5 MAR, 2004 - 1445 CST EAN Thomas Collen, KG0AG 836 Hidden Lake Rd Roberts, MN 54023-8348 Dear Mr. Collen, Thank you for your comments on the ARRL's license restructuring proposal. I'm assuming you have read my latest Central Division Newsletter which outlines the board's rationale for this proposal. Therefore, I will try to not repeat myself too much here. Our proposal that you state was "cobbled together" was developed over the last six months of 2003 in response to the removal of the Morse code amateur radio licensing requirement at the World Radio Conference (WRC-03) last summer, the findings of two professional Readex surveys (2000 and 2003), and the FCC's statement in its last amateur license ruling that says something to the effect that further restructuring/streamlining of the Amateur Radio Service license structure is desirable. At the ARRL board meeting last July, the ARRL Executive Committee was tasked with drafting a license proposal for presentation at the January 2004 board meeting. The entire board spent one evening informally hashing through this proposal and then took the better part of an hour in formal session discussing amendments before finally voting to approve it. Our proposal was definitely not cobbled together. It's understood the FCC wants to see the number of license classes reduced, now that the Morse code treaty requirement has been removed. The ARRL proposal was crafted so as to not remove privileges from existing license classes (there are minor exceptions in the proposed Novice license) when they are merged. This would result in some people being given additional privileges without taking a test for them. Your proposal would generate a lot of clerical cost for the FCC, more than we envision in the ARRL proposal. It's my understanding the commission will not look favorably upon amateur radio licensing proposals that generate a great deal of maintenance cost. You may construe this as being a trivial issue and, in my mind, I agree with you. However, our perspective on how the FCC should spend it's funds, counts for very little in the commissioners' deliberations. It remains to be seen what the FCC will eventually approve. As you know, there have been several other petitions on various aspects of this issue filed. The board believes the commission will put most, if not all of them into one combined proceeding. Hopefully, this will happen within the next couple of months, but the FCC does not appear to be in a hurry. I see you have already filed comments in response to the NVEC's license petition, and I expect you will file similar comments on the ARRL petition, once it has been assigned a docket number. I expect to see several thousand comments filed on this combined proceeding. I also think we will not see any FCC ruling until late this year, at the earliest. And I will not take any bets on how it's going to turn out. :) You may, or may not receive replies from the other directors and officers as they usually wait to see what the director of the member's division has to say first. Again, thank you for your input and your long membership in the ARRL. 73 - George R. (Dick) Isely, W9GIG ARRL Central Division Director dick@pobox.com w9gig@arrl.org