In the comments, CQ generally supported the concept for former licensees as well as those amateurs who gained partial credit for an upgrade but did not complete the upgrade within the one-year "window" granted by a Certificate of Successful Completion of Examination (CSCE) [for example, a pre-2000 Advanced Class licensee who had passed the Extra Class theory exam but not the 20 word-per-minute code test].
CQ disagreed with the proposal to shorten or eliminate the current two-year grace period for license renewal, primarily to protect a licensee from losing his or her call sign due to missed paperwork. CQ also disagreed with the proposal to reduce the minimum number of Volunteer Examiners at a test session from three to two, and recommended that the FCC initiate a pilot program on remote exam administration before making a final decision on that part of the proposal.
Finally, CQ supported the proposal to permit the use of single-slot TDMA (time domain multiple access) on the amateur bands, but called on the FCC to re-initiate a dialog with the amateur community on broader changes in mode regulation in order to remove the necessity of going through the rule-making process whenever a new operating mode is introduced.
The full text of CQ's comments, along with others received by the FCC in this proceeding, may be accessed through the FCC's Electronic Comment Filing System (ECFS) at <http://bit.ly/Ty6Qdh>. Enter 12-283 under "Proceeding Number," then scroll down and click on "Search for Comments." The deadline for filing comments is December 24, 2012, with reply comments accepted through January 22, 2013.