Jim, since no one else has commented let me offer one. It would be best to concentrate on quietly getting rank-and-file members and other supportive amateurs to file, consistent with Chris Imlay's memo to the EC earlier this week (reproduced below). 73, Dave K1ZZ From: exec-com [mailto:exec-com-bounces@reflector.arrl.org] On Behalf Of Imlay, Chris, W3KD Sent: Tuesday, March 15, 2016 12:45 PM To: exec-com Subject: [exec-com:8116] Filing comments on ARRL's 80-meter refarming petition, RM-11759. On January 8, 2016 we filed ARRL's Petition for Rule Making to effect changes in the 80 and 75-meter RTTY/data and phone/image subbands; to restore 80-meter frequency privileges for certain license classes; to shift the 80-meter automatically controlled digital station band segment; and to authorize Novice and Technician class licensees to utilize RTTY/data emissions in certain bands. The Petition was called for by Minute 32 of the July, 2015 Board Meeting. FCC placed our Petition on Public Notice on February 22, 2016. Comments on the Petition are due March 23, 2016. Reply comments are due April 7, 2016. There are as of now 180 comments filed in this proceeding. A few CW operators and others support the proposal, most without stating firm reasons for their support. However, a majority of the comments filed so far are one-liners from Extra Class licensees who object to having their exclusive phone segment reduced. These are one-sentence, unjustified comments in large part but there is enough volume here that we should be concerned. ARRL will file comments with a restatement of the justification for the petition, and for the proposed reduction in the exclusive Amateur Extra class subband at 75 meters. The executive committee over last weekend decided to quietly urge individual extra class hams to file comments in favor of the Petition. The following is some guidance in doing so. It is easy to file comments in the FCC's ECFS filing system. Go to the following URL: http://apps.fcc.gov/ecfs/hotdocket/list Then click on the proceeding "RM-11759" then type in e-mail and address contact information and type in or paste in your text comments and then click "continue" and then follow the directions for completing the filing. Very easy, very user-friendly. ARRL's Petition includes the following points, per the Board's instruction: (A) To modify the 80-meter RTTY/Data subband defined in Rule Sections 97.301 and 97.305 so that it extends from 3500 kHz to 3650 kHz; (B) To modify the 75-meter Phone/Image subband defined in Rule Sections 97.301 and 97.305 so that it extends from 3650 kHz to 4000 kHz; (C) To provide that the 3600-3650 kHz segment of the 80-meter band will be made available for General and Advanced Class licensees, as was the case prior to 2006; (D) To provide that the band segment 3600-3650 kHz will also be available to Novice and Technician Class licensees for telegraphy (consistent with the existing rules that now permit Novice and Technician Class licensees to use telegraphy in the General and Advanced Class RTTY/data subbands at 80, 40, and 15 Meters); (E) To modify Section 97.221(b) of the Commission's Rules governing automatically controlled digital stations, so that the segment of the 80-meter band that is available for automatically controlled digital operation shifts from 3585- 3600 kHz (as per the existing rules) to 3600-3615 kHz (consistent with the IARU Region 1 and Region 2 band plans); and (F) To provide RTTY/data privileges to Novice and Technician licensees in their 15-meter band segment and their 80-meter band segment, the latter contingent on the rule changes at (A) and (B) hereinabove. In the petition, with respect to the effect of the "rebanding" on Extra Class 75-meter phone operators, we stated as follows: While ARRL received overwhelming support for the proposed 50 kilohertz expansion of the 80-meter band, concern was expressed by a few Extra Class licensees about the proposal, inasmuch as those licensees enjoy the inordinately large, exclusive 3600-3700 kHz segment for phone/image operation. Extra Class licensees, however, should be reminded that the 3700-3800 kHz segment of the 75-meter band is and would continue under ARRL's proposal to be available only to Extra and Advanced Class licensees. Only 7 percent of the Commission's licensees hold Advanced Class licenses, and that number will continue to decline toward zero as this license class is no longer being issued. Even if the phone/image subband at 75 meters is reduced in size from 400 kilohertz to 350 kilohertz as herein proposed, it will still be the largest phone/image subband among all of the HF Amateur allocations. While this seems a reasonable justification for the proposed rearrangement of the 75/80 meter band, a vocal minority of Extra Class licensees that the ARRL HF Band Plan Committee heard from when the surveys were conducted are repeating their concerns to the FCC now. Feel free to resend this to your Board colleagues not on the EC who might be interesting in urging some favorable comments on RM-11759. But we should be surreptitious about this effort lest we energize the opponents of our Petition. 73, Chris W3KD -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG<mailto:W3KD@ARRL.ORG> From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of arrl-odv Sent: Thursday, March 17, 2016 10:36 AM To: arrl-odv Subject: [arrl-odv:25244] Bandplan proposal I was informed about the need to have comments submitted for the ARRL Bandplan proposal now under consideration by the FCC, as discussed during the Exec Committee. I see that the Director's workbook, section 2.2 prohibits those on the board from filing comments with the FCC. Since Vice Directors are technically not on the board, are they free to file comments? Should we be targeting groups which would agree with our proposal and encourage them to file? Perhaps CW/NTS operators or digital ops who would benefit from the proposal (Especially on 80 m)? '73 de JIM N2ZZ Director - Roanoke Division Serving ARRL members in the Virginia, West Virginia, South Carolina and North Carolina sections ARRL - The National Association for Amateur Radio(tm)