Greetings. Attached are as-filed comments that I prepared and filed yesterday, the due date. A majority of the Executive Committee reviewed the draft and approved the filing. The comments address a petition for waiver of a Part 90 rule governing Location Monitoring Service facilities in the 902-928 MHz band. RECCO AB is a Swedish company that has developed an avalanche recovery system that is in use in the 866 MHz band in Europe. It involves a handheld detector that can be deployed on the ground or from a helicopter. Skiers protected by the system wear passive reflectors on helmets, boots or clothing. The transmitter can be operated in the USA between 902.85-902.95 MHz. The detector has a receiver on the doubled frequency 1805.7 MHz and, when there is a signal heard on the doubled frequency at the handheld detector, the search and rescue team operating the system can track a buried skier after an avalanche. There are several problems with this, despite the alleged value of the system in saving lives. First, a permanent waiver is sought of a rule that prohibits licensed part 90 location monitoring of anything other than vehicles at 902 MHz. The proper route would have been for RECCO to file a Petition for Rule Making. Second, RECCO admits to having deployed 250 of these systems throughout the USA despite the absence of an equipment authorization grant or the ability to license any of them. Finally, RECCO makes claims that this system has a low interference potential to other services due to the deployment environment and because of an alleged low duty cycle. Neither of these allegations is correct for the reasons discussed in these comments. Thanks to Dave Sumner and Kay Craigie for helpful edits to this pleading and to Cliff Ahrens, David Woolweaver and Mike Lisenco for their review and approval of the draft comments. 73, Chris W3KD -- 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