Generally as a condition of employment in my experience, public statements concerning an employer by employees is restricted as a matter of policy since it could be interpreted as an official statement from the company. It also directly correlated to the position one holds. IIRC, Fusaro’s title is “director of operations.” As such public statements concerning ARRL policy or FCC petitions could be interpreted as being the opinion of the ARRL as it comes from a senior manager with the title “director.” That’s the major problem I have with it. As for the venue, it is what it is. I think bringing this to the board and asking the CEO to address the board on this is entirely appropriate as the comment concerns a public action. 73 Ria N2RJ On Tue, Mar 19, 2019 at 2:36 PM <jbellows@skypoint.com> wrote:
If the question was truly for CEO Michel it is interesting that you chose to address it on ODV rather than directly with him.
Are asking if an ARRL employee is precluded from expressing his or her views in an FCC individual comment to a Rule Making proceeding as a condition of employment or suggesting an ARRL employee may only comment if permitted by the ARRL Board?
Jay, KØQB
*From:* arrl-odv <arrl-odv-bounces@reflector.arrl.org> *On Behalf Of *John Robert Stratton *Sent:* Tuesday, March 19, 2019 12:51 PM *To:* arrl-odv@reflector.arrl.org; Michel, Howard, WB2ITX (CEO) < wb2itx@arrl.org> *Subject:* [arrl-odv:28047] Regarding The Filing of Comments to RM-11828 By An ARRL Employee
Howard
All Board Members — Directors and Vice-Directors — are prohibited from filing individual comments on FCC petitions filed or supported by the League. To my knowledge, the Board has not authorized employees to make such filings.
In light of the foregoing, would you be so kind as to please explain Mr. Fusaro's most recent filing in connection with RM-11828?
Thanks.
______________________________________
John Robert Stratton
N5AUS
Director
Legislative Director
West Gulf Division
Office: 512-445-6262
Cell: 512-426-2028
P.O. Box 2232
Austin, Texas 78768-2232
*______________________________________*
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