N2EY wrote:
In article t, "KØHB"
writes:


"N2EY" wrote


So when you gonna send that proposal to the FCC?

I already did (as you knew perfectly well).


But only as a comment to another's proposal, not as a stand-alone petition.


Hopefully Hans has a ready supply of replies for the FCC to use when
people comment on his petition. It just won't seem right to comment on
it there without being called stupid...oops, I mean novel! ;^)

- Mike KB3EIA -

In article , Mike Coslo writes:

N2EY wrote:
In article t, "KØHB"
writes:


"N2EY" wrote


So when you gonna send that proposal to the FCC?

I already did (as you knew perfectly well).


But only as a comment to another's proposal, not as a stand-alone petition.



Hopefully Hans has a ready supply of replies for the FCC to use when
people comment on his petition.

So far, Hans has sent in his ideas only as a comment to others' petitions and
proposals, Mike. He hasn't sent FCC a petition or proposal to FCC.

It just won't seem right to comment on
it there without being called stupid...oops, I mean novel! ;^)

I think that if Hans was really serious about his proposal, he'd send it off to
FCC just like the other 14 petitioners recently did. I say this because it is
highly doubtful that the major and unique features of his proposal would be
adopted by any other group such as ARRL, NCVEC, or NCI. It is also highly
doubtful that his proposal, when submitted as a comment, would have nearly so
much effect nor gather nearly so much attention as if submitted as a proposal.

If and when Hans did submit it as a petition, FCC would then most probably
assign it an RM number and take comments and reply comments on it. Which I
sense is a process that Hans wants to avoid, because there are bound to be both
supporting and opposing comments. It would be fascinating to see the
reactions....

But it's Hans ideas and therefore his call as to whetehr to submit it or not.

73 de Jim, N2EY

"N2EY" wrote


Which I sense is a process that Hans wants to avoid,
because there are bound to be both
supporting and opposing comments.

Avoid????? What a strange thought process, coming from someone who seems to
be familiar with my participation here on rrap. Do I appear bashful about
stating my ideas, and avoiding reactions to them?

The field is currently crowded with at least 14 petitions, and ARRL will
likely make it 15. Would you like a petition of yours to be buried in that
noise level? Timing, Jim, is EVERYTHING, and introducing another petition
at this time would NOT be a way of gaining any significant mindshare from
the rulemakers.

Happy Y3K,

de Hans, K0HB

In article et, "KØHB"
writes:

"N2EY" wrote


Which I sense is a process that Hans wants to avoid,
because there are bound to be both
supporting and opposing comments.

Avoid????? What a strange thought process, coming from someone who seems to
be familiar with my participation here on rrap. Do I appear bashful about
stating my ideas, and avoiding reactions to them?

The field is currently crowded with at least 14 petitions, and ARRL will
likely make it 15. Would you like a petition of yours to be buried in that
noise level? Timing, Jim, is EVERYTHING, and introducing another petition
at this time would NOT be a way of gaining any significant mindshare from
the rulemakers.

Excellent point. There are a total of 4,661 documents on the ECFS
for those 14 petitions mainly concerned with code testing.

That's more than was gathered on NPRM 98-143 by close to 2K.


Happy Y3K,

I think that should be "Y1K" considering the Reverend's love of the
past...

Just a thought.

WMD

K0HB, the perfect argument against code.

KØHB wrote:

"N2EY" wrote



Which I sense is a process that Hans wants to avoid,
because there are bound to be both
supporting and opposing comments.


Avoid????? What a strange thought process, coming from someone who seems to
be familiar with my participation here on rrap. Do I appear bashful about
stating my ideas, and avoiding reactions to them?

The field is currently crowded with at least 14 petitions, and ARRL will
likely make it 15. Would you like a petition of yours to be buried in that
noise level? Timing, Jim, is EVERYTHING, and introducing another petition
at this time would NOT be a way of gaining any significant mindshare from
the rulemakers.

Happy Y3K,

de Hans, K0HB

In article et, "KØHB"
writes:

"N2EY" wrote


Which I sense is a process that Hans wants to avoid,
because there are bound to be both
supporting and opposing comments.

Avoid?????

Why, yes.

What a strange thought process, coming from someone who seems to
be familiar with my participation here on rrap. Do I appear bashful about
stating my ideas, and avoiding reactions to them?

Not here. But I don't know about in the much wider arena of petitions to the
FCC.

The field is currently crowded with at least 14 petitions, and ARRL will
likely make it 15.

The comment and reply comment periods to all of those 14 petitions are long
past. ARRL hasn't started yet.

Would you like a petition of yours to be buried in that
noise level?

What noise level? Right now there are no petitions/RMs/NPRMs on amateur license
requirement changes out there. Yours would have the comment stage to itself
right now.

Soon ARRL will have its board meeting, and then there will probably be a
proposal that will gather all kinds of comments. Obviously you don't want to
compete with that!

Timing, Jim, is EVERYTHING, and introducing another petition
at this time would NOT be a way of gaining any significant mindshare from
the rulemakers.

Of course! But if you wait too long, the opportunity may be lost. Considering
the way FCC tossed out 14 RM numbers in two batches of seven, if you wait you
may find your proposal batched with ARRL's. If you wait too long, FCC could
move on to the NPRM process before you ever get the petition sent in.

Happy Y3K,

And looking forward to Y4K

73 de Jim, N2EY

"N2EY" wrote

Of course! But if you wait too long, the opportunity may be lost. ......
If you wait too long, FCC could move on to the NPRM process
before you ever get the petition sent in.

Did I miss something? Is this the last NPRM that FCC will issue in Amateur
Radio matters?

The current salad bowl of 14 (15?) petitions is primarily concerned with
Morse testing for HF access. I've already commented on that matter.

The changes I'd like to see in the Amateur Radio service are only mildly
concerned with Morse Code, but primarily concerned with the fundamental
licensing structure of our service. I don't want that issue lost in the
cacaphony of noise surrounding the Morse Code testing issue, so if I do
submit a petition it will be timed to avoid being confused as a "Morse Code"
petition.

73, Hans, K0HB

In article . net, "KØHB"
writes:

"N2EY" wrote

Of course! But if you wait too long, the opportunity may be lost. ......
If you wait too long, FCC could move on to the NPRM process
before you ever get the petition sent in.

Did I miss something?

No, but I did. Thank you for clearing up your thinking on your
method of presenting your proposal, Hans.

Is this the last NPRM that FCC will issue in Amateur
Radio matters?

Of course not! But once FCC does so (probably some months after ARRL does its
proposal), it will be a while before they want to reopen that can of worms
again.

Of course I could be mistaken on that. I thought that FCC would simply dump
Element 1 via Memorandum Report and Order soon after S25.5 changed. At most I
thought there'd be a quickie NPRM. But instead it looks like we're in for a
long ride.

The current salad bowl of 14 (15?) petitions is primarily concerned with
Morse testing for HF access. I've already commented on that matter.

So did I.

Perhaps my preference for doing a job once rather than nickel-and-diming it to
death is showing in that I think a more comprehensive approach (like your
proposal) is better. But that's just me - and it's *your* proposal anyway.

The changes I'd like to see in the Amateur Radio service are only mildly
concerned with Morse Code, but primarily concerned with the fundamental
licensing structure of our service. I don't want that issue lost in the
cacaphony of noise surrounding the Morse Code testing issue, so if I do
submit a petition it will be timed to avoid being confused as a "Morse Code"
petition.

I can certainly understand and respect that approach even if I don't agree with
it 100%.

My main concern is that if you wait until the Morse Code test issue noise dies
down, it may be a long wait *and* there may be an addy-tood of "oh no, we're
not going to reopen THAT can of worms again". Meanwhile, really bad proposals
like the "21st Century" ideas may take the stage, or even be enacted. As much
as I disagree with some parts of your proposal, it is infinitely preferable to
the "21st Century" concepts.

So it becomes clear to me now that you will submit it to FCC when you know the
time is right - which is not right now.

73 de Jim, N2EY

In article , (N2EY)
writes:

In article . net, "KØHB"
writes:

"N2EY" wrote

Of course! But if you wait too long, the opportunity may be lost. ......
If you wait too long, FCC could move on to the NPRM process
before you ever get the petition sent in.

Did I miss something?

No, but I did. Thank you for clearing up your thinking on your
method of presenting your proposal, Hans.

Is this the last NPRM that FCC will issue in Amateur
Radio matters?

Of course not! But once FCC does so (probably some months after ARRL does its
proposal), it will be a while before they want to reopen that can of worms
again.

Of course I could be mistaken on that. I thought that FCC would simply dump
Element 1 via Memorandum Report and Order soon after S25.5 changed. At most I
thought there'd be a quickie NPRM. But instead it looks like we're in for a
long ride.

So, as the "insider" you don't consider consideration of the "ARS
Community" to be important?

Just on the petition comments alone, FCC has nearly twice the
documents that 98-143 had already and NO NPRM has yet been
issued.

If and when an NPRM on code-testing appears, the commentary
received is going to be gigantic in my estimation. It will make the
four-year-old-plus comments on 98-143 seem paltry in comparison.

The current salad bowl of 14 (15?) petitions is primarily concerned with
Morse testing for HF access. I've already commented on that matter.

So did I.

There are 4,661 documents on the 14 petitions. What is your
percentage of the total?

Perhaps my preference for doing a job once rather than nickel-and-diming it to
death is showing in that I think a more comprehensive approach (like your
proposal) is better. But that's just me - and it's *your* proposal anyway.

Perhaps you don't care to spend the time and effort to reply/comment
on all 14 petitions?

Did the FCC "lose" some of your comments? I don't see 14 comments
under your name. [it's all public, you know, no "google" needed...]


My main concern is that if you wait until the Morse Code test issue noise dies
down, it may be a long wait *and* there may be an addy-tood of "oh no, we're
not going to reopen THAT can of worms again". Meanwhile, really bad proposals
like the "21st Century" ideas may take the stage, or even be enacted. As much
as I disagree with some parts of your proposal, it is infinitely preferable
to the "21st Century" concepts.

Hiram forbid EVER taking the US amateur radio service "into the
21st century!"

Morse code uber alles! Marsch, marsch, marsch...

WMD

"KØHB" wrote in message
nk.net...

"N2EY" wrote
Which I sense is a process that Hans wants to avoid,
because there are bound to be both
supporting and opposing comments.

Avoid????? What a strange thought process, coming from someone who seems
to
be familiar with my participation here on rrap. Do I appear bashful about
stating my ideas, and avoiding reactions to them?

The field is currently crowded with at least 14 petitions, and ARRL will
likely make it 15. Would you like a petition of yours to be buried in
that
noise level? Timing, Jim, is EVERYTHING, and introducing another petition
at this time would NOT be a way of gaining any significant mindshare from
the rulemakers.

So what is your likly timetable for submission?
After an ARRL submission?
If yes, how soon after?

There is a risk of submitting beyond a point where the FCC has
already digested the 14 or probably will be 15 submissions and
then posts a NPRM. By that time any new proposals aren't
likly to get any attention...IMHO.

Cheers,
Bill K2UNK