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Maybe clarify the posts b/w John and Michael (then again, I could be
completely wrong!)-
The precession is the rotation of one vector about another.
The precession
of the Earth's spin axis is typically considered to be the rotation of that
angular momentum vector (associated with the Earth's spin) about a vector
perpendicular to the ecliptic (defined by the Earth's orbit) - the Earth's
orbital angular momentum vector
To talk about the precession of the orbital plane, you would have to have a
second reference vector
The angle between the ecliptic and spin axis does not change
(significantly).
The angle between a plane and a vector always causes
problems IMHO,