Greetings. After review and editing by the Executive Committee, with special thanks to Kay Craigie, Dave Sumner and Tom Frenaye for helpful edits and corrections, I have filed this morning electronically the attached comments in the FCC's docket proceeding pertaining to vanity and club call sign rules and procedures. These comments are in two parts. The first addresses the FCC's NPRM proposals. The second addresses ARRL's additional proposals for vanity, club and special event call sign modifications. The Board in January tasked the Executive Committee with developing a firm ARRL position on this matter, and these comments advocate that position, determined after extensive discussion at the EC meeting in Denver a few weeks ago. For a quick summary of the positions advocated, go to the end and read the conclusions section first. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG