Options
Roosie collectors...what do you think?
homerunhall
Posts: 2,496 ✭✭✭
We are in the process of writing the standards for the new "Full Torch" designation. While it would be more descriptive to call it "full bands" because the issue is the bands, we are using Full Torch because it separates Roosies from Mercs and give this underrated series an exciting identity (in my opinion.)
As to the bands, here's the question...
Option 1 - top and bottom horizontal bands must be fully separated.
Option 2 - top and bottom horizontal bands and all vertical bands must be fully separated.
We feel the best about option1, but we would like to hear what serious collectors of this series think before we pull the final trigger. Please give us your input here or thru emails to BJ. All comments and explanations of your thinking will be read and appreciated. Thanks for your help.
David Hall
As to the bands, here's the question...
Option 1 - top and bottom horizontal bands must be fully separated.
Option 2 - top and bottom horizontal bands and all vertical bands must be fully separated.
We feel the best about option1, but we would like to hear what serious collectors of this series think before we pull the final trigger. Please give us your input here or thru emails to BJ. All comments and explanations of your thinking will be read and appreciated. Thanks for your help.
David Hall
0
Comments
FS(full strike) would be better!
Don
Full Bands and
<< <i>Roosie collectors...what do you think? >>
I think that a roosevelt (in Full Torch) along with two MS69 State Quarters will buy me a can of Diet Coke.
Other than that, I think I am glad I don't collect dimes.
If I had it my way, stupidity would be painful!
If you are serious about hearing what we have to say, (Serious Roosevelt colectors) you would read all of these posts and take in consideration that we love to collect coins and we have alot of pride and money involved in collecting these wonderful coins.
Roosevelts are not widely collected as MERCURY or BARBER dimes, BUT we collect them. We deserve to be heard just like any other coin collector. If you choose to change the designation of these coins, regardless of money or any thing else you DO need to hear what we have to say.
Several of us, on or off the registry, have several dimes that need to be re-graded as full torch and/or full bands. It doesn't matter what you what to call them. Every one on this message board sees that PCGS needs to give registry collectors at least 90 days to adjust our sets and/or add a set. Not to mention, NON-REGISTRY collectors have the opportunity to send in their coins to get re-graded, along with US that have been given the chance to get our sets re-graded.
I personally have NO ADDITIONAL ROOSEVELT DIMES to send in to have re-graded for FULL TORCH or FULL SPLIT BANDS other then my registry sets. I will send only my 2 sets to have re-graded. I am a collector and would like to see EVERY ONE ELSE have the chance to have their coins re-graded. Its only fair. Take one of your round table meetings and figure it out. You have the most knowledge of any of us regarding coin collecting and you make the rules!
Roosevelt collectors want to be heard!!!
PLEASE MR. HALL, listen to US! YOU can do right!
Please feel free to e-mail me to discuss this issue at stooge2106@aol.com.
Enthusiasically yours,
Paul B. Gunsallus
Later, Paul.
ps. I think FB (full bands) is FA (fully appropriate).
sensibly, since the horizontal bands are deeper in the die it should require more flow to fill that detail, although the vertical lines may be robbed of metal going to the leaves and lettering. option #1 would probably be best.
whatever decision is made, there really shouldn't be any kind of time constraint placed on the designation addition on coins. it's not as though there will be a mass submission, and even if there is it just isn't realistic to place a cost on the coin owners for a change in policy, whether that's in money or in time.
al h.
For me option two.
If you are going to designat a full strike, you should use all the factors to make sure the coin really is full strike.
President, Racine Numismatic Society 2013-2014; Variety Resource Dimes; See 6/8/12 CDN for my article on Winged Liberty Dimes; Ebay
<< <i>
<< <i>Roosie collectors...what do you think? >>
I think that a roosevelt (in Full Torch) along with two MS69 State Quarters will buy me a can of Diet Coke.
Other than that, I think I am glad I don't collect dimes. >>
Very insightful and valuable input. This is up to par for about 99.94% of your posts.
Option 1 - top and bottom horizontal bands must be fully separated.
David: Thank you for opening this up for discussion before finalizing the standard. I see that Registrycoin (Steve) (the ALL-TIME #1 PCGS Roosie collector) has weighed in already for option #1 and I totally agree that should be the standard, if having to chose between the two options (but, please consider my comment below).
I may comment further upon return from the show, but, let me mention this information for the moment-
A third option would simply be the bottom horizontal bands must be fully separated. Understand that even with this standard, IMHO, for many dates locating an MS67FT will be very difficult and MS68FT virtually "impossible". Why do I suggest keeping it to the bottom bands only -
1. The standard will be tough enough for even the most seasoned Roosie collectors. I know of several collectors that have tried to complete a set of MS67 Roosies using this standard and are 1/2 -2/3 there after the greater part of a DECADE!!
2. Keeping it to the bottom bands only is ENTIRELY CONSISTENT with PCGS' present policy and definition of FULL BELL LINES, namely defining FBL to include only the BOTTOM set of bell lines and not both sets.
3. I believe PCGS only require the CENTER bands on a Mercury to be "FULL" to define that standard as well.
4. PCGS' definition of "FULL STEP" on nickels is not the overwhelming "6" step standard, but, a more relaxed "5 step" standard. Yet, even with the "relaxed" standard, only 1 or 2 people in the country have ANY hope of completing that set in ANY GRADE of FS!!
5. While the upper bands alone do not often knock a Roosie out of "FT" designation, it does happen and I have seen it happen on the otherwise difficult dates such as the "s" mints from the mid-1950's. Again, since the upper BELL LINES do not matter on Franklins for the definition, I see no reason the upper bands on a Roosie should matter either.
6. Finally, PCGS needs to consider that most clad Roosies do not look like silver Roosies. On many clad Roosies, the separation of the bottom bands is not "FULLY" separated as they are on silver dimes but are FT as struck. I would think PCGS would want to consider the differences between as struck FT silver Roosies vs. as struck FT clad Roosies up front, to avoid problems later when collectors point to a clad Roosie getting the designation but having the same "look" as a silver Roosie that did not get the designation.
That's it for now- but, I also look forward to hearing from other collectors on my suggestion of limiting it only to a lower full band requirement.
If you choose option #1 it will be objective. It is clear if the bands are touching or fully split. But you would run into the same issues we have with other series. For example you can have a full head SLQ that has a poorly struck shield.
I don't know how hard it is to find fully struck Rooseys. I would listen to RegistryCoin who says the lettering should be full as well as the bands.
I feel option # 1 is best suited for FT.
Ray
If you are going to designate a full strike, you should use all the factors to make sure the coin really is full strike.
This make the most sense of any comment made yet... IMO.
If you're adding a designation, FT or FB, (personally I would use Full Torch because that seems to be where the focus is) to distinguish one coin from another because of strike, why not make the comparison relative to the entire coin, not just a part of it? Why should the coin carry a premium just because the bands on the Torch of a MS63, with a weak obverse strike, are better than those of a MS65 with a strong obverse strike? Flame me, I can take the heat.
It's a short term money grab for those who already own these coins and for PCGS who wants to add the designation, IMO.
How about FV (Full Veins) for Two Cent pieces?
Carl: I believe RC supports a bottom band requirement for a FT designation (he can comment himself later). RC's comment on lettering (referring to my previous comment) is moot now that we are on board with PCGS' "full band" designation (even if it is called something different).
Wondercoin
Fully struck lettering, or lack thereof, was pointed out by Rick M. in an effort to explain why some coins were not fully struck (ie., 8 candidates). Personally, I think, this was overly discriminating. I think full horizontal bands, and full vertical bands, and strong lettering is asking too much.
For other series, the "full" designation does not necessarily cover all aspects of a fully struck coin. There is usually more than one detail that could, or should be used to determine a "fully struck coin". With that said, I think that for the purposes of creating a new designation, consistancy as compared to other coins' designation is important. I think for consistancy with other series' designations,
Mitch's option #3 (check the lower horiz. bands) is best.
FT would be appropriate only if distinction from FB is desired. Personally, I think it is not desirable and Full Bands (FB) is best.
ps. separate standards for clad and silver are appropriate.
primarily to learn. At the risk of pointing out the obvious the standard should
be such that at least a few coins achieve it for most every date and it is not
extremely common for more than a few dates. Likely we're talking option
2 (with some leeway) on clads and option 1 (or lower bands only) for at
least most of the silvers.
However, it may afford NGC the opportunity to "one-up" PCGS by adding the second set of bands, and David may have already considered this.
At any rate, I strongly agree with RC that FB should be the designation. It just seems common sense. Why call it "full torch" if only the bands are considered?!?
Don
Full Band Mercs & Roosies and
I heard the news last week I rushed home and pulled out every Roosie I had including several roles and looked and
looked and looked some more. After about an hour I found myself only focusing on the lower bands being fully separated.
This seems to be the main focal point on the torch. I also agree with just designating full bands as the lower band
being fully separated. If its just a matter of voting for #1 or #2 above then put me down for #1.
In honor of the memory of Cpl. Michael E. Thompson
_____________________
My Other Hobby
The decision could come down to: an acceptable definition of detail(s) needed to distinguish a new designation, ie the lower bands,
or, a "whole" full strike-type concept, including lettering, etc. (The latter is harder to distinguish.)
But it sounds like the former has acheived "given" status" and the only decision comes down to what detail(s) will be used to determine the new designation, and what that designation will be called. It's probably not really a worthy way to define "full strike", but, as has happened in other series, it does, fairly or unfairly, distinguish certain coins from the pack. Good or bad, it does seem consistant.
I think that in most cases alot of the lower bands are not fully struck. Even on a nice 7 or 8. I would rather PCGS call them full strike or fully split bands just like the Mercury dimes.
So I guess you can put me down for a #1.
Paul B. Gunsallus.
Later, Paul.
Option 2 gets into more subjectivity, and should not be considered for this purpose.
I really think you need to continue the use of "Full Bands" from the Mercury Series. If it was a different denomination, I would think differently, but Full Bands means "DIMES" and it also lends more credibility to what you are trying to accomplish.
My .10.
Thanks for letting me have some input.
Amen!
Don
Full Band Mercs & Roosies and
Looking for PCGS AU58 Washington's, 32-63.
The designation "Full Torch" would be proper if you were going to go with option 2, but wouldn't that be like calling merc's "Full Bundle"?
Just an extra .02 chipped in for the heck of it.
First, I thank you for asking for our input
It would appear to me that PCGS already grades these roosies in a manner you suggest that now is only lacking the "FB" (full band, which I prefer over any other and is consistent) attribute on your holder. I disagree with the use of "FULL TOURCH" because is would include option #2 and might as well be called "FULL STRIKE" "FS", which could be confused with full steps. IMHO.
Also, you have done some homework as to looking up how many sets are listed and I quote
<< <i>There are 46 1946-1964 Roosevelt sets and 27 1965 to date Roosevelt sets in the PCGS Set Registry. >>
My question: have you checked the type sets and will I also be able to get my two coins this attribute added for free?
Ken
My Washington Type B/C Set
Also, I agree that using FSB or FB on the dime is also proper. Who cares if the term is used for Mercury dimes, AU, MS and PR are used and not changed for different series, and I see that as just the same here. If you use Full Torch you may confuse people into thinking and focusing on an area that is not proper. Your looking at the bands for the designation, so you should call a spade a spade, and name the designation apply so.
morris <><
** I would take a shack on the Rock over a castle in the sand !! **
Don't take life so seriously...nobody gets out alive.
ALL VALLEY COIN AND JEWELRY
28480 B OLD TOWN FRONT ST
TEMECULA, CA 92590
(951) 757-0334
www.allvalleycoinandjewelry.com
We have several very high grade sets in house, thanks to a few dealer friends. We also have examples from the DHRC inventory. And we have some nice original rolls, both silver and clad, from another dealer friend. Miles, Mike Sherman, and I have been looking thru dimes and FYI...
It is possible to have fully seperated horizontal bands, but not fully separated vertical bands. It doesn't happen often, but we have seen examples where a few of the verticals mush together.
It appears everyone likes the idea of using "Full bands" for the description of the designation...DMWJR had some great points re the comparision with Mercs and I think that conection to Mercs will be very positive for the Roosie market.
...and most like option #1, i.e. horizontal bands only. I haven't seen any coins where the bottom bands were full but the top weren't, though I can image that these could exist. I believe both top and bottom should be full.
Any other comments before we set the standards will be greatly appreciated.
Thanks for all the help.
David Hall
keep it full bands, option one is the best choice
jmho
Tim Poston
Now, we can talk about what attributes should be considered to determine a designation.
The vertical bands. It's better to just not go there.
The lower bands make things simple for graders and collectors alike. It isn't necessarily a determination of a true full strike, but it does distinguish most nicer coins. I think, so to not separate the roosies from other series, as a matter of consistancy as compared to other "full" designations, full bands, specifically the bottom bands, is sufficient.
al h.
I think your collectors will be much happier if you go the "Full Bands" route, and option 1. I get your point, but I think people are going to find that just finding fully split horizontal bands is going to be difficult enough. I would say only about 30% of my MS67's have "completely" split bands. Again early 70's are going to be extremely challenging, just like they are in high grade anyway. Collectors who don't focus on dimes in the early 70's probably don't realize that there are only 9 coins for 1970p graded higher than 65, and that is NOT for a lack of people trying to find them.
Thanks,
Doug
Ken
My Washington Type B/C Set
<< <i>I agree totaly with what Doug said, Lets carryover the FB designation to the Roosevelts. >>
Add my vote!
"Finally, PCGS needs to consider that most clad Roosies do not look like silver Roosies. On many clad Roosies, the separation of the bottom bands is not "FULLY" separated as they are on silver dimes but are FT as struck. I would think PCGS would want to consider the differences between as struck FT silver Roosies vs. as struck FT clad Roosies up front, to avoid problems later when collectors point to a clad Roosie getting the designation but having the same "look" as a silver Roosie that did not get the designation."
I too have a large stock of Clad Roosie's and I find that the entire coin is "as struck" with full details except for the bottom bands on some issues. Please consider this while you are in the design phase of this project.
Thanks for the opportunity to voice out opinions on this matter.
Mark Di Lauro
I agree with the majority that this maintains consistency for the dimes and will help elevate the Roosevelt by the association with the Mercury dime. I believe the "Full Torch" FT designation does not offer these same benifits but rather would be confusing and problematic.
Calling the coin "Full Torch" but then only looking at the bands simply does not make sense.
Also, the FULL BAND designation should refer to lower bands ONLY. There are myriad Roosies out there displaying FULL bottom bands but weakness up top. WHY IGNORE THE TOP BELL LINES OF A FRANKLIN HALF (WHICH PCGS DOES), BUT REQUIRE THE TOP BANDS ON A ROOSIE? WHY? HONESTLY, IT MAKES NO SENSE AT ALL.
I can also assure you that PCGS has NOT yet had the opportunity to look at but a tiny weenie fraction (if any) of the roughly 2-3 dozen PCGS-MS68 dimes out there and any statement regarding nearly every dime having BOTH bottom and top FB is ENTIRELY ERRONEOUS.
It makes no sense to set up a standard that will not be followed. For example, clad dimes do not come fully split like silver dimes. I see maybe a half dozen clad coins available on DHRC right now - I currently have upwards of 500-1000 PCGS clad and silver dimes on hand and have handled the majority of every MS69 clad dime sold to date and the vast majority of the clad and silver MS68's (not bragging - just setting out some qualifications). Datentype also knows what I am talking about because he produces these clad dimes.
As for the silver dimes, I have spent the past 12+ years studying Roosies in detail - every date and mintmark in a quest to locate a FB set in MS67 or better. Not done yet AND I CAN ASSURE YOU THAT THERE WERE MANY FB LOWER BAND DIMES THAT DID NOT HAVE TOTAL SEPARATION ON UPPER BANDS.
Why create a standard PCGS will not be able to honor later unless PCGS desires very, very few collectors from ever achieving a complete set of FB dimes in the top ultimate grade. We already have that exact situation with Jefferson nickels, EVEN WITH PCGS' RELAXED 5 STEP STANDARD.
AND, FINALLY, I HAVE A SINCERE QUESTION - I TOOK THE TIME TO WRITE A DETAILED AND WELL THOUGHT OUT REPLY ON THIS THREAD. WHY NO COMMENT BACK FROM PCGS ON MY THREAD? WHAT EXACTLY DO YOU DISAGREE WITH PCGS? IS IT BECAUSE I "DEAL" IN ROOSIES AND DON'T HAVE A REGISTRY SET UP THAT MY COMMENTS HAVE BEEN IGNORED? WOULD I GET MORE RESPONSES IF I HAD UP THERE THE #1 SET AGAIN? I WOULD LIKE MY COMMENTS ADDRESSED PLEASE HEAD ON.
WHICH COMMENTS DO YOU DISAGREE WITH PCGS? DO YOU BELIEVE SILVER ROOSIES LOOK THE SAME AS CLAD ROOSIES? LET'S DISCUSS THAT. DO YOU BELIEVE THAT PCGS DOES LOOK AT THE TOP FRANKLIN BELL LINES AND I HAVE MISINTERPRETED THE STANDARD? WHY SHOULD FRANKLINS BE TREATED DIFFERENTLY THAN ROOSIES? DID I MISSTATE THE JEFF NICKEL STANDARD? DID I NOT POINT OUT THAT ONLY THE CENTER BANDS ON MERCURIES ARE CONSIDERED FOR THE FB DESIGNATION - AM I WRONG HERE? ANYONE OUT THERE THAT WOULD LIKE TO ENGAGE IN A SINCERE AND SERIOUS DISCUSSION ABOUT THIS SERIES - WANT TO DO IT DATE BY DATE, MINTMARK BY MINTMARK?
WHY HAVE I TAKEN THE TIME TO WRITE THESE THREADS AND NOT RECEIVED A SINGLE COMMENT BACK, WHILE OTHER COLLECTORS ARE GETTING MENTIONED FOR BRINGING UP BASICALLY THE SAME POINTS? WHAT ABOUT THE "TWO WAY STREET" HERE? Are only comments from collectors relevant here, like you thread title states? Even though I had the #1 set in your 1999 Registry, am I no longer a "collector"and therefore irrelevant to the discussion? Just say so then please - make it clear that Roosie dealers opinions are not relevant and I won't waste the time. I can certainly understand how a collector with a handful of dimes he bought mainly from myself and Datentype gets "clout" here to give suggestions on what an important standard should be. After all, I sell them now - what do I know about "collecting" them. All right, just call me Mr. Know-it - all" and I guess I'll have nothing more to say on this subject.
I sure hope this thread isn't viewed as anti-PCGS. I just feel it's a "two-way street" out there and if you don't want "non-collectors" out there voicing an opinion that WILL BE COMMENTED ON just say so and I certainly won't waste my time anymore. If you are interested, however, and you disagree with a comment of mine, please COMMENT BACK. I know PCGS MS Roosies as well as ANYONE in the country. I am still waiting for an answer from PCGS to my sincere question why it is OK to have a Franklin FBL standard (which PCGS does have) requiring only the BOTTOM SET OF BELL LINES to be full (whereas NGC I understand requires both sets of lines to be full) but with Roosies you are pushing for having both upper and lower bands? Why must this be, especially where the ALL TIME #1 ROOSIE COLLECTOR (REGISTRYCOIN) and the #1 PRESENT ALL TIME NGC ROOSIE COLLECTOR (ONLY ROOSIES) have both also written in on this thread that the bottom bands are just fine for the standard?
Wondercoin
You can add me to the bottom of your post as the #2 "all time" sets in both silver and clad MS (and both proof sets 1950 to present for that matter) as agreeing with the lower bands only position.
For the record, nobody consulted any of the top registry set owners before making the big announcement, and certainly not me. PCGS did apparently consult "some" dealers first. I was as surprised as you were (pleasantly!) that PCGS was considering an adjustment to fit the collectors' desires. I'm sure dealers will follow their customer's desires. Since you have been amassing Roosevelts for 12 years, you should be well ahead of the curve. Be glad PCGS at least wants to take an informed leap into a new designation. Since they have replied, I feel a lot less like it was crammed down my throat AFTER my sets were built.
As for your statements about the dimes themselves, I agree 100%. I have a couple of MS68 clads that do not have split lower bands, and the majority of my 46-present sets, even nearly all are MS67, do not have fully split lower bands. I do have a couple of MS66's that do have split lower bands, but surface marks prevent a higher grade.
If you have any with fully split lower bands, I will surely be interested in hearing the dates to see if I have them or not.
So far, we have the following collectors/dealers/enthusiasts ALL agreeing the standard should be the BOTTOM BANDS ONLY:
1. THE #1 ALL-TIME PCGS SILVER ROOSIE COLLECTOR
2. THE #2 ALL-TIME PCGS SILVER AND CLAD ROOSIE COLLECTOR
3. THE #1 1999 REGISTRY SET OWNER OF ROOSIES (who PCGS also asked to write the preamble for Roosies and Jefferson Nickels in the 2000 Registry Book)
4. THE #1 ALL-TIME AND CURRENT NGC SILVER ROOSIE COLLECTOR, WHO HAS QUIETLY CLIMBED UP THE PCGS CHARTS AS WELL AMASSING MORE PCGS-MS68 SILVER ROOSIES THAN ANY SET CURRENTLY LISTED IN THE REGISTRY.
Also, I have also alerted PCGS to the problem of using the same standard for silver and clad Roosies, for which it appears Datentype, Registrycoin and now DMWJR also agree.
Is there anyone else out there that is comfortable with the bottom band standard?
FWIW
Aye!
Don
Full Bands and
I'm glad Mitch wrote what he did. I'm just a small fish, not #1 or #2 sets, but only #7 and #8 and I'm sure that is why you did not have time to reply to my question about my 2 coins in my type sets
I do joke sometimes about PCGS but never try to cross the line of slander or liable. I'm 42 years old and as gentleman you must respect a man for giving you their honest opinion without fear of retaliation (for lack of a better term being booted from PCGS' board). I'm not sure what Greg said, but it must have been justified (i'm still reading the post).
If I may, I would make a suggestion for some of your replies. Most want to feel included in the conversation. After many replies to your question, then you only mention one members name. This appears (although I'm sure you do not mean it this way) you skipped everyone’s post and read only the ones you thought to contain information you are looking for. I have seen Typetone use this (I believe Latin phrase) for example
"DH, et al" (and others) to address a large post when it is mostly impossible to list everyone, yet not letting anyone feel left out. Just my 10 cents worth
Now I know it is not good to criticize and praise in the same sentence, but I am really happy with some of the attention you have put forth lately
Kenny
My Washington Type B/C Set
We'll use our hands and hearts and if we must we'll use our heads.
I currently have 3 of the top 5 current finest silver sets in the registry. I also have the #3 current modern(clad) set registered.
I have the following opinions on this "change":
1.Us Kentucky boys like to call a spade, a spade.
Do not label this change "full torch". The torch includes bands, vertical lines, and flame. Label it what it will be. Call it what it is!
If you decide to call it "full bands", this should include
"both" bands. If you are only going to use the lower band in your grading consideration, then call it that-"full lower band". CALL AND LABEL THE CHANGE WHAT IT IS. THEN THERE WILL BE NO CONFUSION WHAT TO LOOK FOR.
2.As for the re-grading requirements, please allow us "collectors" ample time to evaluate our coins for re-submission.(90 days is not enough time)
Regardless of what you decide to be the criteria for this change, you must know that less than 20% (maybe 10%) of Roosey dimes will fit the description.
You will not be bombarded with re-submissions. Just check the total # of Roosey dimes graded to date in MS67, then take 10% of that. You will then understand my point.
3. For clarification, do not limit my re-submission options to coins CURRENTLY in my Registry sets. For the record, I feel that my re-submissions should be available free of charge. Do not penalize me financially, because of a change that you are making.
Many of the coins in my current finest sets are there because of "eye appeal" (EXA.-toning). I would like to be able to replace these coins with ones that may fit the new criteria established, once I find out what this new criteria is.
4.I also believe that the criteria for silver and clad should be different. Maybe the clad coins should be required to have both bands fully split? Remember that we are dealing with a complete seperate series.
The criteria CAN be different.
I will make further comments on this thread shortly.
Thank you for letting my voice be heard.
Daniel D. Biddle
Paris, KY.
Danny: Nice to hear from you. To be clear:
DO YOU SUPPORT A DESIGNATION THAT REQUIRES ONLY THE LOWER BANDS TO BE LOOKED AT?
Also, assuming you do, I have to mildly disagree with you on one point. I do believe the designation can still be called "FULL BANDS" and does not need to be called "FULL LOWER BANDS". This would simply be in line with EVERY other PCGS designation. For example, are Franklins designated "FULL LOWER BELL LINES"? Are Mercuries designated "FULL CENTER BANDS"? Are Jeffersons designated "FULL 5/6 STEPS"? Do you see my point? As long as everyone understands that the determining area of the coin is the lower bands, the FULL BANDS designation is fine IMHO.
We all look foward to hearing from you on whether you are also fine with the LOWER BANDS being the determining focal area for the designation.