Ria,
Not really. I’ve never asked for an extension that wasn’t client-driven.
It is a disadvantage to file early in a rulemaking proceeding. Putting the arguments out before the deadline increases the opportunities for opponents to argue against your position and the time to do so, including solicitation of others
to do so. There is no regulatory advantage that counter-balances the negative. FCC staff don’t begin to look at the comments until well after the last deadline. They are working on other proceedings -- it’s not like they handle only one thing at a time,
or that they have a personal attachment to or interest in the subject.
Dave
From: "rjairam@gmail.com" <rjairam@gmail.com>
Date: Thursday, October 29, 2020 at 2:30 PM
To: "david@davidsiddall-law.com" <david@davidsiddall-law.com>
Cc: Phil Temples <phil@temples.com>, "arrl-odv@reflector.arrl.org" <arrl-odv@reflector.arrl.org>
Subject: Re: [arrl-odv:31246] Re: ARRL comments to Docket 20-270 NPRM
I figured... I’m working with an attorney on some litigation now and it’s frustrating because the firm never ever responds early and always ask for extensions. Same with the other party. It’s been dragging on over a year now.
I guess that’s standard practice.
73
Ria
N2RJ
On Thu, Oct 29, 2020 at 2:23 PM david
davidsiddall-law.com <david@davidsiddall-law.com> wrote:
My practice is to file comment on the due date, and not before. Always.
On 10/29/20, 2:22 PM, "arrl-odv on behalf of Phil Temples" <arrl-odv-bounces@reflector.arrl.org on behalf of phil@temples.com> wrote:
I've been following various amateur radio threads about MD Docket
20-270 NPRM comments on social media, and there's some pretty strong
criticism of the League for not yet filing comments. (I know--it was
published in the Federal Register just two weeks ago.;-)) I've also
been asked about this, personally.
Any time estimates on when ARRL comments will be posted to the FCC ECFS?
Thanks and 73,
Phil Temples, K9HI
Vice Director
New England Division
--
Phil Temples <phil@temples.com>
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