Alun L. Palmer wrote:

I am a foreign citizen myself. However, I am a US
permenent resident and have a US ham licence
(not only a US licence, mind
you). My comments say nothing about my citizenship.
I suggest that it isn't
relevant, and it's the country of residence that is important.

I disagree!

Citizenship and residence *are* relevant/important, Alun. Neither
is a prerequisite for commenting, of course, but they *are*
relevant facts.

Of course, I can't vote in elections, but the FCC comment
process is specifically open
to anyone who cares to comment, even non-hams like you, LOL!

It's interesting to note that nowhere in Len's comments does he mention
that he is not a licensed radio amateur, never has been, nor does he
intend to become one if the rules change. Yet he seeks to have FCC
disregard the comments of those already licensed, as if rules changes
will not affect them.

Most US elections are decided by who gets the most votes. The
comment process isn't like that at all. There's no requirement
that the majority of comments, or commenters, get what they
want. That was clearly demonstrated with 98-143 and again with
BPL.

Anyone with interest is welcome to comment. There's no requirement
of licensure, residency, citizenship, age, etc. In fact a comment
doesn't have to be from an individual - organizations like clubs,
manufacturers, etc., can comment as well.

There's also no universal FCC validation that a comment is actually
from the person who claims to have sent it in.

Voiding one comment because the person specifically
said they were a
foreign citizen doesn't make much sense, as there
are in fact others from
foreign citizens that simply don't say (at least one,
i.e. me, but
statistically there must be others).

There are quite a few FCC licenses issued to noncitizens who are also
nonresidents.

I see no reason to invalidate someone's comments because they are
not a citizen, or not a licensed amateur.

In fact I suspect that out of 1414 comments it's statistically likely that
there are some signed with bona fide US calls that are from
foreign
citizens who have never lived in the US. You know there is US
VE testing in
all the countries that have US bases, and it isn't just the
military who
take the tests, but plenty of locals too. You would have to
look up
everybody's address to find out who lives outside the US, and
information
on citizenship of hams simply doesn't exist, so there is no way to verify it.

Not only that, but some nonresident noncitizen FCC-licensed amateurs
use a US mailing address, so even if you did all the checking, a
nonresident noncitizen could be missed.

73 de Jim, N2EY