Greetings. By authority of the Executive Committee I have just now filed electronically the attached Petition for Rule Making with FCC asking for implementation of the Parity Act's basic provisions. The Appendix that we used is not precisely the text of the Parity Act Bill language, nor was it intended to be. Instead, it was a version of the Bill language that resulted from two days of collaborative work that Mike Raisbeck, Fred Hopengarten and I spent in Massachusetts last winter. I reported on that comprehensively to the Board last July. I know that there has been a lot of controversy about the timing of this filing, to say the very least. I have explained to the Executive Committee repeatedly why the timing of this filing is critical in terms of preserving the three levels of support (Hill, White House and FCC) that we have been working on for this administrative action, given that the Bill has not passed and will not pass in this Congress. The sources of committed Hill support are Representatives Walden, Kinzinger and Courtney; and Senators Wicker, Blumenthal and Thune. We also have committed support (unprecedented in ARRL rulemaking proceedings) from David Redl, our advocate throughout the legislative process who is now the Administrator of NTIA. David understands that the White House Telecommunications staff supports this Petition and David advocates on telecom for the Administration. It doesn't get much better than that. Our prime Hill supporter, Rep. Kinzinger, has already contacted Ajit Pai and obtained Pai's favorable view of our plan. Finally, Barry Shelley and I have met with the Wireless Bureau Chief and pre-sold the petition. We have to make the rounds at FCC as soon as possible in order to leverage that support, which does not carry over all that well to the next Congress, when we in all likelihood will not have another Parity Act Bill. All of that support is the culmination of five years of work on this and it hinges on filing this before the end of this year. I will not further rehash this now, but I would like to have a dialog with any non-EC member that has residual concerns about the timing of this filing. In my view it would not be good strategy to either squander the equity that Mike Lisenco, Frank McCarthy and I have built up over five years. I specifically asked the EC back in September if we could make the commitments that we did and they approved the plan. Finally, there is a very, very strong level of support in the field for the Parity Act provisions, and the relief that it offers to tens of thousands of hams who live in deed restricted communities and who are profoundly hampered by that fact. ARRL has, since PRB-1 was first issued in 1985, repeatedly and relentlessly attempted to fix the other half of the problem. I believe that we have the single chance now, with this Petition and with the level of support that Frank McCarthy has helped us achieve, and with a lot of shoe leather burned, to accomplish this in a way that will help thousands of hams, both members and prospective members alike. The Petition as initially drafted was flawed in some respects, despite my best efforts and a few false starts in initially drafting and editing it. Thanks to important edits (some of which were provided just yesterday and today) from a few members of the Board family, most especially Greg Widin, Tom Frenaye, Jim Boehner, Bob Vallio, Jim Tiemstra and Dick Norton, it is a considerably better document now. I know that Jim Tiemstra and Dick Norton were not and are not supportive of the filing but I am very grateful to them for their helpful and good edits nevertheless. I am also especially grateful, as I mentioned to the Board last July, for the relentless and very professional work of Mike Raisbeck and Fred Hopengarten on the appendix part of the document. I will not hold either of them to supporting the final product attached, because neither of them had the opportunity (again despite my best efforts and intention to the contrary) to participate in the drafting of the Petition; but their help crafting the rule that we propose here is a good one thaniks to their efforts. That task was not a simple one. It was nuanced. On the one hand, we didn't want to propose language that was so far from the Bill language that CAI would come steaming in and oppose the Petition at FCC. But neither did we want to just transfer legislative language to FCC rulemaking. Those are two different things, and we tried to accommodate Fred's concerns about the Bill language in order to propose an FCC rule that clarified and better protected hams than does the skeletonal framework of the legislative language. Whether we accomplished that remains to be seen, but that was the intention anyway. Thanks to Fred and Mike for their help. It was appreciated. 73, Chris W3KD P.S. Howard, if you would be kind enough to forward this with the attachments to our newcomers I would be grateful. We should be as open and transparent with colleagues as possible, and perhaps find once again the level of collegiality and teamwork that ARRL's Board used to use as SOP. -- Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG