Jim, obviously, I misunderstood your questions, and I apologize. Let me try again. Based upon my limited experience, I’d think some paralegal effort plus minimal supervision by you would result n a healthy filing. If we were to support this filing via a push on FCC by our members (use our grassroots program to do this), we could generate substantial, controlled pressure. I think this that in general we ought to pursue this basic plan. It is probably not going to succeed, but I think we need to pursue it for our many members on whom we in turn rely for support. This ought to leave us with something on the order of 99 44/100s percent effort for the new license project. I am certainly not short on argument in favor of retaining Morse, but the argument is not, at this point, a matter of law, but rather a matter of proper policy. If the Board wants to make an effort to keep Morse testing for the Extra Class license, I will promise you a first class argument. I don't see it succeeding, but as you say, often the right thing to do is not necessarily the one most likely of success. MY QUESTION ABOUT AVAILABLE FINAGLE ROOM What I’m wondering is just how far (from a legal position) we might be able to get in moving towards the goal of a new entry license but while still working under FCC’s current regs and interpretations. For example, how much latitude do we (the Amateur Radio Community) have in developing question pools for the entry level license at time. Bluntly asked, if we were able to pull the NCVEC forces together behind us (or get all of us to join together for a common goal), could we write and expect FCC to accept a license pool of the type we think it ought to be? There are two issues, Jim, well, actually three, in considering an entry level license class. One is whether or not there will be a separate entry level license from the current technician. It is quite apparent that the FCC's mindset is to not create a new entry level license class. Can we force them to as a matter of law? Of course not. It is a matter of persuading them that it is the right thing to do. Their NPRM says that they are not proposing to create a new entry level license. So, assuming that there will not be a new entry level license, the question becomes what has to be done to the Technician Class license to make it more appealing to newcomers and more conducive to keeping newcomers once they get a Tech license. As we have argued, the Technician Class license has two fundamental flaws, and we can, I think, demonstrate this empirically. First, the examination is overly comprehensive, and needs to be made less so. That is ENTIRELY within the VECs authority. If NCVEC is unwilling to work with us to make that happen, we can create our own question pool, as each VEC is authorized to do (though FCC does "expect" that there will be a single question pool for each examination element, it is not mandatory by any rule or statutory requirement). So, yes, the exam can be "fixed" without any FCC involvement at all. The question pools are no longer blessed by FCC or subject to their criticism. They are out of the picture on that entirely. The second problem with the Technician Class license is the privileges. That FCC has to fix itself, of course, and that, I think, is where we should focus our efforts in the comments in this docket proceeding. Absent a victory on the overall question of a new entry level license, to what degree theoretically is the NCVEC at liberty to mold the current Tech license format toward that we believe would best serve Amateur Radio. They are 100 percent at liberty to "mold" the question pools and the examinations. They can't affect anything else about the Tech license, of course. Can he NCVEC unilaterally change the Tech question pool to become one essentially that would mimic a “new Novice” pool? If NCVEC has this latitude, following this tactic just might be useful if all else fails. Yes. 73, Chris W3KD