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Old May 9th 04, 02:03 PM
Alun
 
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(N2EY) wrote in
om:

"Phil Kane" wrote in message
. net...
On 7 May 2004 10:23:31 -0700, N2EY wrote:

It's been ten months and two days since WRC-2003 ended, and given
FCC's method of handling the issue it may well be another ten months
before we even get to the NPRM stage.


The NCI Petition for Rulemaking gave the FCC a quick out to drop
Element 1 immediately, with sufficient legal foundation to do so
without an NPRM (I read that part thoroughly, and it's right on the
mark).


I recall that even before any petitions were filed, both of us agreed
that if FCC "wanted to", Element 1 could be simply dropped once the
treaty changed. I believe the procedure is called "Memorandum Report
and Order" (could be some other name) but in any event a lot quicker
and simpler than a complete NPRM cycle.

The fact that it hasn't been done means that "someone's" fire hasn't
been lighted.


Right. Could also be that "someone" doesn't want to get in the middle
of the catfight and get scratched by both sides. In which case the
thing to do is to entertain all sorts of petitions, (we're up to what
- 17-18 of them so far?!) collect comments and reply comments and even
ex partes on each of them, and allow the whole thing to percolate
through the great bureaucratic machine. Then, when the flood of
petitions has been reduced to a trickle, issue an NPRM with long
comment time (like 98-143). Resolution of the issue could take years -
and every new petition just resets the clock.

IOW, don't hold yer breath. Lookit how long it took for the "incentive
licensing" proposals of the '60s to take place. First proposals in
1963, final plan in 1966, major changes in 1968 and 1969. And they had
far fewer proposals back then.

This is a phenominon that I am all too familiar with
when dealing with The Monkey House whether from within or from
without.


"Welcome To The Monkey House" ...

73 de Jim, N2EY


If you are right, then the US will be the last country with a code test,
decades after it no longer exists anywhere else. I don't think it will take
that long, though.

Firstly, I think the reason they didn't go for a memorandum report and
order is more mundane. They don't care about any catfight because they
don't care about amateur radio, period.

Secondly, I don't think they will wait for any more petitions.

Thirdly, I think that when the dust settles they will just do what they
were going to do anyway. Eliminate Element 1.

In the recent NPRM I submitted comments that many of the proposed changes,
although good, were mooted by the fact they referred to the former ITU code
test requirement as if it still existed. If they don't issue an NPRM on
this matter they will get comments on it submitted in every other one. I
know this because I will personally see to it.

As for any further restructuring, there are two separate issues:-

1) Re-farming the Novice frequencies an increasing the phone allocations.
Here there is already an NPRM, and I think they will carry it out. It just
gives the same amount of additional spectrum to phone as is now Novice CW.
This is what they are going to do. It's less than I wanted, and even less
than the ARRL or the NCVEC asked for, but I'm betting it's all done;

2) Eliminating supefluous licence classes. They will ultimately just do the
obvious, i.e. give Novices and Advanceds a free upgrade. They won't revive
the Novice and kill off the Tech. They will view that as a waste of time.
The FCC is all for simplification, and they will point to the petitions as
providing the consensus they were looking for, even thought they are
slightly different.

73 de Alun, N3KIP