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September 5th 05, 05:02 AM

wrote:
From: Carl R. Stevenson on Aug 30, 5:53 pm

wrote in message

It is not at all uncommon for items to take this length of time and more to
appear in the Federal Register.

Is a Notice of Proposed Rulemaking a legal document or not?

Does it not say on NPRM 05-143 that a stated Comment period
exists on both the title block on page 1 and in item 54 on
page 25? It says that the Comment period BEGINS when the
notice is published in the Federal Register. Both pages.

I know they (the FCC) are as frustrated as anyone else with the "lead time"
they sometimes face for the Fed Reg (produced by the GPO).

I don't "know" that. I'm just a citizen living roughly
3000 miles from Washington, DC, and depend on the Internet
for "quick" news out of my government. I have NO law firm
to "represent me" and can't afford a Lobbyist firm to push
for anything.

The only "problem" observed with the Federal Register TOC
page was a four-day gap two weeks ago...when they failed to
update the links to appropriate days for Volume 70 (all of
2005). Without a link to the Day TOC, NO ONE can see what
is in them unless they get the paper version.

Perhaps ARRL is waiting until the Fed Reg publication, too, so that their
comments will not "technically" be "premature."

...and perhaps the ARRL is NOT so all-fired "pure" as you say.

Then again, I am not running for any office at the ARRL.

Neither am I running for any office at NCI.

The ARRL was opposed to revision of ITU-R Recommendation S25, in
particular S25.5 making it mandatory for all administrations to
test for morse code proficiency for any license having below-30-
MHz operating privileges. The IARU was for the revision, being
its principal author of change which was voted in at WRC-03.

That is misinformation ... the ARRL "got with the program" on the revision
of S25.5 and was represented on the US Delegation. They also pushed the
improvement of S25.6 by adding a reference to a recommendation that gives
administrations guidance on the (technical) things that applicants for
amateur licenses should be tested for (which NCI also supported).

I wasn't IN Geneva, Switzerland, for WRC-03. All I read are the
U.S. Delegation's Report on WRC-03, comments from the IARU on
their web page, comments on several other web pages, and a few
items that have made it into print so far.

I read what everyone else reads...and that INCLUDES Dave
Sumnner's infrequent postings from Geneva during WRC-03.

From there on, it is speculation. The Comment period on NPRM
05-143 in WT Docket 05-235 has NOT OFFICIALLY STARTED. No notice
has yet been made in the Federal Register. There have been 1920
Comments already filed with the FCC on that Docket. Are these to
be rendered "useless" for consideration because of no Federal
Register notice given before they were filed? [see the Title
Block of NPRM 05-143 as well as page 25, item 54, for the period
of Comments and Replies to Comments]

As a practical matter, while comments file before the Fed Reg publication
are "technically" "premature," they will never the less be read and
considered by the FCC.

Hello? Who are you trying to kid here? Ever hear of "sunshine"
or see the big red type on some dockets' Comment listings?

When did you work IN the FCC Carl?

Further speculation - fueled by suspicion - is that some sort of
behind-the-scenes "stonewalling" is going on...perhaps by
lobbyists urging the FCC to delay the Federal Register notice.
Of all the possible organizations having sufficient "clout" to
lobby the FCC, the ARRL is pre-eminent, retaining the services of
both a communications-law firm and a professional lobbying firm
in the District of Columbia area.

As I said, the publication in the Fed Reg is beyond the FCC's control and I
know that they are just as frustrated as anyone else when this sort of delay
occurs.

Gratuitous corporate doublespeak phrase.

The FCC is simply NOT THAT CONCERNED about amateur radio matters.
Want evidence of that? Go to the FCC home page, click on Wireless
Communications Bureau. When you get to the Bureau, click on
"Amateur." What do you see in "news" of procedings there?

Hello, the LATEST date is 8 October 2002 on DA 02-2475, Antenna
siting and support structure revision to Part 97. Damn near
THREE YEARS OLD. Not one single thing about the 18 Petitions that
went through from 2003 to 2004. Not one notice that NPRM 05-143
was ever released. Not one notice in the separate page of "open"
procedings from all Bureaus and Offices.

"Delay" is like a few days, maybe two weeks. The NOTICE for 05-143
hasn't been there for SIX WEEKS.

Trying to "nail" the ARRL on some sort of half-baked "conspiracy theory" is
simply bogus.

Bullsnit. Hello? I'm SPECULATING. Understand the word?

Don't get your legal briefs in a knot. A legal beagle you ain't
and this is NOT "moot court."

If the FCC doesn't have control over when the item gets
published, which they don't, how can you rationally assert that the ARRL is
"behind the delay???"

RATIONALLY, one only has to look over the past half-century or so
and see that, in the beginning, the ARRL used to get all that it
asked for, lobbied for, etc. All the way up to creation of the
much-beloved (by some) "incentive plan."

Since I don't work for the ARRL and am NOT running for office, I
simply observe what everyone else can observe and RATIONALLY put
together all the available information...and "connect the dots."
It's not difficult for anyone with a RATIONAL mind. Note I
emphasize RATIONAL. Those whose minds are "conditioned" or easily
swayed by nice-nice words that cater to what they want to believe
won't connect all the "dots"...those minds are NOT rational, just
conditioned (or "brainwashed" in the indelicate common phrase).

I'm just a citizen of the USA without a fancy title, can't put
words down on nice letterhead paper sounding like they are oh, so
important(!). Not being an "insider" or having opportunity to
hobnob with the rich and famous, all I or any other citizen can
so is SPECULATE...based on what has happened in years past.

BTW, I *do* appreciate all the effort you've been putting into reading all
of the comments filed and giving us the stats ...

Here's some "charm school" advice, Carl. If you want to SOUND
appreciative, put such phrases FIRST in the body of text. Putting
them at the last makes them look like the phony-baloney they
probably are.

I don't work for NCI. In fact, NCI REFUSED my no-dues membership
for over a year. I don't work for ANY big money or big
organizations and am NOT running to do so. Got that so far?
I've been doing small-scale arguing on this code-test issue since
three decades ago. And received the usual boilerplated form-
letter "replies" in surface mail, like a truly wonderful "answer"
from the late Vic Clark (?) once the elected president of the
older ARRL...which said if I "wanted to know more about radio,
buy the new book out "Now You're Talking!" Judas H. Cottonpicker,
after my beginning in HF radio communications, I was supposed to
read a "radio for dummies" book? Yeah, like thanks a lot, big
League. And the same to you.

I do some bookkeeping on numbers and percentages which are a bit
of extra effort. I read EVERY SINGLE COMMENT...for ME, not for
anyone else. I post the stats in here because I CAN...for
ANYONE's information-input. If those stats show code-test
retention, then that is what I would show. But, the stats
favor code-test elimination. Push aside the gratuitous corporate-
speak phrases and understand that. NPRM 05-143 is going to have
as large, possibly larger, effect on U.S. amateur radio in the
near future than the "restructuring" of R&O 99-412 did. Had you
read all of those Comments on WT Docket 05-235 and done an honest
synopsis of them, you would see the same. But, you are running
for office now, and that may not be in the center of your vision.

Oh, did you want nice-nice phrases down here? :-) Sorry, I don't
HAVE to work for anybody or run for office, I can speak my mind.
I've done the "charm school" thing (manager's classes) and passed
just fine. :-) Don't have to use those "lessons learned" now.
Difficult to take a RATIONAL, independent mind, ain't it? :-)

"...and INSULTING each and every person who contradicts him or just
expresses an opposing viewpoint. NOT a good image."

--Len Anderson

Sometimes you even snap and snarl at those who share your goals, Len.

Dave K8MN

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