Greg, normally, making predictions about what FCC is "going to do" is very risky forecasting indeed and you are right to be skeptical (we have all learned a good lesson from Rick Roderick, after all). This time, the information we have about this NPRM is quite reliable. I believe that the FCC will in fact release this NPRM sometime soon, and that it will propose (and be limited to) the codification of the present waiver process, as the options paper indicates. Just a factual aside.... 73 and Happy New Year; 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 -----Original Message----- From: Greg Sarratt <w4ozk@arrl.org> To: arrl-odv <arrl-odv@reflector.arrl.org> Sent: Tue, Dec 29, 2009 9:54 pm Subject: RE: [arrl-odv:18367] Options paper, Section 97.113 Good job on the opinion paper. We should wait to see what the NPRM contains. If Chris is correct, then we should do nothing. If the NPRM does not materialize and things stay as they currently are, then we should do nothing. The Status Quo is working, no one is prohibited from transmitting, training or exercising. It does appear that fear-mongering exist and a few folks are trying to making this subject out to be much more than it is, which is unfortunate. 73, Greg Sarratt, W4OZK From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org] Sent: Monday, December 28, 2009 3:19 PM To: arrl-odv Subject: [arrl-odv:18367] Options paper, Section 97.113 Item 10.d. on the draft agenda for next month’s Board meeting is the development of the ARRL position on possible amendment of the FCC rules concerning pecuniary interest and communications on behalf of one’s employer (Section 97.113). To assist the Board in its deliberations the Executive Committee requested that an options paper be prepared. General Counsel Imlay and Regulatory Information Manager Henderson developed an excellent paper, which is attached for your review. There will be ample opportunity for discussion of the issues addressed in this paper at the meeting, but of course any consideration that you can give to them in advance of the meeting will facilitate the Board’s work. 73, David Sumner, K1ZZ Secretary <<97.113 Options FINAL.doc>>