[arrl-odv:20141] WT Docket 11-130, Temporary Waiver to Allow Examination Credit for Expired Amateur Operator Licenses

Greetings. Attached are as-filed comments, both in Word 07 and PDF, in response to the Anchorage VEC's proposal for a temporary waiver, pending Commission action on its rulemaking petition, RM-11629, to allow VECs to afford examination element credit to those individuals who once held an Amateur Radio license but who allowed that license to expire beyond the two-year grace period. It is critical to note, as you will when you read these comments, that they carefully preserve the Board's prerogative to support RM-11629, which requests rule changes to permanently afford such exam credit, should the Board wish to take a supportive position on that petition. These comments urge, however, that the grant of a temporary waiver to afford such element credit and relicensing is a bad idea, because, principally, it prejudges the outcome of the Petition, making favorable action on the Petition a fait accompli. There are many other reasons why the waiver should not be granted, but that is the principal one. I think these are well-formulated comments, thanks to the entire Executive Committee, but especially to President Craigie who strategized this filing and actively participated in the edits of it. Thanks too to Dave Sumner and EC members Tom Frenaye, Bob Vallio, and Dick Isely for helpful edits. Good team effort by the EC. 73, Chris W3KD P.S. I am leaving today for vacation in the U.K. and will be back on the 22nd, and following a short trip thereafter to Arizona for a client, I will be back in the office after the 25th. I will allegedly have e-mail capability while in the U.K. We will see.... Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG
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Chris Imlay