Chris -- (Board copied for its situational awareness.) Is the League researching/engaging ET Docket 15-170? If so, my bad for not recalling. If not, I believe this is something the League should certainly research and, if determined to be necessary, throw its weight behind. Unfortunately, the FCC is in the midst of an IT upgrade that prevents viewing the original document until 08 September, but the Google-cached page that results from a search on "fcc 15-92a1", the website https://libreplanet.org/wiki/Save_WiFi, and other Google searches should provide details in the meantime. As a result of their IT upgrade, I have read that the comment period has been extended to 09 October. By my read, if what's proposed were adopted, this could directly impact or halt the expansion and development of amateur radio mesh networking, HamWan, and other IP-focused ham applications and technologies that leverage modern commercial wireless networking hardware within the United States. FCC's document is 89 pages long, but the general concern I'm raising focuses on what appears to be its prohibiting of new wireless network equipment from end-user modification (i.e. custom software/firmware loads and perhaps even modification of settings that enable out of band operation, both enable amateur use within Part 97 spectrum). A closer look at some of these applications/technologies: --- Mesh networking. Pretty much every mesh network node across the country in use for experimentation, ARES, public service, casual uses are composed of Ubiquiti and Linksys hardware that have been flashed with custom, ham-developed firmware loads that turn them into functional amateur radio mesh networking nodes on 900 MHz, 2.4, and 5 GHz amateur spectrum. --- HamWAN. A different application of IP within amateur radio spectrum, HamWAN sites are composed of Mikrotik hardware that has been modified by the user (legitimately, at least today) to function within Part 97 spectrum. HamWan is likewise used for experimentation, ARES, public service, and casual uses. The main centers of activity are the Pacific Northwest and Memphis, but the technology is also being adopted by hams in other geographical areas. --- There are other amateur radio applications/technologies that leverage modified commercial wireless networking hardware, too. I'm on the leadership team of a Colorado/New Mexico-based ham organization that, among other things, has developed and fielded a 5-GHz IP-based microwave backbone and network that operates on Part 97 spectrum to enable a whole host of applications (repeater linking, ARES comms, experimentation, etc). It is composed of Mikrotik hardware that has also been modified (legitimately, at least today) to function within Part 97 spectrum. This multi-megabit microwave network doesn't rely on the existence of the internet to function, and presently spans from the southern border of Wyoming down to central New Mexico. We are presently working to expand it all the way down to El Paso, Texas. I'd appreciate your read on what FCC is proposing as it applies to the above amateur radio applications/technologies which, among other things, are creating a fair amount of activity on our lesser used bands. These are only three innovative applications/technologies in use within amateur radio spectrum, and more will surely come about in the future through the use of mods to commercial wireless networking hardware. If your read aligns with mine, I'm pleased to help with the crafting of ARRL commentary to FCC. 73, Brian N5ZGT