Dick, of course we can call Bill Cross and ask him. I will do it right away if you want that done. But please understand that he doesn't make the decision whether or not to proceed with a rulemaking once a petition is filed, or whether one is timely; he would likely not have a substantial voice in the process, so asking him would be a waste of time, and conveying his opinion to the Board would be an unreliable metric for whether or not to file. No one at FCC who is in a decisionmaking position on the subject (which is in the Wireless Bureau's "front office" initially, and their recommendation is made to the Commissioners, who will decide whether or not to issue a Notice of Proposed Rule Making based on that petition) will give anyone an "advance read" on whether or not an unfiled petition is or is not untimely. They will require that a petition actually be filed, and then they will adjudicate it on the merits. It is a process that takes many months, and it may not be decided until the petition is given a file number, and public comments on the petition are received.

-----Original Message-----
From: Richard J. Norton <richardjnorton@gmail.com>
To: arrl-odv <arrl-odv@reflector.arrl.org>
Sent: Wed, Mar 31, 2010 1:38 am
Subject: [arrl-odv:18805] Re: Returning CW Nets and Digital Modes to 3600 - 3750 kHz

Do any of the ARRL people who interact with the FCC have a
relationship with Bill Cross where they could call him up informally
and ask how he views this idea? If yes, would someone do so?

If not, is it acceptable to ask someone who does know him to
informally ask the question? I note that directors are not supposed to
communicate with FCC people.

73,

Dick Norton, N6AA

On Mon, Mar 29, 2010 at 6:26 AM, Chris Imlay <w3kd@aol.com> wrote:
> It strikes me that Tom is correct (unfortunately). We certainly were not
> happy about the decisions that the FCC made in Docket 04-140 concerning 80
> meters, and in fact we filed a reconsideration petition (which was denied in
> Docket 05-235 in December of 2006). Joel Harrison complained about that to
> then (Acting) FCC Chairman Michael Copps about it. Of course, nothing
> happened, but all this is relatively recent (in FCC time) and the chances of
> getting a change now, this soon after the 05-235 Report and Order are
> questionable. While one might think that there is no harm in asking, if FCC
> was to deny a petition based on the fact that 05-235 was sufficiently
> recent that a further change petition is untimely (i.e. repetitive) would
> set the effort back a good ways.
>
> We will do whatever the Board wishes, of course, but the price of failure
> here in terms of time lost before we could ask again is potentially high, as
> Tom says.
>
> 73, Chris W3KD

>
> -----Original Message-----
> From: Tom Frenaye <frenaye@pcnet.com>
> To: arrl-odv <arrl-odv@reflector.arrl.org>
> Sent: Sun, Mar 28, 2010 10:20 am
> Subject: [arrl-odv:18755] Re: Returning CW Nets and Digital Modes to 3600 -
> 3750 kHz
>
> At 10:08 AM 3/25/2010, Mickey Cox wrote:
>>The ham community is not ready to make wholesale changes in our regulations
> regarding modes/subbands, etc., but we might be successful in convincing
> enough
> folks to support opening up 100 or 150 kHz on 80, perhaps at least on a
> trial
> basis of two or three years.
>
> Mickey -
>
> I don't think the holdup would be the ham community, it would be the FCC.
> It
> would be very unusual for them to re-examine an issue they decided less than
> five years ago, and especially unusual for them to reverse themselves, even
> though I agree that they made a bad mistake.   I also think you'll find most
> Board members agree that it was badly handled by the FCC.
>
> So the question is really when do we go back and raise the question again -
> and
> for that I'd defer to Chris/Kay/Dave for their expertise.  If we go too
> early,
> it will just push the time for possible change out another five or more
> years...
> Plus, as we learned even in the "simple" spread spectrum NPRM that just came
> out, we can ask for something that seems reasonable and the FCC will screw
> us...
> (I think K5UR trademarked that phrase. )
>
> I wouldn't stir the pot in the amateur community unless we really think
> there is
> a path to success.  Nothing worse than raising expectations and then looking
> impotent - which we are sometimes.
>
>          -- Tom
>