In a message dated 10/2/2005 4:20:17 PM Eastern Standard Time, k8je@earthlink.net writes: Obviously some level of activity on the part of our General Counsel would be required to develop and submit these comments; however, this would be a rather perfunctory operation that could be managed nearly in total through a paralegal. I beg to differ with Jim only in his discussion of methodology. I would not normally utilize a paralegal or associate attorney for any portion of drafting ARRL comments in a rulemaking proceeding. We use a different process in most cases: Draft comments are prepared by me, or in the case of technical issues, by me and Paul Rinaldo; the draft is reviewed by Mr. Sumner and appropriate senior staff if applicable; then the ARRL President and appropriate Vice Presidents, and then they are submitted to the Executive Committee. Only rarely in the past has the Board dictated a different procedure. In the case of this docket, Mr. Harrison has been instrumental in the preparation of our Petition and in strategizing the advocacy effort. We used a team concept for the latter: Mr. Sumner, Mr. Haynie, Mr. Harrison and myself met to consider the advocacy effort, after the Board determined the substance of the filing. The Board's outstanding policy, of course, is for ARRL to urge the retention of the Morse telegraphy requirement for the Extra Class license only. 73, Chris W3KD