In this case, their time may be better spent finding allies with interests in stopping yet another ratcheting up of high-frequency trading, and the market volatility and unfairness that it creates. There are some deep-pocketed investors (pension funds?) and well respected economists that will be able to tug on the FCC’s ears better than the ARRL ever could, provided the ARRL can encourage them to do so.
Those types would normally be only concerned with the FTC, but in this case, they can make good cases to the FCC that this particular use of the spectrum has no public benefit.