[Fists] FISTS petition filed with the FCC

[Nancy WZ8C]

Hi FISTS,

On their web page, http://www.arrl.org/news/stories/2003/08/29/2/?nc=1 the
ARRL says "Let the games begin!" when refering to the no-code petitions
filed with the FCC. Well, now the games can REALLY begin, because today I
express-mailed a pro-code Petition for Rulemaking to the FCC on behalf of
FISTS CW Club. They should receive it Tuesday morning, and will hopefully
put it up for comments soon. You can view it now at the ftp site provided by
David Ring N1EA ftp://ftp.qsl.net/pub/n1ea/FIST_FCC_Petition_8-30-303.pdf.
It will be up on the FISTS web site soon, as well in the next Keynote.  It's
14 pages long, so I didn't include it in the text here.

It is important to note that the FCC has put the anti-code petitions up FOR
COMMENTS ONLY. They have not been assigned an NRPM number.  This is an
edited cut and paste from the FCC web page explaining the process:

*Petition for Rulemaking
The Commission regularly issues a news release listing the Filings accepted
by the FCC. The public has 30 days to submit comments, or as directed in the
notice. This is an opportunity to state reasons why a Petition for
Rulemaking should be granted or denied.

*Notice of Inquiry or Notice of Proposed Rulemaking
After reviewing the comments received in response to a Petition for
Rulemaking, the FCC will typically issue either an Order disposing of the
petition, a Notice of Inquiry (NOI), or a Notice of Proposed Rulemaking
(NPRM).

*Further Notice of Proposed Rulemaking
After reviewing the comments received in response to a Notice of Proposed
Rulemaking, and in conjunction with or in lieu of a Report and Order
explaining the FCC's actions on the proposed rule changes, the FCC may issue
a Further Notice of Proposed Rulemaking regarding issues raised in comments
or to provide an opportunity for the public to comment further on a related
alternative proposal.

*Report and Order
After considering comments and reply comments, the FCC may issue a Report
and Order amending the rules or make a decision not to do so. The FCC may
issue additional Report and Orders in the Docket if there is an outstanding
issue to be resolved at a later date, or if there are additional rulemaking
proposals in the Docket.

*Petition for Reconsideration
After the FCC issues a Report and Order, interested parties generally have
30 days to file a Petition for Reconsideration to request that the FCC
reconsider its decision.

*Memorandum Opinion and Order
A Memorandum Opinion and Order is issued by the Commission to deny a
petition for rulemaking, modify a decision, grant or deny a petition for
reconsideration, or grant or deny an application for review of a decision. A
second or third Memorandum Opinion and Order may be issued (2nd MO&O, 3rd
MO&O).
_______
end cut and paste from the FCC web site

So, you can see, we have a long road ahead of us!

Here is a cut and paset from the FCC page about how to file a comment:

*Docket or Rulemaking Number
Whether you are filing your comment in paper or electronic format, it is
critical to include the Docket Number or Rulemaking Number of the item at
hand in your comments.This number is important because it ensures that your
comments will be associated with the correct FCC proceeding. (NANCY's NOTE:
The docket numbers for the anti-code petitions are RM-10781, RM-10782,
RM-10783, RM-10784, RM-10785, RM-10786)

*Content
Your comments should state who you are and what your specific interest is.
You do not need to represent yourself in an official capacity. You may, for
example, express your opinion as a concerned consumer, concerned parent,
etc. and sign your name. State your position and the facts directly, as
thoroughly but as briefly as possible. Explain your position as it relates
to your experience and be explicit. Make clear if the details of a proposed
rule or only one of several provisions of the rule are objectionable. If the
rule would be acceptable with certain safeguards, explain them and why they
are necessary.

 *Support
Statements of agreement or dissent in comments should be supported to the
best extent possible by factual (studies, statistics, etc.), logical, and/or
legal information. Support should illustrate why your position is in the
public interest. The more support made, the more persuasive the comments
will be.

*Length
Comments may be any length, although it is preferred that they be succinct
and direct. If comments are longer than 10 pages, a summary sheet is
required.

*Filing
You may submit comments to the FCC in paper or as an electronic file via the
Internet.

Mail Your Comments The address to mail your comments to is:
Ms. Marlene Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Room TW-B204
Washington, DC 20554

E-Mail Your Comments
E-mail your comments by following the E-mailing Filing Procedures. For
assistance in sending your comments by e-mail call (202) 418-0193, Monday
through Friday, 8:30AM - 4: 30PM ET.

Submit Your Comments via the Electronic Comment Filing System
The Electronic Comment Filing System (ECFS) is designed to give the public
access to FCC rulemakings and docketed proceedings by accepting comments via
the Internet. For assistance in using ECFS, please send an e-mail to
ecfshelp@fcc.gov or call (202) 418-0193. The ECFS Help Line is available
live, Monday through Friday, 8:30AM - 4:30PM ET
_______________
End cut and paste

To read the no-code petitions, its easiest to go to the ARRL web page
http://www.arrl.org/news/stories/2003/08/29/2/?nc=1 and click on the links
from that page.

To E-file comments, go to the FCC page http://www.fcc.gov/cgb/ecfs/ . On the
right side is a Main Menu for filing comments. Click on the 2nd one down,
"SUBMIT A FILING" . Type in the RM- numbers where it says "PROCEEDING". (The
docket numbers for the
anti-code petitions are RM-10781, RM-10782, RM-10783, RM-10784, RM-10785,
RM-10786) Type in your name and contact info, then scroll down and make your
comments. And that's all there is to it!

We are going to need EVERYONE's support to win this, so check it out,
formulate your thoughts and then file your comments on the no-code
petitions. You can see what others have written by clicking on the "SEARCH
FOR FILED COMMENTS" (on the right side of the screen) on the main E-filing
page http://www.fcc.gov/cgb/ecfs/.

I'm sorry this email is so lengthy, but I wanted to be as thorough as
possible to eliminate confusion. I know dealing with all this red tape can
be intimidating. Let me know if you have any questions, and I'll try to do
what I can to help.  Please write to me at nancy@tir.com -- DO NOT HIT YOUR
REPLY BUTTON AND REPLY TO THIS EMAIL. It is an automated address and I may
not see it.

I realize the Petition I filed won't please everyone, but I hope most of you
agree with most of it. It was written from the comments received on the blue
post cards. Many thanks to all who gave their input, suggestions and
expertise.

73
Nancy WZ8C
ftp://ftp.qsl.net/pub/n1ea/FIST_FCC_Petition_8-30-303.pdf