In article , "Carl R. Stevenson"
writes:

"N2EY" wrote in message
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"Carl R. Stevenson" wrote in message
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"Carl R. Stevenson" wrote in message
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NCI's Petition for Rulemaking with the FCC.

It is available in .pdf format at http://www.nocode.org
under the "Articles" link ...

OK, let's cut to the chase.

Obviously the main request is to dump Element 1 ASAP. And there's
probably lots of reasons given for doing so, including the
Commission's own words "no regulatory purpose".

But what else was in the petition?

I gave you a URL where you could read it ...

Not really. You gave the main website and left it up to the reader to find the
article, then download it and open it as a pdf.

If you really wanted people to read it, you'd have it front-and-center on the
webpage and post a direct link.

That's not what I asked.

Here's the answer, to save others the bother of reading 20 pages to
get the answer to my question:

NOTHING.

Jim,

You say "NOTHING"

That's right.

... but in the following paragraphs you admit
that "Most of the 20 pages is supporting reasons to make the change."

Yup. And that was already referred to.

Yes, referred to with a thinly-veiled attempt to dissuade others from
reading and considering all of those reasons.

Not at all. My main concern was whether there were other things in the
petition, such as written test changes, license class changes, etc. There
weren't.

Look again at what I wrote:

"Obviously the main request is to dump Element 1 ASAP."

Which is true.

Yes ... what did you expect?

I expected that much. It's the unexpected that I was concerned about.

Since NCI does not want me as a member, and keeps its internal policy functions
secret, I was simply asking for a quick indication of what other issues would
be covered.

That *IS* NCI's chartered goal.

And it's a good thing they are sticking to it, rather than getting bogged down
in other issues.

"And there's probably lots of reasons given for doing so, including
the
Commission's own words "no regulatory purpose"."

Which is also true.

And then the question:

"But what else was in the petition?"

The "what else" refers to things OTHER THAN dropping Element 1 and
reasons to drop Element 1.

And the correct answer is: NOTHING. The petition consists of a request
to drop element 1 and reasons to do so.

What did you expect?

See above.

That is what a Petition for Rulemaking IS ... a
specific
request(s) and all of the supporting arguments ...

Those specific requests could be anything.

I *really* don't know what else you're asking for ...

Here, I'll spell it out for ya:

You could have simply answered my question this way:

'NCI requested the immediate removal of Element 1 for all classes of license
and the granting of Novice/Tech Plus privileges to all Technicians. Detailed
supporting arguments were included in the proposal. No other changes were
requested because they fall outside the stated purpose of NCI."

One paragraph. Three sentences. Short sweet and concise. 100% accurate. Would
it have been so hard to have answered my question that way?

I think that's important information for folks to consider ... that's
why
I encourage folks to actually READ and consider the NCI Petition,
rather than relying on your "5 cent synopsis."

I've read and cosidered it, and I'm opposed to it.

Really? (what a surprise)

Yes, really.

Why do you want to "save others the bother" of reading the Petition?

Because we already know that it would contain a request to drop
Element 1 and reasons to do so. Those reasons have been argued
endlessly here and elsewhere.

The reasons elaborated in the Petition form the factual, legal, and
rational basis for granting the request ... I think they're presented
clearly in a well-organized manner that, in only 20 pages, tells a
a reader all they need to know to make an informed decision based
on the facts.

My summary, above, boils it down to three sentences.

You don't WANT people reading it and coming to the logical
conclusion, IMHO ...

Not at all! Did I say anyone should not read it? Of course not! I simply wanted
to save the time of wading through 20 pages of same-old same-old looking for
something new.

My question was about what else was in the petition besides dropping
Element 1 and reasons to do so.

That wasn't clear at all ...

Sure it was...if you read what I wrote.

and why you would expect more escapes me,
since, as I pointed out above, all of the essential elements of a Petition
for Rulemaking are there (and you knew the what the goal of the Petition
would be before it was written ...)

Because there is always the chance that something unexpected would be in there.


(Could it be that you find the arguments so compelling that you don't
WANT others to read them???)

Nope. None of the arguments are compelling at all. Not to me, anyway -
YMMV. And we've all read them many times before.

OK, we disagree ... but I believe the FCC (and MANY amateurs) will
find the arguments compelling.

Sure. They've already been convinced. Did not FCC write, almost 4 years ago,
"no regulatory purpose"? Those three little words say it all.

I don't think the petition will change anyone's mind.

You HOPE not ... that's why you try to brush it off as somehow being
insignficant and "not worth the time to read." Interesting tactic, but
I doubt that it will work.

Has anyone's mind been changed?

The NCI petition consists of a request to drop Element 1 without
further delay or discussion and give Techs the same privileges as Tech
Pluses. No other changes proposed. Most of the 20 pages is supporting
reasons to make the change.

Is this synopsis not 100% accurate?

Yup ... and that's EXACTLY what's SUPPOSED to be there.

In your opinion. Do you dictate NCI policy, Carl, or is it formulated by the
Board? I'm an outsider, remember - not even privileged to know how many
members NCI has.

As you have pointed out, Carl, FCC hasn't even given any of the
proposals an RM number yet. And it's reasonable to assume there
will
be more proposals - from NCVEC, ARRL, and other groups. FCC may
assign
numbers, or they may take ideas from each one and produce an NPRM.

NCVEC already filed a petition, as have several individuals.

It's clear NCVEC isn't done yet. They're talking about other changes
too.

That's their business ... NCI is focused on the Morse test issue and
is not proposing more sweeping changes that are outside of our
charter ...

That's the smart way to go. Focus on the core issue and don't be
delayed or derailed by other issues.

Bingo ... and I don't believe that the FCC will allow this issue to
get bogged down with other unrelated issues. It's too clear-cut,
whereas other issues (band segmentation, privs by license class,
etc.) are clearly going to be harder to deal with because they are
not so clear-cut.
(They're also not NCI's charter, so they're not our "ox to gore.")

Maybe. OTOH, if the issue is that clear cut, why is FCC dragging its feet? I
actually thought the main delay would be ratification, and that the removal of
Element 1 would be a quick MO&O thing. Now it looks like the whole NPRM cycle
will be invoked. A year - 2 years....?

There are supposedly four other petitions filed, too. Wonder what they
say?

They basically say the same thing, in various levels of detail and
sophistication,
ranging from a 1-pager from a guy who's filed MANY (read between the lines)

Not many lines to read between in a one-pager...

to a few pages of generally well-considered material that doesn't have the
cites
to law, previous FCC decisions/determinations, etc. that NCI's has. They
all
add to the momentum, however ...

Maybe. NPRM means comments...

I urge all to read the NCI proposal and consider the arguments contained
therein. I don't agree with them or find them compleiing - maybe others will.

73 de Jim, N2EY