Greetings. Some interesting developments this afternoon. It appears from our FCC sources that there was a meeting involving only NTIA reps, individual Coast Guard, Justice and Navy IRAC delegates, and FCC (OET and WTB) staff at FCC about three weeks ago. I know most of the attendees, Paul knows the rest. We of course were not invited; NTIA wanted it that way. NTIA decided that they were exempt from the ex parte rules, though FCC staff asked whether the meeting had to be reported as an ex parte in the docket proceeding. So it wasn't reported. The Coast Guard rep and the Justice Department rep reportedly "whined" about protecting their assignments, and that they didn't want to have to track down interference from Amateurs in the course of their "National Security" efforts. When FCC asked the Justice Department rep how many stations Justice had in the band at issue, she replied "two". The Coast Guard said that their ALE protocol, by which their radios search for a vacant channel before transmitting (kind of like trunking, I guess, not being as familiar with this as Paul is) will bypass a channel in which, apparently, there is ANY noise found, so the Coast Guard especially is concerned that they will not be able to use channels due to noise from Amateur signals which would lock out the channels. The communications, however, are normal SSB. The FCC had a post-mortem meeting after the NTIA presentation, and (we are told) were of the collective view that this was standard NTIA "dog-in-the-manger" attitudes, and represented no more than an effort to protect turf, rather than a realistic concern about interference. I have a scheduled conference with Tom Derenge on Monday. Tom does allocations for OET. He had not this afternoon read the NTIA letter, but heard from Kathy Medley (who has yet to return my calls -- plural --) that it had been filed. He will read it and discuss it with me then. It may be premature to worry about cutting any deals with NTIA, if there is a reasonable prospect that FCC will disregard the NTIA submission. While I mentioned yesterday that FCC had no incentive to override NTIA, I may have been too pessimistic. First, the IRAC has already passed off on this NPRM, over the dissent of the Coast Guard and the Justice Department. So NTIA's letter rings just a bit hollow at this late date. Second, FCC would have some major egg on its face having to back off on the allocation after proposing it. So, it may be that FCC will be on our side here. The downside is that FCC might be inclined to propose some severe restrictions on Amateur operation in the band as its bow to accommodate NTIA. The good news is that, according to an FCC attendee at the secret NTIA/FCC meeting, NTIA was persuaded that an "Extra Class Only" restriction would be counterproductive: the Extra Class licensees are the most active group on the HF bands, and would be the least desirable single class of licensees to have access there. Nor would it be a good idea to create a special preserve for Extra Class licensees in an exclusive band, which would encourage active operation there. NTIA has apparently backed away from that proposal, and Russ Slye's separate comments to me bear that out. I have a few more calls out at FCC, but am somewhat more encouraged than I was from just reading the NTIA comments and speaking with Slye. This is entirely confidential, of course! 73, Chris W3KD