Getting down to the wire on WT Docket 05-235!

As of 5 PM EST on 10 November, there have been a total of
3,760 filings since 15 July 2005.

Of those, 3,703 were filed up to and including 31 August
2005, the official end of Comments. However, since the
Federal Register notice of NPRM 05-143 wasn't made until
31 August, the official Comment period is from 31 August
to 31 October. There were 1,721 filings made within the
official Comment period.

The official Replies to Comments period is from 31 August to
14 November. In the period 1 November to 10 November, there
have been 57 filings, only 9 of which are official (clearly
indicated as Replies to Comments). All 9 Replies are FOR the
NPRM. The official end of Replies to Comments is on Monday,
14 November 2005.

So far, there is no clear-cut consensus of any group for or
against code-testing, nor for the in-betweeners wanting code
testing for extras but allowing "lower" classes to be code
test free. The percentage of filings just "of the amateur
community" is only 0.82 to 0.29 percent of the total number
of licensees, depending on who sets the judging criteria.*

Before the official start of Comments (31 Aug 05), filings
FOR the NPRM were running about 2:1 in favor versus those
against dropping all code testing. At the end of the
official Comment period the ratio of dropping ALL code
testing versus keeping some code testing was about 1:1.
Of all 57 filings made after 31 August, all 9 official
Replies to Comments were FOR the NPRM and ending all code
testing; 4 were against the ARRL Comment of 31 Oct 05.

There are only four days left to make REPLIES to Comments
on WT Docket 05-235. Ordinary Comments will be unofficial
since the Comment period has expired.

* As of 10 Nov 05, www.handata.com shows 723,888 total
individual licensees in U.S. amateur radio (less 9,757 club
calls). Compared to about 3,471 total filings that are not
duplicates of the same individual saying the same thing, the
percentage of 3471 / 723888 = 0.82 percent. If only 5/6 of
all 723,888 licensees are "valid" (within their 10-year term
and not in the 2-year grace period), then total number of
"valid, operable" individual licensees would be 603,240.**
Given that there were only 1,730 filings made WITHIN the
OFFICIAL period then the percentage of filings to total
"amateur community" is 1730 / 603240 = 0.29 percent. One
can go nuts in establishing "correct criteria" without
determining anything of specific value. A slice of only
about a single percent as to the opinion of "the amateur
community" isn't a good statistical sampling of the
opinion of ALL.***

** The 5/6 value assumes that 1/6 of all licensees are IN
their grace period. It would be erroneous to accept that
since most living/able licensees renew BEFORE their 10-year
license terms are up. The total number of licensees with
valid (able to operate legally) licenses would be larger.
Compounding that is the fact of last year's license
numbers (at hamdata) showing 17,003 expirations versus
16,933 new licenses granted in the preceding year. The
amateur radio total license numbers have remained very
static for the last 2 years and several months.

*** FCC does not consider just those filings from licensed
radio amateurs to reach a decision on an NPRM. If it did
accept just those in the "clubhouse," then those individuals
not licensed would not be mentioned in Reports and Orders.
They are. All those who submitted filings on WT Docket
05-235 did so voluntarily and there are NO sampling rules
available to set any accuracy of results of a small
sampling of any opinion.