MEMORANDUM   To:                  ARRL ODV   -- Confidential From:              Chris Imlay, W3KD Re:                  Riley Hollingsworth Retirement and Replacement Issue Date:               June 26, 2008               Greetings. I wanted to bring you up to date on the Riley Hollingsworth replacement issue, because it seems to be a problem in the making, and because it is going in an entirely different direction than Riley allowed us to believe.               Riley is retiring July 3. This is not news. He told us this on April 28. But at that time, when Riley announced for the second and obviously now final time that he was retiring, he had led us to understand that his replacement was his “hand-picked” colleague, Bill Knowles-Kellett. He said that Bill would almost certainly be his replacement and wanted the job. I had met Bill on an earlier occasion in Gettysburg and he is certainly competent to take Riley’s place. Bill is not a ham, but was experienced in land mobile radio enforcement issues, which are not significantly different from ours. Riley said that Bill was interested in the job and was going to get a ham license as part of the deal. Riley also said that he would not retire unless he was certain that the enforcement program would continue unabated as he had been doing it. He claimed he had the requisite assurances that this would occur.               Then things started to change. Riley said that the Enforcement Bureau would have to post the job publicly, and that Riley was worried that the job would be moved to Washington. If that happened, Riley said that he was concerned that the job would be diluted, and that the person that replaced him might be tasked with a significant number of other enforcement obligations and that Amateur Radio enforcement might take a back seat.               Riley had suggested that we meet with his boss in the Enforcement Division, Kathy Berthot, Chief of the Spectrum Enforcement Division. I met with her (and with George Dillon, a colleague of Riley’s at FCC in Washington) in May, and made a strong pitch that Riley’s work be continued unabated. I also mentioned that while I understood that Bill Knowles-Kellett was interested in the job, and we would be satisfied with Bill,  we couldn’t attempt to tell the Commission how to run its ship and had no intention of attempting to do so. However, our concern was that the enforcement program in the Amateur Service had validated our strong belief that a very small bit of deterrence in Amateur Radio enforcement is sufficient and necessary, and that we were adamant that the program that Riley has been administering must continue without substantial change. I received hearty assurances from both Kathy and George that they agreed with that. They said that the job had to be posted, and that the resolution of that was out of their hands. We have since learned that the Chairman’s office micromanages all hiring of even the lowest level staff, and that no assurances can be given by anyone at the Bureau level at FCC about any hiring decisions.               After that meeting, strong interest in the job was expressed by Laura Smith, a lady who had worked in the past for ITA (now EWA, the Enterprise Wireless Alliance) the former Industrial Telecommunications Association, a land mobile association. She was known to me as an administrative person, but very knowledgeable about land mobile radio regulation. She left ITA and moved, as it turns out, to Carlisle, PA, about 45 minutes from Gettysburg, with her husband, and she is now doing freelance work or contract work from her home in Carlisle for the land mobile lawyers at the Shulman, Rogers law firm in Rockville, MD. She heard of Riley’s job and lobbied hard to get it. Riley and Bill called me to “sell” ARRL on Laura, who at the time seemed to be the front runner for the job. She may still be for all I know. Bill’s being as vocal about it as he was made me think that he didn’t have any interest in the job himself, if indeed he ever really did.               The situation deteriorated further when the job was posted. It was posted as a GS-15 job, which has a salary range of between $115K and $145K per year or thereabouts, so it is a pretty spiffy job for anyone who wants it. But it was posted as being “in the Washington area”. Riley thinks this is broad enough to include Gettysburg, but I don’t. I am afraid that it will be a D.C. job and that Riley’s fear about the job being diluted is very real. It is not unreasonable for them to post this job, but Riley’s assurances to us have largely been shown to be unreliable so far.               ARRL went out with its own news release about this job, essentially soliciting anyone with a ham license and a law degree to apply. This is not necessarily a good strategy, because there are some hams with law degrees in the Washington area that would not do a great job replacing Riley, but who might want the job due to the salary level. On the other hand, a ham would be better in this job than a non-ham. It is unclear what the status is of the continued interest of Laura Smith.               So, while we have very little input into this process and no control at all, we will have to keep the pressure on the Enforcement Bureau to continue the enforcement program unabated, and perhaps it is timely to remind Kris Monteith, the EB Chief (who probably is not overly warm and fuzzy with us now since Joel and I gave her a very difficult meeting about the BPL matter awhile back) that we have high expectations for Riley’s replacement.   Your thoughts on this subject are welcome. I believe that this is a very high priority issue, and I bet Rod Stafford does as well, since it was on his watch as ARRL President that we returned from the dark times of no Amateur enforcement at all, and the difference has been amazing. Incidentally, contrary to what you will read on ARRL’s web site, it was not Riley who brought Amateur Radio enforcement back; it was Richard Lee, who has now faded into obscurity at FCC due to some whistle blowing he did (quite properly), but before Rich fell from grace at FCC, he resurrected Amateur Radio enforcement single handedly, and put Riley into the job (after Rich did it himself for a time, and very effectively, I might add).   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