The attached comments were filed yesterday by Brennan Price in an FCC International Bureau proceeding having to do with domestic preparations for two upcoming ITU conferences: the World Telecommunication Development Conference to be held in Hyderabad, India next month and the Plenipotentiary Conference to be held in Guadalajara, Mexico in October. There will be no ARRL representative on the US delegation to Hyderabad, although Rod Stafford will be present on behalf of the IARU as IARU Secretary. Jon Siverling will be on the US delegation to the Plenipot. In an ITU-related FCC proceeding it is normal for Brennan to draft the ARRL comments but for them to be filed by Chris Imlay as General Counsel. Brennan is the most familiar with the issues and with the state of domestic preparations for these conferences through his participation as a Board member of the US ITU Association. In this instance the draft was not available until the morning of the comment deadline, a delay for which Brennan accepts responsibility and apologizes. The draft was coordinated with Kay, Rod, Jay Bellows, and me, and was also sent to Chris, but as he is in Las Vegas at the NAB Convention he was unable to participate in the review prior to yesterday's close of business at the FCC. I also was unavailable late yesterday afternoon, and with the deadline looming Brennan made what I believe was the right decision under the circumstances, which was to file the comments over his own name on behalf of the ARRL. Kay has made it clear to the EC that this was a one-time departure from the normal process of filings being reviewed by the EC prior to filing and their being filed by the General Counsel. We will do everything we can to avoid a repetition. Dave Sumner, K1ZZ