Ham Radio/Ham Radio CD-ROM (Emerald Software) (1995).ISO/news/yi890915/yi890915.txt

Text File | 1989-10-16 | 23KB | 855 lines

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 ::  T H E   W 5 Y I   R E P O R T  ::

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 ::      D i t s   &   B i t s      ::

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 ::      Vol 11 #18 --- 09/15/89    ::

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 ::    HamNet Electronic Edition    ::

 ::   CompuServe's  Ham/SWL Forum   ::

 ::                                 ::

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Up to the minute news from the worlds of amateur radio, personal

computing and emerging electronics.  While no guarantee is made,

information is from  sources we believe to be reliable.  May be

reproduced providing credit is given to The W5YI Report.



This HamNet Electronic Edition is a limited excerpt from the full

published edition of The W5YI Report.  Selected and prepared by

Scott, W3VS.



Commercial redistribution of this copy is prohibited.



IMPORTANT Note: Some of the material included in The W5YI Report -

Electronic Edition may not be suitable for transmission via Amateur

Radio.





In this issue:



-    ARRL Files for Code-Free Ham Class



HamNet thanks Fred Maia, W5YI, for permission to excerpt this

Electronic Edition of his W5YI Report.  The full ten-page biweekly

newsletter is available by mail for $23 per year from Fred at Dept.

C, PO Box 565101, Dallas, TX 75356-5101. Samples available for a 2

stamp large SASE.



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Do you have Amateur Radio news to contribute to The W5YI Report?  If

so,  please call [phone] and leave a message on Fred's

recorder!



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o ARRL Files for Code-Free Ham Class!

  ----------------------------------



"The League has carefully researched and evaluated this subject.  It

is not one which yet enjoys universal acceptance in the amateur radio

community.  It is, however, one which the League now supports as

beneficial to the future, short and long term, of the Amateur Radio

Service.  The only way the plan can fail is if the Amateur Service

rejects the Communicator class licensees as full-fledged members.

This the League firmly believes will not occur, as the Amateur

Service has a tradition of mutual assistance, and guidance of

newcomers by the more experienced members.  Newcomers will strengthen

the Service.  Once and for all, those who have a true interest in

becoming radio amateurs will have the opportunity to join, unfettered

by unfounded perceptions about entry barriers.  They will not only

have the opportunity to become amateurs, but will also have a more

favorable exposure to the benefits of having a personal, cognitive

communications skill, which is shared worldwide in the Amateur Radio

Service.  The learning of Morse code should be viewed more as an

opportunity than as a burden, or a hurdle over which they must jump."

(Excerpt from ARRL Petition for Rulemaking)



As expected, the American Radio Relay League submitted a Petition for

Rule Making to the Federal Communications Commission on August 31

seeking "Establishment of a Class of Amateur Radio Operator License

Not Requiring a Demonstration of Proficiency in the International

Morse Code."



The League proposed a new sixth class Communicator license offering

specific, limited privileges on amateur frequencies above 220 MHz.

There was no mention that these privileges would actually be above

222 MHz since the FCC reallocated 220-222 MHz to the Land Mobile

Service.



The filing came a little more than a month after League officials,

meeting at their July board meeting, voted to seek a ham class which

did not require knowledge of Morse code.  The vote was not

overwhelming in favor of a code-free ham class.  Nine directors were

in favor; six opposed.



The Board not only considered the views of its members but also the

recommendations of a special study committee which for months had

gathered information on the subject and rendered a comprehensive

report (See 4/15/89 W5YI Report).  That Committee was comprised of

representatives of the Amateur Radio industry, League elected

representatives and individual amateurs.  They reached four basic

conclusions:



(1.) there is a perception that the code proficiency element of the

amateur entry level examination is a significant barrier;



(2.) ...the code proficiency requirement does not act as an

appropriate filter to weed out undesirables;



(3.) ...there are many good reasons for maintaining code proficiency;



(4.) ...there is nothing antiquated or irrelevant about the code "but

this is a matter that some individuals must learn for themselves, in

order to appreciate the relevance."



The Board adopted a slightly more conservative proposal than the

Committee recommended.  The League said the changes reflected the

input received from the amateur community.  It appeared overall that

the attitude of amateurs was significantly more favorable toward a

codeless amateur license than in 1983.



The well researched and prepared petition was authored by League

attorney Chris Imlay, N3AKD, and comprises some 25 typewritten pages.

It also contained a very interesting history of the no-code ham

movement in the United States.



The Communicator Class



The ARRL maintains that the Communicator class ticket is not an

entry-level license in the same sense as the Novice class license.

Earning the new codeless license would require the applicant to pass

a written examination somewhat more comprehensive than the present

Technician class theory examination, including some questions

relating to Morse Code, but without a Morse receiving, sending or

recognition requirement.  The code questions would be on the

tradition and utility of the Morse code.



Three accredited volunteer examiners from the VEC System would

administer the examination, and upgrading to a Technician class of

license similarly would involve taking a five-word-per-minute code

examination similarly administered.  "The need for absolute security,

and the perception of the same, is critical not only to the success

of the program in fact, but also to its acceptance among present

licensed amateurs.  The amateur community must be convinced that the

new licensees obtain their licenses through a highly monitored,

publicly administered examination program, in order that it avoid and

be perceived to avoid, compromise.  The license carries with it

privileges not available to Novice licensees, and as such is properly

included in the VEC program."



"There should be an upgrade path from the Communicator class of

license to the present Technician license by way of a five-word-per-

minute Morse code examination element, administered through the

established Volunteer Examiner system>  The petition clearly states

that all Communicator and Novice licensees would have to be retested

under the VEC program at 5 WPM code before they could qualify for a

Technician ticket.



"No credit for element 1(A) shall be afforded those seeking a

Technician class operator license on or after the effective date of

the Communicator class operator license by virtue of the possession

of an unexpired license which incorporates that element."  It will be

interesting to see what Novice level and VEC System examiners think

of that proposal.



ARRL said Communicator applicants would be required to pass the

current 30 question Novice written test element 2 and a beefed up 30

question Technician element 3(A) written examination to obtain a

Communicator license.  The present element 3(A) contains 25

questions.  The additional five questions would be on:  Amateur

digital communications techniques (3 questions) and two questions on

the use and application of Morse code.



It is unclear if this would require increasing the nine examination

topics to eleven to insure their inclusion in written tests or

whether these questions could be added to the existing "operating

procedures" and/or "signals and emissions" subelements.  Specific

questions merely added to existing subelement pools need not be asked

in all examinations.



Communicator privileges would be all amateur frequencies and

authorized modes above 220 MHz, at a maximum output power of 250

watts.  "There is a perception that the VHF bands below 220 MHz are

overcrowded, or are otherwise inappropriate for Communicator use.

The League ascertained that there exists a great deal of acceptance

of a code-less amateur license if the privileges were limited, as

proposed, to frequencies above 220 MHz."



The ARRL also believes "...there should be a strong incentive (such

as the attainment of 2 meter privileges) for codeless licensees to

upgrade their license class."  A Communicator licensee may not be a

control operator of a repeater or auxiliary station.  With respect to

power levels, the League saw no need to permit the Communicator class

licensee to operate at greater than 250 watts PEP output, given the

frequency bands available.  "...greater power can be reserved for

higher-class licensees, so as to create the incentive to upgrade."



Call signs would be assigned from the Commission's Group D block; 2

prefix letters, one call sign region number and three suffix letters.

"This is most important, as the goal of a codeless amateur license is

to bring such licensees into the 'mainstream' of the Amateur Radio

Service, and to encourage them to upgrade their license class.  It is

thus important not to 'label' these licensees as distinct from other

entry-level amateurs, or to attach a stigma to the license class."



The League acknowledged that adding a sixth amateur class to an

already complex licensing structure adds somewhat to the burden of

the volunteer examiner program, which has thus far performed

extremely well.  ARRL directors asked their officers to examine the

amateur licensing structure as part of their long-range planning

effort.  Overall, it was determined that the advantages of

implementing a new license class now - outweighs the disadvantages,

taking into account the desire of many amateurs and prospective

amateurs to open this additional gateway to amateur radio.



No-Code Background



The ARRL said the current resurgence in the debate about the creation

of a codeless amateur license is interesting, given the fact that it

is a subject that has been repeatedly considered over a span of

years.



In 1974, in Docket 20282, the FCC considered the possibility of a

codeless amateur license which the League indicated it could support.

The "Basic Amateur" license class was to have included Novice theory

and a "code recognition" but not a code text copying requirement.

Five years later the FCC closed the matter without action stating

they required current amateur thinking on the issue in a separate

proceeding.



1978's Docket 78-250 proposed a new class of amateur operator license

without a Morse code proficiency requirement which would be

restricted to handicapped persons.  It too was dropped when

handicapped amateurs generally did not desire special treatment in

the substance of amateur examinations.  Rather, they merely asked

that examiners take into account their specific needs in procedural

aspects of examination administration.  The FCC adopted this position

and that policy continues to this day.  (See 97.509)



Prior to the 1979 World Administrative Radio Conference, Article 41

of the international radio regulations did not require Morse code

knowledge if the amateur operation was exclusively above 144 MHz.

The ARRL said the United States WARC-79 delegation disregarded the

recommendation of the FCC convened Advisory Committee for Amateur

Radio (ACAR) and other public comments which suggested no changes to

Article 41.



Surprisingly, the United States WARC delegation proposed to drop the

international requirement of Morse code proficiency for operation

below 144 MHz in favor of a 'recommendation' that the various

countries of the world have such a requirement.  The U.S. proposal

was defeated by the WARC conferees.  The ITU Radio Regulations were

ultimately changed, however, to require Morse code knowledge for

amateur operation on frequencies below 30 MHz, instead of 144 MHz.

Only the 50-54 MHz band was affected by the action.



The League said that event was received extremely negatively by the

amateur radio community at a time when the FCC was actively

considering a codeless amateur license in the United States.  "...it

is not surprising that there existed a strong distrust of the

Commission on the subject."



The early 1983 release of Docket 83-28 coincided with fiscal and

manpower problems at the FCC.  The Commission's examination system

"...was in great disrepute, and frankly in disarray," the ARRL said.

Even so, the FCC proposed on its own initiative two codeless license

alternatives: (1.) the elimination of the Morse code examination

element from the Novice class license or (2.) the creation of an

entirely new class of license involving a written examination aimed

primarily at digital communication techniques.



Without referring to Dick Bash/KL7IHP by name, the ARRL discussed the

negative aspects of "at least one firm" publishing study aids which

included the exact questions contained in the FCC license exams.  The

perception was, according to the League, that the Morse code test was

the only portion of the amateur radio examination that meant anything

at all.



To solve the written examination problem, the Congress, in 1982,

enacted Public Law 97-259 to allow the Commission to utilize

volunteer examiners in the Amateur Service.  The eventual result was

a question pool system from which examiners would draw certain

questions according to a formula to prepare their written

examinations.  To eliminate applicants from "shopping" for easier

examinations, the VEC's ultimately agreed among themselves that they

would all use exactly the same answers and multiple choice answer

formats verbatim.



The ARRL said the volunteer examiner system was not yet in place in

1983 and "...it was not clear whether a private sector examination

plan was feasible, much less sufficiently secure to prevent

cheating."  For this (and other) reasons, the amateur community thus

rejected the Commission's 1983 codeless license proposal by a ratio

of twenty to one.  The Commission terminated the proceeding without

action in December of 1983.



Novice Enhancement



The League maintains the "enhanced" Novice class privileges have been

a great success in terms of reducing attrition and encouraging

upgrading.  "What the increase in Novice privileges has not

accomplished, however, is to increase significantly the overall rate

of influx of new Novices in the Amateur Service.  The relatively flat

rate of increase in the number of new amateurs since the 1987 'Novice

Enhancement' proceeding once again has fueled the debate about a

codeless entry level amateur license.  There is a desire among

amateurs for growth in the Amateur Radio Service, and a desire to

reveal to more people the benefits and opportunities of the Service."



The ARRL acknowledged the perception that the Morse code requirement

is a barrier to amateur radio entry and creation of a codeless

license might attract newcomers.



Conclusion



The League believes "...provided that the Commission avoids the

mistakes of administrations which have enacted unsuccessful codeless

license classes, and follows the guidance of those which have enacted

successful ones, the creation of a codeless amateur license should be

successful here as well.  The key ingredients seem to be a

substantial written examination, significant incentives to upgrade,

provisions for including codeless licensees in the on-air activities

of other licensees and assimilating them into the mainstream of

amateur radio."



ARRL "respectfully requests that the Commission at an early date,

release a Notice of Proposed Rulemaking, proposing the creation of a

Communicator class amateur operator license..."



Now What Happens?



The ARRL no-code petition will be placed on official Public Notice -

probably this coming week, along with 11 other related petitions that

propose different types of no-code license or other changes in the

licensing structure or operator privileges or regulations.  (One

fellow wanted to change code speeds).



Each will be assigned "RM" (Rule Making) serial numbers.  These

numbers are issued out of the (FCC) Office of the Secretary.  The FCC

has just received some additional no-code petitions and these will be

considered to be comments on the existing petitions.



The Public Notice will begin a 30-day period during which time

interested persons may file comments telling the FCC why they think

any or all of the petitions should or should not proceed to the rule

making stage.  The idea here is to enable the FCC to determine

preliminary public reaction to the proposals.   If there is vehement

opposition the FCC could well decide that the proposal should not go

forward.  Similarly, if there are substantial expressions of support,

the FCC will know that there is merit to the idea and will likely

proceed.



Following this comment period there will be a short reply comment

period in which people on each side of the issues can answer the

points raised by their opponents.  After this exchange of views, the

FCC will decide whether to proceed to rule making.



It is important to note that if the petitions get RM numbers, it

means that the FCC has made the preliminary decision to go forward.

It has the power to dismiss the petitions out of hand and it will do

so if it does not wish to proceed.  So the assignment of an RM Number

in and of itself represents a first positive step toward a no-code

license.



The comments at the RM stage are NOT the place to get into a debate

about the particulars of the proposals.  The comments, either in

favor or in opposition, need only manifest the ultimate position of

the commenting person or group.



In other words, there will be time enough to argue about whether the

no-code license should include privileges at 2 meters.  The important

thing is to let the FCC know one's position on the ultimate issue:

whether you are in favor of some form of no-code license or not.



The preliminary round of comments at the RM stage is not just a

formality.  However, in view of the ARRL's filing, one has to believe

that the matter will proceed to rulemaking.  The ARRL does not file

trifling petitions.  Moreover, this matter is strictly internal to

amateur radio, and on such matters the FCC pays great deference to

the desires of the League.  So if the ARRL wants a no-code license,

it is likely to get it.



The Commission staff is supposed to take preliminary comments into

account when deciding whether to grant the Notice of Proposed

Rulemaking (NPRM) desired by the petitioner.  Many petitions never

receive RM numbers because they are judged to be repetitive,

frivolous or otherwise not deserving of serious consideration.  Most,

but not all, of the petitions that do receive RM numbers will

eventually make it to the NPRM stage.



The FCC's Personal Radio Branch has a small staff and budget for the

large amount of work they have to do in researching petitions,

drafting rules, working on enforcement cases, monitoring the VEC

program, ...and the like.



For this reason, Branch Chief John Johnston/W3BE told us informally

that he thought amateurs ought to hold their comments until the NPRM

stage:  "We're not really looking for comments on these items.  It

would just slow things down to throw in comments at this phase.  It

would be better to wait until a NPRM to file comments.  We still have

a pile of other petitions to work on, some that people have been

waiting a long time for.  While we were working on the Part 97

rewrite, the hams kept on thinking of things to do."



Following the preliminary round of comments, the FCC will decide

whether to proceed.  The next thing that will come out will be either

a Memorandum Opinion and Order, killing the proceeding (once the RM

number is assigned, the FCC can no longer dismiss it out of hand; it

must explain why it changed its mind); or a Notice of Proposed Rule

Making (NPRM).



if the FCC issues the NPRM, it will represent the FCC's first cut at

what the no-code rules and privileges look like.  (The Commission

could also issue a Notice of Inquiry which seeks more information,

but this path of action is extremely doubtful).



The NPRM will be a distillation of all of the suggestions contained

in the various petitions, plus anything useful that might have been

said in comments.  This is where the heavy analysis comes in.  This

is where the particulars are hammered out: what bands; what

privileges; ...what testing requirements.  We expect a Notice of

Proposed Rulemaking will consolidate some or all of the petitions

within the next six months - although it could happen by Christmas.

In other words, the FCC will not release 12 different no-code NPRM's.

Instead, a single no-code NPRM will emerge, possibly accompanied by

NPRMs dealing with rules other than the Morse code requirement.  This

scenario is only speculation on our part.  FCC staff are keeping

their plans confidential.



In any event, don't expect fast final action by the Commission.  Rule

making takes time.  Even if this matter is put on a fast track for

decision, a no-code license is probably still a year off.



[End this issue]