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Re: [RFI] LED Bulbs

To: <rfi@contesting.com>
Subject: Re: [RFI] LED Bulbs
From: "Paul Christensen" <w9ac@arrl.net>
Date: Wed, 12 Feb 2014 13:22:09 -0500
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
I think the bottom line is that the FCC is under funded and under staffed and we amateurs are a low priority. Maybe a concerted letter writing to our congressional representatives is in order.

The funding and the staffing is there. Who among us has looked at the Commission's budget and analyzed every aspect of it? It's takes strong leadership to recognize a significant problem and bring about change.

When I hear these underfuding/over-worked arguments, I'm reminded of the movie "Dave," where Kevin Kline plays the part of our President. To deal with a myriad of complex budgetary issues, he enlists the assistance of his CPA friend. Together, over a couple days, they have whittled away at huge chunks of unnecessary spending in the federal budget.

I have no doubt that Commission funding is adequate. Don't be all-to-quick to give in to that red herring. What's needed is budget accountability and that includes a re-allocation of funding and a re-balancing of human resources and priorities.

In addition to these changes, global federal changes are needed in the FERS/CSRS retirement system to reign-in agency costs. Why in 2014, are we still allowing federal workers to retire at the age of 55 when the Department of HHS's computed life span for men and women now averages 82 years of age? My father in-law retired under CSRS at 55. He's now 86. Last year marked the beginning of the period where the U.S. Government has paid him more in time -- and substantially more in dollars than during the 30 year period in which he worked for a federal agency. In total, we have now paid out $1.8 million to just one person -- for not working and the lion's share of that retirement contribution has come from U.S. tax payers. Let's further move toward a system where the retirement age for Congress and federal workers moves lock-step with Social Security, regardless of years of service.

Just how much funding does it take to amend 47 CFR 15.103(d), for example? The Commission has always had the power to invoke a Petition for Rulemaking on its own motion. Yet, despite attempts by prominent organizations like the the NAB and affluent AM Broadcast group owners, the Commission (via Congress) has yielded to the concerns of manufacturers who produce EMI/RFI generating appliances. We need to severely limit Congressional influence by large organizations, enforce the laws already codified, and strengthen what's already there -- even if that means a Constitutional Amendment.

I'm not naïve in making an oversimplification of the problem. I know change isn’t easy when it's human nature to leave the status quo and cave in to pressure, especially when your livelihood depends on it.

Paul, W9AC

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