[Lowfer] Comment repository link for Docket 15-99

[JD]

>>> It also seems best served that the ARRL be the one to point these issues 
>>> out, if at all.  It should be glaring to the FCC.

I very much hope ARRL does point out the weaknesses in UTC's arguments and 
the total lack of numbers to support them.

Even though most of the faults will surely be obvious to the FCC, it is 
sometimes very good strategy to let the other side in an adversarial 
proceeding (which this is in many ways, although more civilized than the 
typical courtoom drama) know that they're not pulling the wool over anyone's 
eyes.  If done with sufficent tact and aplomb, it reassures the regulators 
that you are cognizant of the issues and have some depth of understanding 
that the other side may lack.  This can get you a better deal than if you're 
too passive, especially in situations like this where the opposition is well 
funded and has dominated the discussion for so long.  I've seen it work 
before.  But it is a balancing act.

ARRL is in the best position to do this, it seems to me.  Their filing in 
this matter is comprehensive and well reasoned, and is a great boost for the 
cause!  For that reason, if I do reply to a few of UTC's points, I intend to 
keep it simple and straightforward and try not to let any new issues be 
raised.  Staying on point is the big thing at this stage, so I'm quite happy 
to save any more vigorous remarks for another time and let ARRL do the 
"heavy lifting" in connection with UTC.

>>> If you have another idea about something contained within someone else's 
>>> initial comment, it seems best to present the idea as an alternative 
>>> approach with a similar  outcome - keep it positive - because the enemy 
>>> will use that division against us, particularly if submitted before the 
>>> deadline where they can see them before the filing deadline.

I'm in total agreement with John.  Various folks who filed may have views 
that differ on some of the particulars, but our goals are fundamentally the 
same.  Keeping a positive tone in replying to someone else who supports the 
cause not only prevents the opposition from magnifying any perceived 
divisions, but it also demonstrates to the Commission that we know how to 
work together, which will go a long way toward convincing them we can also 
make spectrum sharing work.

John D