are addressed along with two data collections and an experiment by the Naval Research Laboratory which support these concerns.
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