I thank the Executive Committee for its quick review and Chris for his edits and filing. I recommended filing favorable comments in large part because our allies in the DoD (at least at the senior executive level) are committed to real-world testing of spectrum sharing arrangements going forward. They justifiably view it as an improvement over some scattershot approaches that have been taken in the past. DOD's main concern was that real-world testing in a Model City should come at the proof-of-concept stage, only after joint, public-private negotiation and analysis of a sharing protocol and testing in a controlled environment. They also didn't want a permanent Model City named, as there is no one city that will be ideal for each analysis. Their positions on both these issues were also in our interest, so I worked them into our main argument, which Chris accurately described. This was a good exercise in keeping our sharing partners close. The chance to take a dig at CC&Rs was gravy. And very tasty gravy. 73 de Brennan N4QX Brennan T. Price, N4QX Chief Technology Officer American Radio Relay League 3545 Chain Bridge Rd Ste 209 Fairfax VA 22030-2708 Tel +1 703 934-2077 Fax +1 703 934-2079 ________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of Imlay, Chris, W3KD Sent: Friday, August 29, 2014 12:38 To: arrl-odv Subject: [arrl-odv:23251] FCC Comments as filed, Docket 14-99; Model City for Demonstrating and Evaluating Advanced Sharing Technologies Greetings. Today, with the approval of the Executive Committee, I have edited and filed the attached comments with both FCC and NTIA. FCC and NTIA jointly propose in this proceeding to establish, via a public/private partnership, a "model city" (i.e. an urban environment) that is considered a test bed for spectrum sharing and technology development and initial rollout and evaluation. The original idea came from the President's Council of Advisors on Science and Technology in 2012. These comments were prepared initially by Brennan Price and reviewed by me when I first saw them yesterday afternoon. The basic premise of our comments is that there can't be a model city for technological development and spectrum sharing without integrating Amateur Radio in it. There is also an important segment at the end about the inherent inequity and failure of the concept of a Model City for technological rollout and testing if some of the services in the model city are saddled with public,private or environmental antenna regulations which preclude the creation of a realistic environment. The EC has directed that we monitor this proceeding because, absent our meaningful participation in Model City technological investigation, we could be very much out in the cold. Today is the comment date so we will know soon what others have said. There is not a reply comment period permitted by the public notice, but we can get in some rebuttal if we need to do so. This was prepared at the very last minute for various reasons so thanks to the Executive Committee for a quick review and turnaround on this and for their patience. We will try to prevent a recurrence of the timing of this. Let me or Brennan know any questions you have about this filing. 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>