I have sent a few former posts on 97.113 and hospitals. As a physician, this issue has received my direct attention. My short version of this post is that the board's proposed change to 97.113 will easily handle the concerns of hospitals in regards to TJC (The Joint Commission-their new designation) accreditation. Second, in regards to the "Grates" concern, I am certain that the AHA is representing not only the hospitals, but the hams that are employed by the hospitals and volunteers. The South Carolina Hospital Association has the same idea, but going at it a different way, by working though elected officials to bring awareness to the FCC about hospital emergency preparedness concerns. I am certain that both feel that an organization such as the AHA or SCHA would have more political clout with the FCC than an independent group of amateurs operating within their organizations. I have heard over and over about first using commercial frequencies for backup. MY hospital alone has SEVEN commercial frequencies WITH TWO commercial repeaters for backup, with over EIGHTY portable HT's. THOSE WILL BE USED FIRST for backup communications, after telephone, fax, cell, etc. The hospital employees, including hams, will use those frequencies first. "When all else fails", ESPECIALLY hospital to hospital communications, Amateur radio will need to be used. This was the basis and rationale for the SCHEART system. When disaster strikes, volunteer hams may not be available. Resources are thin. They may evacuate, participate with RACES or other organizations, or may not be able to get through roadblocks. Hospital employed hams MAY BE THE ONLY OPTION. Foremost, the hospital hams MUST HAVE PROPER TRAINING! The board's proposed change of 97.113 will NOT let the "Genie out of the bottle", but will allow emergency based organizations, including hospitals, conduct training necessary to affect proper amateur radio operations during an emergency situation. The following seems to be self-serving, but it is certainly not meant to be: I am the Chair of the Board of Governors of my Medical Center. We have just been surveyed by The Joint Commission. Our Emergency Preparedness Director is a ham, an ASM that I previously appointed during my Tenure as SM The comments by TJC surveyors was that our Emergency Preparedness Plan (and subsequent drills) was second to none they have seen in the country and considered as a "best practice". Our Amateur Radio initiative is an integral part of our Emergency Plan, and was received VERY favorably by the surveyors. Who benefits? The Public! Keep on Target! '73 de JIM N2ZZ ARRL Vice Director Roanoke Division ARRL, the national association for Amateur RadioT From: Chris Imlay [mailto:w3kd@aol.com] Sent: Monday, February 22, 2010 5:51 PM To: arrl-odv Subject: [arrl-odv:18580] Re: American Hospital Association waiver request Yes, here is the insider trading on this: When Dave and I met with Charles Mathias in Commissioner Baker's office, we were advised by Charles to speak with Bryan Tramont, a former big honcho staffer on the 8th floor at FCC some time ago, who we know and have had a lot of interaction with. Very competent guy. He landed at the Wilkinson, Barker, Knauer firm (as I was once invited to do at the time that W3PS died in 1981; I turned them down, but it is a good solid law firm, though too large and bureaucratic for me). Bryan now represents the American Hospital Association, and they filed the letter. Bryan sent it around to the Commissioners' offices and to PSHSB. It seems to me that the letter is more than a bit conceptually in error, and overbroad; I have not yet called Bryan, and perhaps there is not a reason to do so, other than to persuade him that ARRL's Board policy would accommodate the AHA. They are asking for short term relief though, and the real question is what our position is with respect to this waiver. I would like some guidance on this. It grates somewhat to have a non-Amateur Radio group attempting to determine policy for the Amateur Service. We reacted quite agressively many years ago when the NAB attempted to open the business communications rules to permit amateurs to provide certain types of electronic news gathering communications. They have their own broadcast auxiliary spectrum for that; just as hospitals have Part 90 radios for their internal communications, even internal emergency preparedness exercises. There is no reason their ham employees can't use those radios for that purpose. 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 -----Original Message----- From: Brian Mileshosky <n5zgt@swcp.com> To: arrl-odv <arrl-odv@reflector.arrl.org> Sent: Mon, Feb 22, 2010 2:24 pm Subject: [arrl-odv:18576] Re: American Hospital Association waiver request The League-proposed language may meet their needs, but one has to wonder about their motivation for making such a disingenuous argument in the first place. Hopefully this isn't an example of, in the words of either Chris or Dan at the last board meeting, "once the genie is out of the bottle..." 73, Brian N5ZGT On Mon, 22 Feb 2010, Sumner, Dave, K1ZZ wrote:

The attached waiver request was shared with us this morning.

The language we are proposing for 97.113(a)(3) would seem to meet their needs. That said, it seems disingenuous of AHA to argue that participating in a drill that is required in order to maintain your employer's accreditation is not "on behalf of" the employer.

Dave K1ZZ

<<Am Hospital Assoc_Request for Blanket Waiver Sec 97 113(a)_DATA-STAMP_2-17-2010.pdf>>

ARRL Director, Rocky Mountain Division On the web at www.RockyMountainDivision.org <http://www.rockymountaindivision.org/>