Greetings. The attached comments were filed today (the due date) by authority of the Executive Committee. These comments were thoughtfully developed by President Craigie with input from Dave Sumner, Maria Somma, and Tom Frenaye. I wrote them up from that input, and then received very helpful edits on various draft versions from Kay, Maria and Dave. Kudos to them especially in this proceeding. You be the judge, but these are, I think, some good, insightful comments. Please let me know if you have any questions. On March 10, I am scheduled to represent ARRL on a panel at the FCC about this docket proceeding. The Office of the Managing Director is following up on our prior participation in a workshop at FCC last year on the new Consolidated Licensing System now in the process of development. I will during the March 10 panel, of course, limit my remarks to the extent possible to advocating the positions taken in these comments. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG