Before the Board of Licensure for Professional Engineers
State of Maine


In the matter of:

Brian L. Crow, Complainant

vs.

Glenn A. Baxter, P.E., Respondent

Registered Professional Engineer, By Examination, in Illinois

and

Registered Professional Engineer, by Reciprocity, in Maine

and

Amateur Radio Call Sign K1MAN

and

Executive Director of the Fire Hazard Reduction Institute
(Box 440, Belgrade Lakes, Maine 04918 tel. 1-800-262-9543)

and

Certified Fire Safety Advisor


-----------------------------------------

SECOND MOTION TO DISMISS,

or

SECOND REQUEST FOR HEARING


------------------------------------------



Respondent, Glenn A. Baxter, P.E., hereby comes through this pleading
and makes this sworn affidavit of his own personal knowledge.



INTRODUCTION

The original Brian Crow "Complaint" has essentially been dismissed by
the Board with the focus now being on general discharge issues with a
former employer, Ray Bouchard, and a Complaint made by Respondent to
the Board against the Professional Engineer whose P.E. stamp was on
Bouchard's new building plans which are in clear fire code violation
according to a representation made to Respondent by the Augusta Code
Enforcement Officer. This latter Complaint was dismissed by the
Board on the curious grounds that said engineer "was not involved," an
issue now being formally investigated by the Fire Hazard Reduction
Institute, Glenn A. Baxter, P.E., Executive Director.


1. Respondent is currently d/b/a as Executive Director of the Fire
Hazard Reduction Institute and is a Certified Fire Safety Advisor with
hundreds of inspections and fire safety installations already made
throughout Maine and the primary source of professional income since
FHRI's inception shortly after Respondent was "fired" from Ray
Bouchard's Light of Life Ministries and Christian radio stations in
Augusta, Maine.


2. Respondent was hired by Mr. Bouchard in 2003 to be his "Chief
Engineer" in the radio sense of the term "engineer" on the strength of
Respondent's First Class Commercial Radiotelephone(1) and Amateur
Extra Class FCC licenses, 16 years of experience in designing and
operating a multi transmitter short wave station heard world wide
(with an ID announcer being former CBS Newsman Walter Cronkite, who
is also a licensed amateur radio operator), many years of professional
experience in electronics repair and engineering modifications to
Collins high frequency equipment, the design for in house
manufacturing of electro-mechanical filters (equivalent to Collins
mechanical filters) which were the very "heart" of 750 low frequency
receivers custom made for our U.S. submarine fleet, and design and
installation of many radio tower and antenna installations.

Respondent has a B.S. Degree in Industrial Engineering (January 1968)
from the University of Rhode Island and is a Registered Professional
Engineer by examination in that specialty in Illinois, and by
reciprocity in Maine.

Respondent has completed significant course work in electrical
engineering and has published several articles in the area of physics,
chemistry, and the theory of relativity, as well as teaching high
school physics, chemistry, and advanced math.


3. Unknown to the Respondent, Mr. Bouchard did not have adequate
finances to do most of the projects worked on, and the Station Manager
advised Respondent of this fact in detail after the time of hiring.
Apparently, Mr. Bouchard really hired Respondent to train a high
school junior for six months in electronics and engineering so that
this person could assume the job of permanent Chief Engineer at
minimum wage or less, since common practice at the station was to work
full time and be paid for far less time than actually worked.

For example, Mr. Bouchard constructed the whole station himself, and
there were no wiring diagrams or schematics of any of the maze of
wire interconnects present in his broadcast station. Respondent
strongly recommended making such diagrams and schematics, and Mr.
Bouchard insisted that Respondent do this work on Respondent's "own
time," which Respondent declined under these circumstances. Lack of
these diagrams and schematics would naturally create a "night mare"
for Respondent when there was an equipment failure, as actually
happened and has become a subject of the current Complaint against the
Respondent.


4. Respondent never received a written job description until a few
days before being "fired." The paper signed by Respondent at the
time of hiring gives an incorrect impression that there ever was a
written job description. The actual job description was verbal and
changed on a continuing basis and included:

o Training and supervising the high school junior

o Organizing the relocation of the FM transmitter site

o Design and construction of the new transmitter site

o Starting and running an electronics school

o Negotiating with Salvation Army and private owners regarding
proposed translator sites

o Repairs to station equipment

o Negotiation for a cooperative venture in training recent
jail released persons.

o Erecting the first translator tower

o Negotiating the price of custom designed antennas

o Negotiating the price for purchase of station equipment

o Salvaging donated towers and equipment.

o Trouble shooting a recently installed repeater

o Selling unwanted equipment on E-Bay

o Consulting with professional consultants

o Making transmitter compliance measurements


When the owner of the FM transmitter location asked "Where is Glenn?",
Mr. Bouchard said "He was let go because he wasn't following his job
description." Respondent demanded in writing a retraction, and never
got one from Mr. Bouchard.


5. Respondent had a computer in his engineering office (found out
later to be illegally occupied per the REAL Code Enforcement Officer -
Respondent was introduced to a phony "Code Enforcement Officer"
minutes before being "fired(2)" -) with all work done for 2003 on a
single disk. This disk was loaded into the central office
computer as a back up and so some printing could be done on the
central office printer. After being "fired," Mr. Bouchard found this
computer file and jumped to the false conclusion that Respondent did
non job related work on company time. Respondent never did any such
thing, this being a very serious allegation and being a part of the
current "Complaint".


6. Respondent wore many hats and relied on different credentials at
different times. For example, during the tower erection, Respondent
relied on previous tower erection experience with the guy anchoring
scheme being standard amateur radio practice and right out of the
ARRL antenna handbook(3). The design of the tower system was not a
Professional Engineering design, although a progress report was
written in a document signed by the Respondent who happens to be a
Professional Engineer as opposed to "as a Professional Engineer."


7. Note there is nothing in the above list of job descriptions
regarding contact with the FCC or obtaining a required construction
permit from the FCC. When Respondent realized that there were
serious FCC violations being made by Mr. Bouchard, I brought this to
the attention of the station Manager who advised me to protect my
personal commercial FCC license which I did by reporting the
violations to the FCC immediately, both to mitigate the damages for my
employer and to eliminate the danger, as Chief Engineer, and the
legal FCC interpretation of this, to my FCC commercial license.


8. At no time did I ever disclose confidential information to anyone
in violation of Professional Engineering ethics as apparently alleged
by Mr. Bouchard.


9. Although apparently dismissed by the Board, Respondent hereby
addresses the "Nazi" comment. Respondent is a world wide short
wave celebrity with a daily radio program often containing robust
editorials. Respondent often publishes editorials on the internet.
One amateur radio data base at www.QRZ.com decided, for "hobby
politics," reasons to de-list Respondent's radio call sign K1MAN.
About 1000 persons posted comments, many to the effect that Respondent
does not deserve to have a listing on www.QRZ.com which uses public
FCC data as its basis. Making an editorial point, Respondent
compared a list of commenter's call signs with being tantamount to
membership in the "American Amateur Nazi Party." There is no such
animal, of course. "Nazi" was later changed to "Nerd." One on the
list was apparently a P.E. in California, something unknown to the
Respondent and not really relevant to this current "Complaint."


8. As a Professional Engineer, I notified the owner and three other
Managers of serious fire hazards at the station shortly after the
AM transmitter caught fire under the stairs of the only exit to the
"fire death trap" old building. That old building, curiously, met
the code, but the new building did not meet code according to the REAL
Code Enforcement Officer who, somewhat embarrassed, dismissed it
as being only 16% or so out of compliance. I notified this Code
Officer in writing of my objections, and he "ducked" his mail several
times until I served him with written notice at his home address.
This is when I fully realized the common and life threatening "slack"
involved in these fire safety matters, an issue at the very heart of
professional engineering licensing, namely protection of public
safety.

It is my legal position that immediate protection of the lives of the
public required addressing these concerns to more than just the
owners and Station Manager. The concerns were immediate, time
sensitive, and this was no time for "secrets" or confidentiality, in
my Professional Engineering opinion. Protection of life was my
paramount and immediate concern. I genuinely felt the threat of
criminal prosecution for criminal negligence should another fire break
out and someone should die in Bouchard's fire traps due to inaction.

I realized that a serious entity needed to be created for public fire
safety, and this is when I started the Fire Hazard Reduction Institute
with my opening salvo being a formal complaint against the
Professional Engineer whose P.E. stamp I saw on the new Bouchard
building plans when I first visited the Code Enforcement Officer's
office. He, by the way, is also a licensed ham radio operator. His
alleged representation to the Complaint Officer of this P.E. Board
that he advised me that the new Bouchard building met code is simply
not true! He agreed with me that the building was out of code by
about 16% but that he had issued a "waiver." This, plus Mr. Bouchard
introducing me to a phony Code Officer just before I was "fired" (a
crime I reported to the Augusta Police) was the real driving force
behind the newly created Fire Hazard Reduction Institute and also
started me on a new and exciting professional career as a Certified
Fire Safety Advisor.

The Fire Hazard Reduction Institute has uncovered other evidence and
testimony about more fire safety code violation issues in Maine in
addition to this Board choosing to dismiss out of hand Respondent's
formal Complaint. Even new Board member William A. Lotz, P.E.
stated during the 19 January 2006 Board meeting that he has personally
observed numerous situations that are in FLAGRANT fire code violation
here in Maine.

I feel that if I didn't do everything in my power to bring these
life threatening violations to light, I would not be living up to my
ethical responsibility as a Licensed Professional Engineer, if not
also being criminally negligent, should anyone ever be killed in one
of Mr. Bouchard's or someone else's fire traps. I don't feel that
(or it is not my legal position that) Professional Engineering client
confidentiality applies here since I did file a formal Complaint
(available to the PUBLIC) with this Board AFTER being "fired" by Mr.
Bouchard with my genuine concerns being consistent with being denied
my statutory right to cross examine and subpoena witnesses in my
"test case" unemployment claim hearing where Mrs. Bouchard even
perjured herself; this also being consistent with my Complaint to the
Maine Overseers of the Bar regarding an illegal and totally false
ex-parte letter (de facto to the Hearing Officer - a clear violation
of Maine bar rules) being filed by Bouchard's attorney, Robert Stolt,
also being dismissed out of hand (by the Maine Overseers of the Bar).

To get this (affront to justice) officially in before of the
Overseers' supervisory authority, the Maine Supreme Judicial Court,
Respondent brought a civil action in Superior Court against Mr. Stolt
which was dismissed (surprise, surprise!) and then appealed to the
Maine Supreme Judicial Court, also dismissed on the de facto bogus
grounds that Mr. Stolt's ex-parte letter was privileged (it was, of
course, that wasn't the point; it clearly voilated bar rules, and the
Overseers didn't do their job to discipline Maine licensed Attorney
Robert Stolt; point made to the honorable Maine Supreme Court
justices, QED I think!)


Indeed, since this Board voted in a public meeting attended by the
Complainant's apparent representative, Ralph Myra, K1IV, (and thus now
probably reported on world wide amateur radio short wave as well as
over the world wide internet) to fine me $1,500 (via a Board proposed
consent agreement) for making an alleged false formal Complaint about
the Maine Professional Engineer who wrongly approved the out of code
Bouchard building plans, I am hereby publishing this reply document on
the internet as well (to protect my professional reputation) at also
world wide www.K1MAN.com. (and also in the public interest of
exposing these very dangerous and - life threatening to the public -
and commonly found conditions now in Maine - and most other states -
and illustrated - for Maine - above).



Wherefore, Respondent respectfully declines to sign the proposed
consent agreement and pay the proposed $1,500 fine,

and

Respondent moves the Board to Dismiss this Complaint

or

Respondent requests a full hearing,

and

Respondent requests this Board to reopen the Respondent's Complaint
about the Bouchard unsafe and dangerous to the public fire traps (in
my Professional Engineering opinion).



Respectfully submitted,







(signed)
Glenn A. Baxter, P.E.
Certified Fire Safety Advisor







(1) Now known as a General Radiotelephone License

(2) Respondent had just written an engineering report outlining very
serious fire hazards in both the old and new buildings at the station.

(3) The guy anchoring scheme is known to amateur radio operators as a
"dead man." The expanding bolt installation was on the advice of the
supplier.




Sworn before me,







(signed)
______________________________________ __________________________
Notary Public Date