Ground Penetrating Radar Coalition for Action Against the New FCC Rule
Dear Colleagues
We are soliciting your support to develop a coordinated response to the new FCC rules. These rules, to be published in the next 1-2 weeks, would severely limit and in many cases eliminate the use of Ground Penetrating Radar. We as GPR service providers need to coordinate a response to protect the future of our work. After the new rules are published, those who wish to object can "petition for reconsideration". However, the new rules are in effect during the petitioning period, which could go on for several months. In order for us to continue to operate, we also need to seek a "stay", which will enable us to operate as we have until the petitioning process is complete. If our petition is successful, then we are done. If not, we can file for a "waiver" which would exempt us from the new rules (for some justifiable reason).
Milestones are as follows (dates are estimates):
April 1 - new rules are published
April 15 - announcement of new rules appears in the Federal Register; motion for a stay to
be filed as soon as possible
May 15 - petitions for reconsideration must be submitted
June 1 - petitions are published in the Federal Register
June 15 - opposing comments to the petitions must be filed
June 25 - petitioners submit reply to opposing comments
The motion for stay and the petition for reconsideration are legal processes, and we need to engage the services of an FCC attorney to make the submissions and pursue the follow-up. I have been referred to the law firm of Miller & Van Eaton. They are based in DC, deal regularly with FCC regulatory issues, and seem very knowledgeable. The estimated cost for the petitioning and the stay motion is $25,000. This estimate is in line with other estimates that I have received. You can find out more about Miller & Van Eaton at www.millervaneaton.com. We would like to form a consortium of companies who will share this cost and be named in the petition. If we have 25 companies then the cost will be $1000 each. The money will be put into a separate account and used only for paying these legal expenses. For our part, we think this is a small investment compared to the potential cost of losing our businesses.
The equipment manufacturers GSSI, Mala, and Sensors and Software have joined together and engaged an attorney to file a similar action from the manufacturer's perspective. They have encouraged us, the users and service providers, to present our position independently, so that the effort has a broader constituency.
If you are concerned and willing to participate, please contact us at by replying to this email at info@infrasense.com At a minimum, you can sign up for no cost with our save GPR discussion list at: save-gpr@world.std.com. (visit
http://www.radar-solutions.com/Stop_FCC.html to do this) Thank you for your interest, and we look forward to your participation.As of 4 April, 15 service provider companies have
joined, each of whom has agreed to contribute $1000 to the support the legal steps that
need to be taken. We anticipate support from other companies. Contact Ken Maser for a
current list of companies.
Ken Maser and Doria Kutrubes
GPR Coalition for Action Against the new FCC Rule
please reply to: info@infrasense Elaine Gampp 781-648-0440
Kenneth R. Maser, Ph.D, P.E
President
INFRASENSE, Inc.
14 Kensington Road
Arlington, MA 02476
ph.781-648-0440; fax 781-648-1778
www.infrasense.com
Doria Kutrubes, President
RADAR SOLUTIONS INTERNATIONAL
Waltham, MA 02453-3819 USA
Toll Free: (877) 44-RADAR
or Tel./Fax (781) 891-4492
www.radar-solutions.com