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#1
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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. 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. 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. In the two years since WRC-03 (July of 2003), the ARRL has generally appeared ambivalent on morse code testing with the exception of their Petition RM-10867 of 18 March 2004. RM-10867 called for a retention of morse code testing for Amateur Extra class licensees. RM-10867 was DENIED in NPRM 05-143. 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] 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. Yes, speculation is only speculation, no proof. However, time is elapsing and a month and a half has gone by sine the release of NPRM 05-143 and NO notice in the Federal Register. That is out of the ordinary procedure of the FCC. The legality of such delay is not known. We taxpayers can't peer far enough into the inner workings of the FCC (or its lobbyists) to know for sure. It may be that the failure to make notice in the Federal Register is a human error, a lapse of duty performance. If so, it could be corrected easily...but we ordinary citizens don't know. If so, there still remains a question on whether or not 1920 filed documents will be considered by the FCC on issuing a final Report and Order in regards to that NPRM. Will those be a useless effort by over 1700 citizens commenting? |
#2
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![]() 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 |
#3
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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? :-) |
#6
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![]() Dave Heil wrote: wrote: From: Carl R. Stevenson on Aug 30, 5:53 pm cut "...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. sometimes he does as is his right. I am sure he will even agree you have the right to snap and snarl at everyone who disgrees with you but you missed the point(s) as usaul Amoug them being Your snap at everyone, your right but not a good image. Len does reserve to right to snapp at folks too, event hose he shares goals with Indeed you miss out on the fact the Nocoders do disagree amoug ourselfs, and we are free to to do so, a sign of the greater freedom espoused by the NoCoders but then you never seem to get the point, and indeed seem to prefer volumes on evasion rather than answer a few simple questions Dave K8MN |
#7
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In . com "an old friend" writes:
Dave Heil wrote: wrote: From: Carl R. Stevenson on Aug 30, 5:53 pm cut "...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. sometimes he does as is his right. I am sure he will even agree you have the right to snap and snarl at everyone who disgrees with you but you missed the point(s) as usaul Amoug them being Your snap at everyone, your right but not a good image. Len does reserve to right to snapp at folks too, event hose he shares goals with Len may have the "right" to do a lot of things, but if he truly wants to "win friends and influence people" in this debate, and leave a personal legacy other than that of a Usenet "kook," he might want to take stock of who are his allies and who are his enemies. And even enemies can become allies on some issues. Recently, Len insisted that he only posts facts and truth, and challenged me to find examples otherwise. When I did, finding several recent errors and subjective interpretations, rather than acknowledge or rebut them, he chose to change the subject and accuse me of being a hanging "judge" for daring to criticize. Len also seems to feel he is entitled to unlimited public revenge against those who have slighted him, and will lash out reflexively, and Serdar Argic style, whenever anyone posts with certain "hot-button" keywords like Morse Code. Serdar accused anyone who disagreed with him as "criminal Armenian," even those who were ethnic Japanese. Similarly, I wonder if invectives like "Macho Morsemen" are aimed at Kim and Dee Dee, also. When I pointed out areas of agreement, including one example where I was the only one to side with him in this forum, he replied with, "I don't give a flying fig about your 'position.'" I also wonder why most of those that try to defend Len choose to post anonymously. I have agreed with Len on some issues, and have posted with my real name. One red flag that someone is being tuned out is the number of likely sock puppets that start to orbit around him. Indeed you miss out on the fact the Nocoders do disagree amoug ourselfs, and we are free to to do so, a sign of the greater freedom espoused by the NoCoders I'm happy to debate with anyone on any subject, and though I may disagree, I will treat that person respectfully, even going so far as to separate behavior from personality. There's a difference between honest debate and sniping, insults, and ad-hominem attacks. It's also useful to clarify and make understandable your position by indicating whom you may agree with, rather than solipsistically dismissing any worldview other than your own with, "I don't give a flying fig about your 'position.'" but then you never seem to get the point, and indeed seem to prefer volumes on evasion rather than answer a few simple questions Dave K8MN My comments on this docket are forthcoming. No evasion or avoidance of simple questions are planned. -- 73, Paul W. Schleck, K3FU http://www.novia.net/~pschleck/ Finger for PGP Public Key |
#8
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![]() "Paul W. Schleck" wrote in message ... In . com "an old friend" writes: [snip] Similarly, I wonder if invectives like "Macho Morsemen" are aimed at Kim and Dee Dee, also. Of course they are. Especially if one has not only passed the code but also had the audacity to get their Extra class ticket. And heaven help you if you actually USE Morse code. Dee D. Flint, N8UZE |
#9
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![]() Paul W. Schleck wrote: In . com "an old friend" writes: Dave Heil wrote: wrote: From: Carl R. Stevenson on Aug 30, 5:53 pm cut "...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. sometimes he does as is his right. I am sure he will even agree you have the right to snap and snarl at everyone who disgrees with you but you missed the point(s) as usaul Amoug them being Your snap at everyone, your right but not a good image. Len does reserve to right to snapp at folks too, event hose he shares goals with Len may have the "right" to do a lot of things, but if he truly wants to "win friends and influence people" in this debate, and leave a personal legacy other than that of a Usenet "kook," he might want to take stock again missing the point |
#10
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an Old friend wrote:
Paul W. Schleck wrote: In . com "an old friend" writes: Dave Heil wrote: wrote: From: Carl R. Stevenson on Aug 30, 5:53 pm cut "...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. sometimes he does as is his right. I am sure he will even agree you have the right to snap and snarl at everyone who disgrees with you but you missed the point(s) as usaul Amoug them being Your snap at everyone, your right but not a good image. Len does reserve to right to snapp at folks too, event hose he shares goals with Len may have the "right" to do a lot of things, but if he truly wants to "win friends and influence people" in this debate, and leave a personal legacy other than that of a Usenet "kook," he might want to take stock again missing the point I'm sorry that you missed the point. Perhaps it'll come to you after a re-reading. Dave K8MN |
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