Options paper, Section 97.113ODV, There are a number of unhappy members in the Delta Division right now concerning the "strict" interpretation of 97.113 by Bill Cross, etc. For example, over the past several years a lot of hospital employees (particularly in AR, but also in LA, MS, and TN) have received their ham tickets with an obvious eye toward emcomm operations "on behalf" of their employers. In addition, I've heard from disgruntled ARRL members who are either professionally employed in emergency management or closely allied with such organizations. One emcomm manager in TN (who also happens to be a Delta Division Assistant Director) has directly told me that he will use MARS rather than ARES until/unless this issue is resolved. At this time I would like to see more flexibility as outlined in Option C (Expanded Training Option) on page 3 in the Options paper. However, I would also suggest that some time limitations be included with this option in a similar spirit as found in 97.407(e)(4) for RACES tests and drills. For example, an amateur participating in emergency tests and drills "on behalf of an employer" should be limited to one hour per week or a total of 72 hours per year. (We can debate the best choice of numbers later.) A time limitation along these lines would help minimize the risk that businesses would use amateur radio for inappropriate purposes. I look forward to hearing the thoughts from other Board members on this issue! 73, Mickey K5MC ----- Original Message ----- From: Sumner, Dave, K1ZZ To: arrl-odv Sent: Monday, December 28, 2009 3:18 PM Subject: [arrl-odv:18367] Options paper, Section 97.113 Item 10.d. on the draft agenda for next month's Board meeting is the development of the ARRL position on possible amendment of the FCC rules concerning pecuniary interest and communications on behalf of one's employer (Section 97.113). To assist the Board in its deliberations the Executive Committee requested that an options paper be prepared. General Counsel Imlay and Regulatory Information Manager Henderson developed an excellent paper, which is attached for your review. There will be ample opportunity for discussion of the issues addressed in this paper at the meeting, but of course any consideration that you can give to them in advance of the meeting will facilitate the Board's work. 73, David Sumner, K1ZZ Secretary <<97.113 Options FINAL.doc>>