I offer the following comments on your Amateur radio NPRM.
Consolidation to the 4 classes is good, a 5 WPM telegraphy
test would be best for General class.  Actually one test at 5 WPM
would be sufficient for classes General and above.  I would
like to see 5 WPM still be required for HF access, actually it
scares me if 5 WPM wasn't required.  I would also like to see
Novices and Tech pluses be made Generals as in the ARRL plan
to avoid any confusion, red tape and paper work on your part.
For new entry's to General and upgrades, element 2, 3A,3B and 5
WPM would suffice.  Thanks for reading.

73 Jim
WX2JIM