[arrl-odv:24817] Historical LIcense Data in the ULS; Docket No. 15.81; Supplemental Ex Parte Comments filed.

Greetings. FCC asked us recently to file a supplement to our comments (filed last June) in the above FCC docket. FCC was interested in a quantification of the number of people who are taking advantage of the lifetime exam credit for former license holders that went into effect last July. We had argued in our June comments in this docket that it was unfair of FCC to impose the burden of validation of claimed former license holder exam credit, and then turn around a scant year later and propose in this proceeding to eliminate the means by which the VECs do that validation. Scot Stone at FCC asked for this. They want to get a handle on the volume of the validations that need to be done. It is not insubstantial. Thanks to the Executive Committee for a fast approval of this short filing, and especially thanks to Maria Somma for good quick work assembling the data for this. Maria also consulted with the W5YI VEC which concurred with her points and authorities so we have high confidence in this filing and we have in effect the support of the two VECs which together account for an overwhelming majority of the VEC workload. Let me know if you have any questions about this. It is entirely consistent with our June comments. 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
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Christopher Imlay