Yes indeed, good catch. This proceeding is not in any sense aimed at the 222-225 MHz band, but rather is to determine whether the current darling of the WTB, band managers (i.e. spectrum owners and lessors) should be used in the 220-222 MHz land mobile band. FCC has changed its mind about that band and licensing plans for it so many times that almost nothing can be relied on there, but these comments clearly do call for rebuttal. We will determine the reply comment date and fire back in defense of the 222-225 MHz allocation. 73, Chris W3KD