This is a response to the paper "Amateur Radio in the 21st Century", prepared
by Jim Wiley, KL7CC, with assistance from other members of NCVEC working on
changes to the US Amateur rules. This response is intended to evaluate and
constructively comment on the merits of the various ideas and changes presented
in the paper, regardless of their source.

For purposes of clarity and brevity, the introductions and executive summaries
are not reproduced here.

"Part One" dealt with the code test. "Part Two" and "Part Three" deal with the
proposed "Communicator" license.

Since the style of the paper is conversational, I inserted my comments into the
original paper in the same style, so that the paper reads like a conversation
between KL7CC and myself. My comments are preceded with "N2EY". The main text
of the original paper is preceded by "KL7CC".

Here is my response to "Amateur Radio In the 21st Century" (Part Two)

KL7CC: OK, what about that new license class - why in the heck are we even
thinking about it at all?

Let me give you a chill. Think, seriously, for a moment what this means: For
every ham under the age of 20 we are attracting, 2 (or more) hams over the age
of 50 either die or leave the hobby. Hmmmmm. It shouldn't take a genius to
see where that is going. In 10 years, we may not even have ham radio. Wait!
Wait!, you say, I'm only 45 (or whatever age you are), and I'll be around
longer than that. Great - but there might very well be no ham radio.

N2EY: Where do these statistics come from? The total number of licensed hams
has been growing since the late 1960s. Right now the FCC license data base
shows well over 680,000 US hams. When I started out in 1967 there were only
about 250,000 US hams. How many do we need to make amateur radio viable?

What about the age group from 20 to 50? Are we not getting any new amateurs
from that age group?

The total number of US hams is at or near an all-time high. How many is
"enough"?

KL7CC: Why? You think I'm kidding, right? What is the fastest growing sector
of our economy today? The answer is Information Technology (IT). And what
does IT need to succeed and grow? Interconnection, that's what. And
increasingly, wireless interconnection. And what does wireless interconnection
need? Spectrum. Radio spectrum -- Lots of it. And who has lots of spectrum,
most of it unused? Go to your bathroom and look in the mirror. That's who.
Now, what happens to that spectrum when (not if) you become a silent key - and
there is no one to take your place?

N2EY: And what spectrum do the IT folks want? VHF/UHF/microwaves - and all of
the amateur bands in that part of the spectrum have been wide open without any
code test requirement for more than 12 years.

All of this discussion is about access to amateur HF/MF, not VHF/UHF. The IT
folks want, and are getting, more VHF/UHF space.

KL7CC: What happens when there are so few hams that we become insignificant?
What happens when there are so few hams that manufacturers can no longer afford
to amortize the engineering costs needed to bring you a new radio?

N2EY: I repeat - the number of US hams is at or near an all-time high. Over
680,000 - that's triple what it was in the late 1950s. There is a wider variety
of amateur gear available today than ever before, and in inflation-adjusted
dollars it's far less expensive than in the past.

KL7CC: Oh, pardon me - you always build everything from scratch?

N2EY: Yes - or from kits, or I restore older gear. Is that a bad thing? Am I
somehow a problem because I don't buy my rigs from Japanese manufacturers?

KL7CC: Great! Who, exactly, are you going to talk to?

N2EY: Other hams, same as I have done for decades.

KL7CC: Most of the rest of us opt for the practical approach, and purchase a
rig from one of the several companies that cater to hams. If there are no
manufacturers, then there are no new rigs. Hard to carry on a QSO if no one is
there.

N2EY: "Practical approach"? You mean you think amateurs can't build their own
equipment anymore? If that's true, how can we hams possibly justify our
existence as a "fundamentally technical service"?

KL7CC: One of the primary goals of the new license we are going to propose is a
true entry-level ticket. Limited power, limited frequencies, but still useful,
with enough of the essence of Amateur Radio to attract beginners and show them
what lies ahead when they upgrade. Simpler exam. WAIT! - - WAIT! - - WHAT WAS
THAT??!!

Yes, I said simpler exam. Hopefully 20 questions. Aimed at a young person
aged 12 or more. That means a 6th grade education. Also fits teens, high
schoolers, home schoolers. You know, fresh ideas, new blood, people that can
actually see their radios without having to put on glasses - what a concept!
20 questions, simple enough to get someone started in a responsible way,
pointed in the right direction, all that stuff.

That sure sounds like "dumbing down", doesn't it? Keep reading.

N2EY: It doesn't sound like "dumbing down" at all. It sounds exactly like the
old Novice license concept. An entry level license with limited privileges
that's easy to get. So far so good.

The current and previous license tests have been passed by young children. I
know of a six-year-old who passed the General and an eight-year-old who passed
the Extra - the OLD extra, with 5 written tests and 20 wpm code. Granted, these
were very bright young people. But their example makes it a bit harder to
accept the idea that the current 35 question Technician test is above the level
of a 12 year old's ability.

KL7CC: Here is what we are thinking, and some of the rationale behind it. We,
however, don't have all the good ideas, in fact we may not even have most of
them, so input from others is welcome. Make that rational input. Invective
and obviously impractical stuff will get filed immediately in 13.

First consideration: Lower power. 2 reasons. First, everyone at the recent
NCVEC meeting expressed concern about letting brand new hams loose with 1500
watts of VHF or UHF. That's dangerous, no doubt about it. Cook your
neighbor's cat type stuff. Not funny. So, we are thinking about a license
that allows enough power to be useful, but not enough to be unsafe. It turns
out that 50 watts above 24 MHz and 100 watts below 24 MHz allows hams to
operate without having to worry about RF safety issues or evaluations.
Transmitters at those power levels are presumed safe. If there are no RF
safety issues, then there is no need to ask questions about those issues, and
we can have a smaller exam. Second, those power levels represent the vast
majority of commercially manufactured (or kit) radios offered for sale. The
100-watt HF set is everywhere, and very few VHF/UHF mobiles exceed 50 watts.
Yes, some sets run more power, but the overwhelming majority meet the 100W HF /
50W VHF standard.

N2EY: OK, fine - and most amateurs don't run much more power than that, anyway.
Staying under the RF exposure evaluation limit takes a lot of questions out of
the pool.

KL7CC: Another idea: Restrict radios (for this license class only) to a maximum
of 30 Volts on the final stage. Why? 30 volts is the generally accepted point
that defines the split between low and high voltage. Virtually all-solid
state sets use less than 30V on the PA stage, most being, of course, 12 volts.
Less chance of an inexperienced ham injuring him or herself. Oops - no vacuum
tubes! OK, we know that. Also lets out lots of used gear. We know that too.


N2EY: Also no line-powered equipment - it has 110 AC in it. No antenna tuners -
they may have high voltages present when transmitting.

The voltage-limitation thing is a very bad idea. Not only is it overly
limiting, it's unenforceable. Worse, it does not guarantee that inexperienced
hams won't hurt themselves. The power supply for a 100 watt solid state amateur
transceiver is typically 13.8 volts at 25 amps or so. Get a tool, wire or piece
of metal across that 13.8 volt line and see what happens.

And while 100 watts of RF is not considered an RF exposure hazard, direct
contact with it can be very hazardous to your health.

The 100W/50W power restriction makes sense. The 30 volt restriction does not.
Forget about it. You might as well propose requiring licenses for personal
computers - they have high voltages inside, particularly the CRT-type monitors.

KL7CC: All a ham has to do is upgrade, and the restriction goes away.

N2EY: If it's no big deal, why do we need a new entry-level license?

KL7CC: However, to upgrade, he or she must pass another test, which involves,
among other things, RF safety questions, power safety questions, and other
appropriate stuff. Remember that we are aiming this entry-level ticket at 12
year olds. Do you have kids? Grandkids? Wouldn't you be happier if their new
radio had very little chance of harming them? I would.

N2EY: The 30 volt restriction won't protect people from hurting themselves.
There's no license required to work with 110 volt house current.

KL7CC: Remove some of the math.

N2EY: There's no need for math above the 6th grade level in an entry level
test.

KL7CC: Remove some or even most of the "radio law" type questions.

N2EY: Removing any of the questions on applicable regulations is simply
unacceptable. If there is ANY subject which MUST be part of an amateur license
exam, it's the applicable rules and regulations. No exceptions for any license
class.

However, the privileges of the new license can be such that the applicable
regulations are not very extensive. If the privileges are kept simple, the
rules questions are also simplified.

KL7CC: Instead, require applicants to sign a statement that they have read the
Part 97 rulebook, and that they have a copy (available for free via web
download). Yes, some of the applicants will "skate" - and not read it when
they signed that they did. But, most will, and even among those that don't,
eventually, probably sooner than later, they will get around to it. Some never
will. That's human nature - we're not looking for saints, just people that can
become productive hams.

N2EY: BAD IDEA! There are simply no other words for it.

If you will accept a signed statement from a 12-year-old beginner with no radio
experience, why not take all of the radio law questions out of all of the
written exams and simply require the same statement from all hams?

This idea is part of what made cb go downhill. It's a very bad idea. It's
simply unacceptable.

In a word: NO! If they don't know the regs, they are not qualified to be hams.
It's that simple.

KL7CC: The 35-question exam is shrinking. 20 questions seem in reach.

Take out one or two more theory questions. We're not making engineers, at
least not yet. Put in a couple of additional practical questions about
operating your radio. A poke here, a cut there, and we're done. A
20-question exam that covers all a beginner really needs to know. Finish up
with a few words about how to find the information needed to advance one's
skills, how to find an "Elmer", and how to find more about the hobby on the
internet.

By the way - the Novice license of old, the one that many of us used to get
started - was a 20 question exam.

N2EY: And it later became a 25 question exam, and finally a 30 question exam.
The number of questions isn't the biggest concern, it's the content. Leave in
the regs and go for 25 questions.

KL7CC: For most of it's existence, the Novice exam had no questions about
antennas, propagation, feed lines, or most of the other questions that the
present "entry level" exam has. Yet, somehow, a great many hams who entered
via that license became active, productive, vital members of the Amateur Radio
community. How could that have been possible?

N2EY: Simple. Most hams back then started out with a shortwave receiver and
listened to the amateur bands before they ever got their license. That's how
most of us discovered amateur radio and learned the code. Many of us built our
first receivers, learning a lot of theory in the process. By the time we went
for our exams, all we needed was a transmitter to go on the air.

The old Novice by-mail license process was so slow that a ham could build a
complete station while waiting for the various FCC paperwork processes. And
because the old Novice was a one-time one- or two-year license, there was
tremendous incentive to upgrade before the license ran out.

KL7CC: Take a moment to think back. I'll be willing to bet you didn't just
drop out of a tree all ready to go, knowing everything that you know about ham
radio today, did you?

N2EY: Nope.

KL7CC: It took time; study, listening to other hams, all the rest, to get where
you are today.

N2EY: Sure. Now, how do we make sure that sort of thing keeps on happening?

KL7CC: Were you nervous on your first contact? Did you get over it? Did you
make a couple of dumb mistakes; maybe even accidentally violate the rules once,
or maybe even twice? These people will too. It's called learning.

N2EY: Sure - but it is essential that they know some basics before getting the
license and going on the air. The old Novice limited us to small parts of a few
bands, 75 watts input, and crystal control. Oh yes - and Morse code only.

KL7CC: What do you think is better for our hobby - lots of enthusiastic
newcomers, or an ever-declining number of increasingly older hams? Answer the
question honestly, not just in light of your favorite band getting more
crowded.

N2EY: Newcomers of all ages are always needed - and welcome! But we need to
insure that newcomers know certain basic things before they are granted a
license. The privileges granted should match the testing required.

This is not a trivial matter. We amateurs enjoy unprecedented and unequalled
freedom compared to other radio services. Our rules are relatively simple, our
choice of bands and modes enormous, and we are allowed to use non-type-accepted
and non-certified equipment on the air at considerable power levels.

This freedom carries with it the price of responsibility, which means knowing
the rules and following them. It means behaving ourselves on the air without a
lot of enforcement from FCC. And it means not interfering with other services
or each other when such interference can be avoided.

KL7CC: And another thing - if the bands get more crowded, doesn't that help
make a case for increased spectrum? And guess what? All those new hams vote
(or will soon enough), and Congress pays attention to numbers. Numbers become
very important when we are in ompetition with commercial interests for
spectrum space.

N2EY: How many amateurs are "enough", then? We have over 680,000 hams in the
USA today, at or near the all-time high.

Compared to the total population of the USA, we are a small group - and that is
not going to change no matter what the license requirements are, because radio
as an end in itself does not interest everyone.

KL7CC: And maybe the prices of new radio gear will decline, if manufacturers
can spread fixed costs over a larger sales base. And maybe some brand new
manufacturers will be encouraged to bring something to market. Will that be
bad?

N2EY: Amateur equipment costs less in inflation-adjusted dollars today than at
any time in the past. There are more manufacturers and a wider variety than
ever before - including kits and homebrew parts suppliers.

KL7CC: OK, now we've got a brand new ham.

N2EY: Maybe. You haven't explained how you're going to get more people to know
about amateur radio by simply changing the requirements for an entry-level
license.

KL7CC: Whether we call them a "Communicator", or some other name, what's next?
Where are they going to operate? Are you going to get run over by a horde of
newcomers? Help! I'm sinking in a sea of QRM!

Ahem. We have a plan. It probably won't turn out to be exactly the way things
come down, but it's a start. Someone else may very well come up with a better
suggestion. That's OK, too.

Whatever we come up with, it will have to fit within the FCC budget. This
probably means that in all likelihood what will happen, assuming that the idea
of a beginner's class license is even accepted at all, is that they (the FCC)
will juggle the existing 3 classes to accommodate the new structure.
Technician will change from what it is now to the basic license. It may be
named "Communicator" or simply left as Technician. Let's assume it gets the
name "Communicator".

N2EY: The FCC database currently maintains six different classes of amateur
license. FCC seems to have no problems with maintaining 3 old classes of
license that are no longer issued to new hams.

Since the proposed "Communicator" is really just a 21st century version of the
old Novice, just reopen the Novice to new issues and close off the Technician.
Existing Novices could get the new "Communicator" privileges so there is no
difference between "old" and "new" Novices.

KL7CC: All existing Techs will be upgraded to General.

N2EY: Why?

KL7CC: Assuming that the Morse requirement is removed first, our opinion is
that most of the Techs will take (and hopefully pass) the element 3 exam as
soon as they can, thus becoming General class licensees.

N2EY: If that happens, there is no reason for a free upgrade. If it doesn't,
Techs can always upgrade to General by taking the required test.

Recall that a free upgrade of existing Novices and Technician Pluses to General
was proposed by ARRL in 1998 - and soundly rejected.

KL7CC: Remember, that before the changes that created the present no-code tech,
the General and Tech exams were identical.

N2EY: This is not correct! The General and Technician shared the same written
exam until March of 1987 - four years before the Tech lost its code test.

KL7CC: Only the code separated them, and even there it was only the difference
between 5 and 13 WPM.

N2EY: As the rules stand right now, all pre-March-21-1987 Technicians get
credit for Elements 1 and 3 (5 wpm code and the General class written test) -
even if they let their licenses expire!

There is no reason to hand out free upgrades to Techs who have not passed the
General written. Those Techs who have passed the General written need only
provide documentation (old license, old Callbook page, data retrieved from old
databases) and they can get a General with no additional testing.

Is the current 35 question General class written exam so difficult?

KL7CC: All Advanced licenses will be upgraded to Extra, and if there are any
remaining Novice tickets out there, they will become "Communicators". Now we
have 3 classes: (1) Communicator, (2) General, and (3) Extra.

N2EY: Again - WHY? All existing Advanceds are able to upgrade to Extra by
taking Element 4 - no additional code.

KL7CC: The exams will be adjusted to combine element 2 and 3 into a new element
3, probably with a 50-question exam, using the existing pools. Element 1 (Code)
disappears. A new Element 2 is created, which becomes the Communicator exam.


N2EY: OK so far.

KL7CC: Element 4 remains as is, or maybe becomes even harder, in the event we
(all hams) indicate that the extra exam should really be a test that "separates
the men from the boys" (apologies to the YL's - JW). Many would agree that
this is already the case, and that no changes are required here.

N2EY: The third-grader who earned the Extra was an 8 year old girl at the time.

KL7CC: Kind of sounds like a bunch of folks are going to get something for
free, something that you might have worked hard for, doesn't it? How can we
justify this?

N2EY: The simple fact is, you can't justify it. Is there really a problem
maintaining the existing license classes in the database? What is the urgency
of combining license classes that are no longer issued to newcomers?

The instant upgrade scenarios also create the problem of "bargain hunting"
among newcomers because the changes will be discussed and announced long before
they become reality. So a new ham could get a Tech before the change occurs,
then simply get a free upgrade to General when the change happens. Same thing
with existing Techs and Advanceds - just wait for the change. What would be
created is a disincentive to learning more and passing the tests for the next
higher grade of license, because if they just wait a bit they'll get a free
upgrade. Not a good thing from a license structure that it supposed to
encourage learning!

KL7CC: Well, maybe it won't happen that way at all. Maybe instead of "instant
upgrades", the Techs will have to pass their element 3 exam or be downgraded to
Communicator licensees, and Advanced licensees will have to pass element 4 or
be downgraded to General. That goes in the face of our desire to have this
whole thing take place with no net loss to any existing licensee, but if enough
people object to the idea of "free" upgrades, then there is one alternative
(but probably unlikely) solution. Another is to continue the Technician and
Advanced licenses "as is", until they upgrade. Maybe even make upgrading
mandatory for renewal. Using that plan, they will all either upgrade or
disappear within 10 years, with no further effort on the part of the FCC.

N2EY: There's no reason to force upgrades or give free ones. FCC has maintained
a 6 class database with 3 'dead' classes for 3-1/2 years now - what's the
problem? What's the urgency to force all hams, new and existing, into just 3
license classes?

If you want a new entry level license, here's how to do it with minimal
problems:

Reopen Novice with new test and privileges proposed for "Communicator".
Close off existing Technician to new issues.
All Technicians get "Communicator" privileges on HF/MF
Old Technician and General writtens combine into a single written test of about
60 questions
Everybody can keep their existing license class, callsign and privileges except
that the Novice/Tech HF privileges are made the same as "Communicator".

Simple and easy. No big changes for existing hams nor rules. No instant
upgrades or license class changes.

KL7CC: OK, now the license classes have been tuned up, and the exams adjusted,
what's next?

We need some place where these new licensees can get their feet wet, where they
can participate in Amateur Radio in a meaningful way. All of ham radio, not
just local repeaters.

N2EY: Do you think VHF/UHF is just local repeaters? That's simply not the case.

KL7CC: What we need is a few spare kilohertz.

N2EY: Why?

KL7CC: I wonder where we can find some? New band? Probably not. So, what do
we have that can be reworked to fit our need? How about the present HF novice
bands?

Suppose, just for a moment, that a petition got filed requesting that the FCC
make the following changes: Take the present HF Novice bands on 80, 40, 15,
and 10 meters and reassign them to voice operation. Move the corresponding
phone segments down by the appropriate amount. Change the segments open to
various classes of license to fit, and let the new "Communicator" licensees
have access to the HF bands in 50 or 100 KHz blocks. For example, and this is
just an illustration, 40 meters could end up looking something like this:

7000 - 7025 Extra, CW and data only
7025 - 7100 All classes, including communicator, CW and data only
7100 - 7150 Extra, all modes
7150 - 7250 Extra and General, all modes
7250 - 7300 All classes, including communicator, all modes

Similar adjustments would be done at 80, 15, and 10 meters. Actually, 10
meters is already pretty much set and ready to go. We might do only 50 KHz on
15 meters, leaving the other 50 as a "DX window". There could be, or not be,
consideration of allowing communicators on the other HF bands (160, 30, 20, 17,
12). Not too sure what to do about the new 60-meter band yet. Have to think
about that one for a while. Perhaps we start here (with 80, 40, 15, and 10),
and after a few years experience, revisit the issue and decide whether granting
access to parts of the other HF bands is a good idea or not. Time will tell.

In other words, what we will have done is to "slide" the phone bands down the
equivalent amount of the former novice segment, and allowed the new
communicators access to the top 50 KHz of the voice band. Traditionally,
higher-class licensees have been given access to the lower frequency segments
within a band, and this would remain true.

N2EY: Very bad idea. There is no need for more 'phone space on HF. Such a plan
robs the spectrum-efficient modes and favors the spectrum-inefficient modes.

Look at the 40 meter plan proposed. It acts as a disincentive to use CW and
data, by increasing crowding of those modes and driving the Region 2 DX phones
even further below 7150. The same thing will be true of Regions 1 and 3 when
they get 7100-7200.

In addition, there is not much incentive for the Communicator CW or data
operator to upgrade unless he/she wants more power or the lowest 25 kHz - and
those lowest 25 kHz require an Extra.

What Communicators need is a good assortment of bands and modes to start out
with, and a reason to upgrade. At the very least, slices of all HF/MF bands
should be included. 30, 17 and 12 meters are so narrow that it makes sense to
give Communicators all of them (at the appropriate power level). This results
in less crowding and more flexibility.

Here's 40 for an example of how to handle the non-WARC bands:

7000-7150 CW and data only, 7150-7300 CW, analog phone and image

7000-7025 Extra only
7025-7050 Extra, General, Advanced only
7050-7150 All classes of license
7150-7225 Extra and Advanced only
7225-7250 Extra, Advanced and General only
7250-7300 All classes of license


KL7CC: No one loses anything!

N2EY: Yes, they do! The CW and data operators get squeezed and the 'phone
operators rewarded for using modes that take up a lot more spectrum. That's
just wrong.

There is no reason to widen the 'phone/image bands if the newcomers are allowed
enough space on each band. It's a mistake to limit Communicators to just
80/40/15 and 10, particularly as the sunspot cycle declines.

KL7CC: Generals and Extras get some new phone bands, even former Novices, (now
upgraded to Communicator) get more room in the CW segment, and access to a
portion of the phone band.

Communicators operate with their 100-watt limit, General and Extra can use 1500
if they wish. Again, no one loses!

N2EY: The current power level allowed to Novices and Tech Pluses on HF is more
than 100 watts.

KL7CC: No hassle like many of us remember over "incentive licensing" all those
many years ago.

N2EY: Trust me - there will be hassles. The free upgrade idea will cause a lot
of them.

KL7CC: If a "Communicator" wants to run more power, he or she simply upgrades
to General, and away they go. We (hams in general) might decide that
voluntary power restrictions in the "communicator" segments are appropriate,
but time will tell. That is another issue, not part of the 3-part plan we are
working on.

VHF and UHF privileges would be given to the communicator licensees. We are
suggesting 50 watts max for the bands 50 to 450 MHz inclusive, with no
operation on the higher UHF or microwave bands.

N2EY: The power limit makes sense.

KL7CC: An alternative solution, which has been adopted in other parts of the
world, would be to grant Communicators the same frequency privileges as
Generals, but with the lower power limits discussed above. The United Kingdom
has implemented this approach in their Foundation license, which has become the
fastest growing license in the UK's history.

N2EY: The UK system is very different from ours once you get into the details.
For example, all UK licenses require taking an approved amateur radio training
course before the license tests are taken. No exceptions, even for a Ph.D. in
EE who can do 50 wpm Morse. And the UK writtens are not 20-35 questions from a
published pool.

Do you want a system where every new ham has to go through an approved training
course? Why not? That's a core part of the UK system.

Granting full General privileges but limited power is not a good idea, either.
If the power limit is set fairly high (say, 100/50 watts) then there is less
incentive to upgrade because most US hams don't run much more than 100 watts.
If the limit is set at QRP levels, new hams are at a severe operational
disadvantage, particularly if they have to use compromise antennas.

KL7CC: Will anyone have any problems with these proposals? Of course.
Inevitably, it will turn out that someone's favorite net is in the
"communicator" area. Maybe the net members will decide to move, maybe they
will stay where they are and attract hundreds of new members. Someone's
favorite spot will suddenly turn out to be open to new modes. OK, so what?
Where does it say that anyone is given exclusive rights to one particular spot
or another? Pretty much every radio available today has a VFO. Use it. You
might even meet a new friend or two.

N2EY: It is important to have incentives to use more spectrum-efficient modes,
like PSK-31 and CW. Widening the 'phone bands reduces those incentives.

(continued in Part Three)

73 de Jim, N2EY