How to File comments in response to FCC Notices of Proposed Rule Making (NPRM) actions

First step:  Read this entire message, then come back to the top and follow the procedure you think best suits your needs.

Start:

Brief instructions on how to file comments on a petition pending before the FCC. 

Let's assume you wanted to file comments on one of the petitions regarding dropping the Morse Code testing requirement, in this case the petition filed by the National Council of Volunteer Examiner Coordinators (NCVEC) has been assigned RM-10787 as it's "proceeding number". (there are 5 other petitions on file on this same general subject)

First, start at the FCC's  Electronic Comment Filing System  (EFCS) home page. 

here is the URL:

http://www.fcc.gov/cgb/ecfs/

Then, select "Submit a Filing" , which is the 2nd item down on the menu under  "EFCS Main Links"  in the upper right corner of the EFCS main page.   Click on "Submit a Filing"

This will take you to the electronic comment filing page.  Or, you may go directly there by clicking on the following link:

http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi

Once there,  fill in the form.   The most important thing to do is to enter the proceeding number you are commenting on. 

In the case of the NCVEC filing for eliminating Morse Code testing, the proceeding number is:       RM-10787 

You must type the number in exactly as shown, with the RM in upper case, and include the hyphen.  You can cut and paste from this message if you wish. 

Next, fill in the appropriate blank areas. 

Note that some of the fields are optional and some are required.  Use your name for the "Name of Petitioner".  If a data field is already filled with "default" information, take that choice.

You may fill in the "optional" information fields, but that is not necessary.  However, I recommend that you fill in the "e-mail ID" field, so they can send you a confirmation number that shows your comment was received and entered into the system, and also so they can communicate with you if there is a problem with entering your comment. .

Next, move down the page and note that there are two areas for comment filings:  The first, with a blue border,  is  for use if you are attaching a Word document , such as the sample file I have attached to this email.  This becomes an official comment.  Type in the complete file and path name for your attachment (or use the "browse" button to find it), and attached it to your message.  Be sure  "COMMENT" is selected as the description, and choose a file type that is compatible with what you have prepared.  You MUST use one of the listed file types.  If your document is not in one of the acceptable formats, you must convert it before continuing.

To use the file I have attached, open it with MS Word, edit it appropriately, including changing the name and address from mine to yours, and attach the edited document to your comment filing.

Alternatively, if you are not attaching a previously prepared document, then you can move a bit farther down the page until you see the are with the green border.  This is where you can type in comments directly, and these become known as "brief comments".

When you have finished typing in your information, and/or attaching any documents, then click on "Send attached file to FCC"  or "Send brief comment ot FCC"  button, as appropriate.  Select only one of these choices. 

A new screen should appear, with a confirmation number that indicates that your comment has been received and filed.

If  you want to view previously filed comments without making one of your own, then chose the URL below:

http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi

Enter   RM-10787 in the "Proceeding" field, and press "enter" .  Again, the proceeding number must be entered exactly as shown here.  If you are interested in a different proceeding, use that  number instead of RM-10787. 

The system will begin displaying filed comments in groups of 10 or 20.  To view a comment, select the "COMMENT", or "brief comment" link in the lower left corner of each comment descriptor block, and an Adobe Acrobat view of that comment will appear.  (You must have Acrobat Reader on our system to view comments).  Use the "forward" and "back" arrow keys on your browser to navigate, and select the group of comments  from the list at the bottom.  Note: It is much more efficient to view comments in small groups instead of loading the whole set at once.

The initial petition will appear as the highest numbered comment.  In other words, if there are 300 comments on file, the initial petition itself will be comment number 300.  And, instead of "COMMENT" of "brief comment", it will say "View".  Click on "View" to see the original petition as filed.

Deadline for comments on petition RM-10787 is September 29 - if you are intending to file a comment, do it now!

Finally, many of you already know his, but I was one of the four people selected by the NCVEC to draft the original petition, which was sent in under the signature of Fred Maia, W5YI.  Fred was chairman of our committee, and was included because of his experience and knowledge in making previous filings before the FCC, and his grasp of "legalese".  The other members were Scott Neustadter, W4WW, who heads the question pool committee, John Johnstone, W3BE, a retired FCC type who wrote the original FCC Part 97 rules, and myself.  I was chosen partly to replace Bart Jahnke, W9JJ, who runs the ARRL VEC, and declined to serve because of possible conflict, the league not having developed their official position on the matter, and partly because of my involvement in the Alaska Remote Testing Project.  Somehow in this process, I also got myself elected vice-chairman of NCVEC - so if you have something to say to them, send it to me and I will see it gets to the right place.

If you would like more background about why the petition was filed, let me know and I will be glad to send you a document that outlines our thinking in detail, and how we got there.   I would particularly recommend looking at this information if you are unsure whether or not to support this idea.   The document will also outline some of the next steps we intend to pursue.

73 -

- Jim, KL7CC