wrote on Mon, 25 Jun 2007 20:44:58 EDT:

On Jun 25, 6:52?pm, AF6AY wrote:

The ARRL hierarchy was dead-set against
abolishing the code test or even reducing the test rate
back in 1998.

That's simply untrue. You are mistaken, Len.

I stated an opinion. Opinions aren't "test" answers. There are no
"incorrect" or "correct" lables except from one's own subjective
viewpoints. You subjective viewpoint does not over-rule mine. :-)

I used the "code thing" as illustrative of the ARRL's conservative
attitudes towards code testing. It was not an attempt to revive
some ages-old argument over just code testing. It was an
illustration,
an example.

Here's what really happened back then:

What "really happened back then" is history. It is documented.
By others.

In its 1998 restructuring proposal to FCC, the ARRL proposed the
following changes to Morse Code testing:

The ARRL has never given up on trying to KEEP code testing for at
least Amateur Extras up to and including NPRM 05-235. That is
also documented. At the FCC.


ARRL was against it even though the IARU recommended
the changes to S25.5 at WRC-03.

Incorrect.

In early 2001, ARRL changed its policy of support for S25.5 from
supporting continued code testing to no opinion.

How is having "no opinion" a "support?" :-)

Incidentally, MOST of ITU-R S25 was rewritten at WRC-03; S25.5
only applied to administrations' license testing requirements in
regards to international morse code.

In its proposal to FCC after ITU-R S25.5 was revised, ARRL proposed
that all Morse Code testing for all amateur radio licenses except
Extra be eliminated.

The ARRL refused to bend on code testing for Amateur Extra...they
HAD to have it in there. :-) That is only natural. The ARRL
represents its membership. The ARRL's core membership is made
up of long-time amateurs favoring morse code skill as the epitome of
US amateur radio skills.

ITU-R S25 does not directly apply to United States radio regulations.
It has no force of law. The United States is obliged to follow the
decisions of this UN body on the basis of Foreign Policy and all
treaties made by the United States to others.

As rewritten, ITU-R Radio Regulation S25.5 removed the requirement
that all adminstrations mandate code testing for all administrations'
licenses yielding amateur operating privileges below 30 MHz to
making it Optional for each administration to do as it wished. There
is no direct relationship between S25 and whatever the ARRL wanted.


In 2005, complete elimination of all Morse Code testing was not the
majority opinion of those who bothered to comment.

Comments on Notices of Proposed Rule Making (NPRMs) are not a
"vote." They never had such a definition. The Commission issues a
Notice of Proposed Rule Making, then invites Comments on same.
The FCC is not, nor has it ever, been "required" to obey any
"majority" opinion of Comments. The Commission will, after the
official end of the Comment period, consider all such Comments
and make a final decision on the NPRM. That final decision then
becomes a Memorandum Report and Order, colloquially known as
an "R&O." Once that R&O is published in the Federal Register, it
become law.

Anyone who wishes to look can go to the FCC's ECFS and Search
under 05-235 and 25 November 2005. On that date I submitted an
EXHIBIT done after the end of official Comment period on 05-235 and
offered solely as an Exhibit. In that I made tallies day-by-day of
each
and every Comment and Replies to Comments totaling 3,795 made
from 15 July 2005 to past the official end of 14 November 2005. I
read
each and every one of the 3,795 documents. Note that nearly half of
the documents were posted before the official start of the Comment
period on 05-235. I commented on that fact in the Exhibit.

That Exhibit has been argued before and I will not reprise it. The
Exhibit document stands on its own and was done over a year and a
half ago. The FCC accepted it enough to post it for public viewing
on their ECFS.

The ARRL is not obliged to publish my views on anything despite my
being a dues-paid voting member. That is as it should be. The ARRL
is a private membership organization and is NOT a part of the
government of the United States. The FCC is a part of the government.
The FCC is obliged to answer to all citizens of the USA. ARRL
membership is less than a quarter of all licensed US radio amateurs.
ARRL members cannot constitute a "majority" of amateur licensees.

AF6AY