Dave summarized the meeting very well. I had heard from a ham within the National Association of Broadcasters who is heading the NAB's efforts against the Enforcement Bureau reorganization that an order implementing the Bureau reorganization is now on circulation among the Commissioners. Indeed, Jennifer Thompson did not deny it when we mentioned it yesterday. However, looking at the list of items on circulation among the Commissioners (which is very short; the current chairman has done a good job of clearing the backlog of outstanding docket items) I can't verify that there is such an item on circulation. There are now four items marked "enforcement bureau" but those have appeared for years on that list indicating NALs or Forfeiture Orders on appeal. So it may be that NAB is mistaken about whether or not there is among the Commissioners a specific order on this subject. We will attempt to clarify this in the near term. 73, Chris W3KD On Wed, May 6, 2015 at 9:53 AM, Sumner, Dave, K1ZZ <dsumner@arrl.org> wrote:
Yesterday, May 5, Chris Imlay, Riley Hollingsworth and I met with Jennifer Thompson in FCC Commissioner Rosenworcel’s office to express our concerns about the planned reorganization of the Enforcement Bureau’s
field offices. See arrl-odv:24044 dated March 11, arrl-odv:24150 dated April 6, and the May QST editorial for background.
We had sought a meeting with the Commissioner herself but were told that was not possible because of her travel schedule. We have reason to believe that she might be a swing vote (although the Chairman generally gets his way).
Chris had prepared the attached briefing memo that he sent to Ms. Thompson before our meeting. She clearly had done her homework on the issue; she was, for example, familiar with the editorial. She gave us her full attention for 30 minutes, took extensive notes and asked several questions. Riley supplemented the topics covered by the memo by sharing his experience, in particular making the point that visible enforcement in the Amateur Radio Service spills over to the other radio services because so many hams are in, for example, the broadcasting and land mobile services. Chris and I emphasized that while the consultants claimed to have talked to a wide range of stakeholders before preparing their report, they didn’t talk to us --- nor has there been any opportunity for public input. We expressed doubt that the consultants understand RF and skepticism that the Commission’s goal of being able to be on the scene of a serious interference incident within 24 hours is achievable with just three offices west of the Mississippi.
While influencing a Commissioner on the majority side to resist the Chairman is always an uphill battle and we had low expectations going in, all three of us felt that the meeting went somewhat better than expected. Whether it will affect the outcome (the reorganization reportedly is on circulation) remains to be seen, although to be realistic there is not much basis for optimism.
Dave Sumner, K1ZZ
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-- 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