Forget all the "my survey of comments analysis"
is more accurate than yours... Consider the following
question/challenge:

In all of the procode test arguments and comments has
even one NEW reason to retain code testiing been
offered?

Forget even if such an argument is valid or
compelling in any way...I'm looking for any argument
not previously raised and dismissed by or in past
FCC commentary (NPRMs, R&Os, etc.)

My short answer (and I'll be the first to say I
haven't read all comments) is that there are no
new arguments raised... because if there had been
we'd have seen it or them by now.

Cheers,
Bill K2UNK