On 11 Jul 2003 07:56:06 -0700, Brian Kelly wrote:

I can visualize this phase being a real nit-picking and repositioning
exercise, perhaps a source of fodder for appeals.

Yup. Maybe that's why there are some 3000 communication attornies
in the Washington DC area (and one in Beaverton).

What's the relationship between an NOI and an NPRM? Doesn't the FCC
eventually have to publish an NPRM and go thru the whole comments and
rebuttals drill again?

Only if they decide to do it by a "publicly debated" rule change.

If they want to be sneaky (assuming that they have this much
imagination - Hey, Bill, pay attention - they can issue an Order and
Further Notice of Inquiry, dropping Element 1 and asking for further
input on Novice HF Refarming. (AKA "The SmokeScreen")

--
73 de K2ASP - Phil Kane