Your proposal leaves thousands of technician plus class licensees
in limbo. The way I read the proposal it appears that current
technician plus will lose the HF privileges they have earned
unless they upgrade to general class requiring a 13 WPM code
test.  If one of the objectives is to reduce the burden on VECs,
imagine all those technician plus licensees scrambling to pass a
13 WPM code exam to retain their HF allocation with the coming
sunspot cycle.  It would be a VEC nightmare.  At the very least,
the General class code speed requirement should be reduced to 5
WPM which would eliminate the need to test the current technician
plus license for telegraphy.

The proposal also contradicts itself where in one place
(paragraph 20) you acknowledge the relative unimportance of
telegraphy skills in recent years, but the proposed changes
require a higher code speed(13 WPM)for entry level onto
the HF bands since one must hold a General class license under
this proposal to gain any HF privileges!

The obvious solution is as follows.

(1.) Eliminate the Novice license.
(2.) Keep the Technician (no code) license.
(3.) Reduce the code speed requirement for all other licenses to
5 WPM.
(4.) Add questions concerning the digital modes on the written
exams.

If the above changes are made you will accomplish your objectives
of reducing the burdens on both the FCC and the VECs.