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aTOa <br />anew rule not just an interpretation of an existing one.' We also asserted that the 30 day <br />deadline will result in many practical problems that the FCC did not fully consider. <br />On December 22, 2009, the FCC released a public notice requesting comments on <br />NATOA's Petition. Although the notice specifically requests "opposition" to NATOA's <br />Petition, this is also the appropriate time to express your support of our Petition to the FCC. <br />Attached with this memorandum is a template that you can use to show your support. <br />What will be most helpful to local government's cause is if you can share some examples with <br />the FCC of instances where the 30 day deadline would be problematic. The more examples we <br />can provide, the stronger our case becomes. <br />These comments are due to the FCC no later than 5:00 pm on Friday, January 22, <br />2010. The comments maybe filed electronically or you may send paper copies. <br />Make sure the filing references the Docket Number: WT Docket No. 08 -165. Please <br />note that the recommended template does reference this Docket number already. <br />If you want to file an electronic copy (recommended) you may do so at <br />htto: / /www.fcc.aov /ceb /ecfs /. At this webpage, follow these directions: <br />1. Click on "Submit a Filing." <br />2. Fill out all relevant information. Do not forget the docket number (08 -165). <br />3. Upload your filing. Please note that you should convert the document to a PDF format <br />before uploading. <br />4. Click on "Continue" <br />5. Verify all information and that document uploaded properly. <br />6. Click on "Confirm" <br />Please note that at this point you may be brought back to the document upload screen. If <br />you are, please click "Continue" again and on the next screen click on "Confirm" again. At this <br />point, you should receive a Confirmation Number. Print this for your records. <br />If you file paper copies, you must file a total of five copies (one original and four copies). <br />Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first <br />class or overnight U.S. Postal Service mail. All filings must be addressed as follows: <br />Ms. Marlene H. Dortch <br />Office of the Secretary <br />Federal Communications Commission <br />445 12th Street SW <br />Washington, D.C. 20554 <br />' Note that the Petition made clear that NATOA rejects the FCC's interpretation. Nonetheless, we believe that <br />argument is best suited for parties filing in Federal Court. In this Petition, we argue that even if we accept their <br />interpretation for the sake of argument, they were still wrong in establishing the 30 day deadline. <br />National Association of TelecommunusGons Officers and Advisors <br />1800 Dugonal Road. Suite 495, Alexandria, VA Mid, (703) 519-8035, (703) 519-8036— Fax, w .natoa.org <br />up <br />