Phil: I would not just relay that to members who will repeat it, except to say we are on top of it and there is NO advantage to filing early. Better right than rush. I sometimes find that is true in my own practice as well. Bob Famiglio, K3RF Vice Director - ARRL Atlantic Division 610-359-7300 www.QRZ.com/db/K3RF -----Original Message----- From: arrl-odv On Behalf Of Phil Temples Sent: Thursday, October 29, 2020 2:46 PM To: david davidsiddall-law.com <david@davidsiddall-law.com> Cc: arrl-odv@reflector.arrl.org Subject: [arrl-odv:31249] Re: ARRL comments to Docket 20-270 NPRM Dave, This is good information to know, thank you! I figured that there was probably a good reason for waiting. Phil On Thu, Oct 29, 2020 at 2:39 PM david davidsiddall-law.com <david@davidsiddall-law.com> wrote:
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
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