[arrl-odv:19045] As-filed ARRL Reply comments on Section 97.113 of FCC Rules; WP Docket 10-72

Greetings. I hate sports babble, but I must say that the Executive Committee "came together as a team and got the job done." Attached are as-filed reply comments that address the more than 200 comments filed in this proceeding. Most of them-- approximately 90 percent according to research Dan Henderson and I did -- support the FCC proposal to permit employees to provide communications on behalf of their employers during government-sponsored emergency communications drills and exercises, during the pendency of those drills and exercises. Our comments urge a rule only a tad broader than that, of course. This docket is very delicate, and the wording that is ultimately adopted is critical, which is why the Board's language is repeatedly touted precisely. We did get some mileage out of working with the American Hospital Association, which supported the Board's language. We hit Boeing and Arlington County, Virginia pretty hard here, because their comments opened the door far too wide to abuses. Other comments were off the wall, but less credible than these, so we focused on Boeing and Arlington as examples of "selling the farm" (a term not suggested by VP Frahm). These comments were subject to helpful edits from almost the entire Executive Committee, which is exactly the way this process is supposed to work. Thanks to all of them, and especially Dave Sumner and Kay Craigie. And thanks to Dan Henderson who did a good deal of research with me to get these prepared on short fuse, during a time when Dan was recovering from some surgery. Next up: Spread Spectrum power comments due June 14, now under EC review; comments on the 5 MHz channel docket, the comment date for which is not yet determined; and a possible reconsideration petition for broadband allocations at and above 2305 MHz which will have an adverse effect on our 2304 MHz band, the 30-day filing window for which has not yet started to run. 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
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Chris Imlay