I wouldn't discount the power of a well-written comment by a lone amateur. In my opinion it can have, at least, the weight of a petition from the ARRL.
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For an insight of ARRL stunts and the nitty-gritty on the ad hoc ARRL committee that "authored" RM-11306 see this QRZ.com posting by Skip KH6TY, a member of that ARRL HF Digital ad hoc committee.
In my opinion, this is a MUST READ for doing your homework on RM-11305 and RM-11306.
His posting is halfway down the page:
http://www.qrz.com/ib-bin/ikonboard.cgi?s=d025dfe734da9b72211e141821081302;act=ST;f=3;t=111259;st=180(you may need to reformat this long link above or copy and paste it into your browser URL address line.)
Within the QRZ posting is a link to a report he alone wrote on this ad hoc committee:
http://www.zerobeat.net/bandplan-dissent.htmlVery enlightening, grasshopper.