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 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