[arrl-odv:19570] Vanity Call Sign Docket (09-209) Petition for Partial Reconsideration, as-filed at FCC today

Greetings. Today, following quick review and approval by the Executive Committee, I filed the attached Petition for Partial Reconsideration in the FCC's Vanity Call Sign docket. The Petition asks for very little relief, really: only the editing of two rules pertaining to club licensing and the FCC's effort to prevent hoarding of vanity call signs by some club trustees. The FCC came out basically OK on the philosophy of this, but not the rule text. We do, however, rather stridently chastise the Commission for inviting other proposals to facilitate fair and efficient call sign administration, and then tersely dismissing without serious consideration ARRL's extensive proposals to increase the number of available Group A call signs, the pools of which are now largely exhausted. Indeed, that was the entire point of the FCC's docket proceeding in the first place: to preclude hoarding or warehousing of preferred call sign permutations. We hope to be able to revisit this without prejudice in the near term. Fair warning of this is being given to FCC now, hopefully to avoid an "asked and answered" response the next time. I want to thank in particular Dave Sumner and Kay Craigie for their extensive help and corrections on repeated drafts of this; their help was critical to get this filing on track. 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
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Chris Imlay