wrote in message
ups.com...
NPRM 05-143, the Notice of Proposed Rulemaking that would eliminate
morse code test element 1 from all amateur radio license
examinations was supposedly released on 15 July 2005. It is
marked "approved" as of 19 July 2005. A scanned copy of that NPRM
was marked "received" by date stamp as 20 July 2005 and introduced
to WT Docket 05-235 supposedly on 15 July 2005...but did not appear
to anyone accessing the ECFS until 21 July 2005.

NPRM 05-143 is clearly marked as to the Comment Perior being "60
Days after published in the Federal Register." That's on the
first page and page 25 of that 30-page NPRM document.

One problem: NPRM 05-143 HAS NOT BEEN PUBLISHED IN THE FEDERAL
REGISTER AS OF THE MORNING OF 30 AUGUST 2005! A month and a half
has elapsed since the middle of July, 1962 Comments have been filed
on WT Docket 05-235 as of 29 August 2005.

Len,

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

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).


Access the Federal Register Contents page through GPO at:

http://www.access.gpo.gov/su_docs/fedreg/frcont05.html

Noticeably missing is ANY filed Comment from the ARRL. In fact,
NO organization except for one local 23-member "DX club" has filed
anything under WT Docket 05-235. No Code International Executive
Director Carl Stevenson has stated that NCI will not make any
Comment for NCI until after the NPRM has been published in the
Federal Register. The ARRL has been very noticeably present at
every other amateur radio docket proceding before the FCC...but
not yet on NPRM 05-143.

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

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).


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.

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

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

73,
Carl - wk3c