Greetings. Attached are as-filed copies of a Petition for Rule Making and a Request for Temporary Waiver that we filed with FCC yesterday, following the approval of the Executive Committee. The purpose of these two documents is to authorize the use of single-time-slot Time Division Multiple Access (TDMA) emissions in Amateur bands at and above 50 MHz, wherever multiple-time-slot TDMA is authorized. This will, simply stated, allow those amateurs who are presently using a Motorola narrowband (12.5 kHz) digital land mobile system commercially marketed as "MotoTRBO" to be used legally. Now, because of some historical but apparently unintentional restrictions in the Part 90 rules, the TDMA repeaters (which are multiple-time-slot devices) are arguably legal but the mobiles and portables are not because the emissions used (single-time-slot TDMA) is not authorized anywhere due to the emission designator. This is a somewhat arcane regulatory problem, but there are apparently more than a few of these MotoTRBO repeater systems being used, and the narrowband character of them should be encouraged. So, at the EC's instruction, and by virtue of a "deal" we cut with the FCC's Mobility Division, we have filed the petition and the request for waiver. The waiver is necessary because it takes the FCC a long time to process a rulemaking petition, and these systems are in operation now. FCC is willing to grant the waiver as soon as they give the Petition a file number and place it on public notice. Please keep the terms of the FCC deal confidential for now, but the Petition and Waiver request are public information as of right now. You can feel free to send these documents to any of your consituents who are interested in the subject matter. Thanks to Dave Sumner, Kay Craigie and Brian Mileshosky for their extensive help on this, and to the EC for its quick review, helpful edits and approval. This represents a good step forward toward encouraging the use of narrowband emissions in the bands above 50 MHz and an increase in flexibility in rules that were designed for analog emissions. By the way, in looking at the first page of the Petition, it may appear to you that the "Filed/Accepted" stamp from FCC is crossed out; but it is not. The "Filed/Accepted" stamp was simply unfortunately placed by the FCC clerk that accepted the paper filing; he or she stamped right over the blank line that I had typed in for the RM number. The filing was in fact filed and accepted on March 15. 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