It is gratifying that we were told by telephone, in a call initiated by FCC Mobility Division staff, what would be in this Report and Order a week or two prior to its release, and that in fact the R&O says what we were told it would say. Best of all, however, we got what we wanted in terms of preserving the 3-examiner rule and in other respects. I think the reason that we were given the accommodation of a head's-up by the Mobility Division staff this time (a unique experience in the last decade and a half or so) is twofold: (1) Dave and I made a very specific, targeted, in-person ex parte presentation to the Mobility Division staff early on in the process after our comments were filed, and we engaged the staff; and (2) we made the same arguments in our in-person meeting with Roger Sherman, the new Wireless Bureau Chief, about this docket, in the presence of the same Mobility Division staff. The lesson from this, I think, is that on Part 97 issues, the key is to get in their faces early on, where there is a policy issue in dispute not involving spectrum. 73, Chris W3KD Christopher D. Imlay Booth, Freret & Imlay, LLC 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ, K1ZZ <dsumner@arrl.org> To: arrl-odv <arrl-odv@arrl.org> Sent: Tue, Jun 10, 2014 12:08 pm Subject: [arrl-odv:22819] Re: Exam system (and other topics) Report and Order I have now had the chance to review the R&O. To give credit where it is due, it’s pretty well done and well balanced. Here are the main points: 1. Holders of expired General, Advanced, and Extra licenses, and of Technician licenses issued before March 21, 1987, who pass the current Element 2 (Technician) examination will be given credit for additional examination elements as follows: Extra, Elements 3 and 4; all others, Element 3. Credit will not be given on the basis of an expired CSCE, which was our main concern because of the opportunity for fraud. 2. The FCC dropped its own idea, which we strongly opposed, to reduce the required number of VEs from three to two. 3. Remote testing will be allowed, without the mechanics of how remote testing is to be conducted being spelled out in the rules. “VECs may coordinate sessions only if they are certain that remote testing can assure the proper conduct and necessary supervision of the examination session….we emphasize that the obligation under our rules of VECs and VEs to administer examinations responsibly applies in full to remote testing. In the event that their remote administration compromises the examination process, VECs can decertify VEs and we can terminate our agreements with VECs.” 4. Our request for a rules change to permit single slot TDMA technology was strongly supported in the comments and has been granted. 5. The Commission has taken the opportunity to make a few editorial corrections, none of them substantive. In short, I see nothing in the R&O that should give us any heartburn. The rules changes take effect 30 days after publication in the Federal Register. 73, Dave Sumner, K1ZZ Chief Executive Officer _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org http://reflector.arrl.org/mailman/listinfo/arrl-odv