In your proposal, you
cleans up the licensure
Bravo!
However, you have not

have suggested establishing a system that
catagories,  into a simplified grouping system.

proposed any changes to the CW proficiency level

requirements...!  Most interesting position to take....
initially.
In that the International minimal requirement and the only
requirement

on CW proficency speeds that are in existance in their rules, is
only 5 wpm,
then perhaps, when establishing a CW proficency level for a
minimal
level license, now proposed as GENERAL, you might consider the
issue of
consistency, and re-propose the level to be consistent with the
International
level of 5 wpm, particularly in light of the issue of
reciprocity..

Additionally, if you use the wording in your regulations to
reflect that
the code level of HF proficency to be the same as "xxxx" (the
International
rule - currently at 5 wpm) then,  IF the International standard
changes,
you do not need to revisit this issue,  as the proficiency level
will
automatically be changed to "0".  This is the KISS theory... Keep
It Simple,
Stupid...

As for the rationale for a potential future level of "O",
remember that
it has already been determined that the "Public Safety" does not
require the
use of CW/Morse Code proficency on navigatable waters or seas
when the
USCG et al dropped the requirement for Morse Code Proficiency for
such -
Interstate
AND  International vessels.  If there is no need on the
navigatable rivers in
the various states of the Union, and on the High Seas, outside of
the
territorieal waters of the States and Territories, where is the
justification
for a different standard on an Interstate Highway.
Additionally, there is currently no statutory requirement for a
license to
be used when communicating within the several States by state
Citizens for
communication of a non-commercial nature,  between other state
Citizen of
any of the several States.
Thus, it might be propitious to claim the international standard
as the ONLY
level required for ALL HF communications,  due to the
requirements of
International
Treaty.  Again,  when the Treaty is amended,  so will your
proficiency
levels....   KISS!

Keep up the good work,
John Rauch

NIYXS, PG(l)-7-10223