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Old February 13th 04, 06:46 PM
N2EY
 
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Paul W. Schleck wrote in message ...
In (N2EY) writes:


(old stuff snipped to save bw)

So you might accept grandfathering, if it occurred at some asymptotic
point in the past, and only affected a small minority of hams?


Depends on the situation. The old Extra waiver only began after there was no
difference
among the operating privileges of a General, Conditional, Advanced or Extra
(1952 or later). IOW it was
just a title sort of thing - didn't make any difference in practical
application. And anyone who qualified
for it was an OT from the very early days (35 years at least). By the time the
waiver meant anything
in terms of operating privileges, that gap was over 51 years.


According to W2XOY, the upgrade to Extra given to pre-1917 Hams with a
General or Advanced-class license started in 1951:

http://groups.yahoo.com/group/Ham-Ra...y/message/5330

along with the renaming of Class A to Advanced, Class B to General, C to
Conditional, and the introduction of the Novice and Technician.


That's correct.

So there was some short period of time (until the "Giveaway of 1953"),
where this "free upgrade" gave additional phone privileges on 75 and 20
meters for some of those pre-1917 hams. Specifically, those that held a
General class (formerly "Class B") license. That would be *accurate*.


Yes, it would be! I should have mentioned that earlier.

However, very few actually used that waiver, because

- there were not that many hams before May 1917
- there were fewer who had a Class B/General license
- full privs could be had with an Advanced, which was still available
until the end of 1952.

More information on this, just received today, is given below.

And the more I think about it, the more I think the old Extra waiver was a bad
idea, and that there may be
no scenario that would be worthwhile.


What about a proposal that
grandfathers some percentage of hams in-between?


I say no to free upgrades, then.


So nearly all of the previous discussion above is moot because there is
no "free upgrade" scenario that you will support regardless of the
percentage of hams affected, or their status/seniority.


There may be a free upgrade scenario that I would support, but I have
not seen one yet.

Remember that at some time in the future, we may be looking on this
grandfathering as occurring at some asymptotic point in the past, as
with the pre-1917 waiver above.


You mean like when the Advanced has been unavailable for 35+ years and their
numbers are down to about 1% of the ARS total?


Well, yes, that's what I was driving at. You want to wait until then.


I want to wait until someone presents a convincing argument as to why
such giveaways are needed for the good of the ARS.

I want to deal with the matter sooner. At least I got you to explicitly
bound your answers tighter than "never" or 0%. And what would you do
then?


Depends entirely on the situation at the time.

You ask below what is the long-term
plan. I say one aspect of the plan is to be able to look back on this
grandfathering in the same way that we look upon the pre-1917 waiver.


We don't look back on it the same way.


And why was it done?


The Restructuring FAQ at arrl.org omits the mention of waiver of the
written test, so it too is incomplete. I dropped a line to N1KB, who is
listed as the author of the document, with a request for correction and
clarification. He replied to me with pointers to some sources,
including Ham-Radio-History group noted above, which dates the origin of
the waiver, and "free upgrade," to 1951. W1UED just replied today with
an answer as to why. George E. Sterling, W1AE, was the first (and
likely only) radio amateur to come up through the ranks at the FCC and
be appointed Commissioner. The Amateur Extra license first appeared in
the 1920's and lasted through the 1930's, when it was discontinued as a
budget-cutting measure.


It didn't grant much in the way of more privileges, either, and very
few were actually issued.

During the 1951 restructuring, which restored
the Amateur Extra license, W1AE was an FCC Commissioner:

http://www.fcc.gov/commissioners/commish-list.html

As a pre-WWI licensee himself, he thought it would be an appropriate
honor to that group of hams if they were given the restored Amateur
Extra license, and had the political clout to make it happen. So, the
1951 restructuring gave anyone who was licensed prior to April 1917 and
who presently held a General or Advanced-class license, a "free upgrade"
to Extra.


IOW it was one guy's idea, and nobody was going to tell The
Commissioner that it wasn't a good one. Particularly since it only
affected a few hams anyway.

The following QST article describes the 1951 Restructuring and FCC
Dockets 10073 and 10077:

http://www.arrl.org/members-only/qqn... 1&selpub=QST

(ARRL Members-Only Link)

A photocopy of the full article is available for $3 ($5 for non-members)
postpaid from the ARRL.


Don't need it - I have those QSTs.

That still supports my original assertion that free upgrades given to
existing licensees, based on seniority or status, can be
non-controversial, especially when viewed from the long-term future.


Perhaps. Or perhaps they were "noncontroversial" because nobody wanted
The Commisioner mad at them.


To put it simply: Just leave the closed-off classes alone, and let them
go away by attrition.


This is exactly what was done with the Advanced from the beginning of 1953
until 1967 - more than 14 years. What problems did it cause?


The Advanced-class was eventually opened back up to new licensees, so we
do not know what the longer-term effects would have been.


True - but it was well over a decade before that reopening was even
discussed! And FCC had no problem with keeping those folks on the
records, even with a noncomputerized database.

I see no
realistic likelihood that Advanced will be (or even should be) reopened
in any foreseeable future.


That's what folks said exactly 50 years ago, too.

The outcome that you propose, which is to
carry them on the books for at least 35 more years or until they
constitute less than 1% of all hams, may introduce further problems than
the previous, and much shorter, 14-year period.


But all that avoids the main question of "what's the problem"? If
those Advanceds are satisfied with their license, why not let them
alone? If
they're not satisfied, is the Extra written test so difficult that
they
need a waiver?

In 4 years the number of Advanced has dropped by about 17,000. If it
keeps dropping in a linear (not asymptotic) fashion, the last one will
be gone
in less than 20 years.

I
would argue against that, for the reasons I have given previously
(streamlining of license classes, streamlining of band plans, reduction
of regulatory burden, reduction in confusion for amateurs and the FCC,
harmonization with the deletion of S25.5 and with other countries'
regulations, etc.).


All it takes to keep those classes is a few sentences in Part 97.


"A few sentences" in laws or regulations can have non-trivial
implications about the regulatory infrastructure that is necessary to
give them force.


OK, fine.

The difference between an Advanced and an Extra for enforcement
purposes is just 8 little slices on 4 HF ham bands. Is that a real
enforcement burden?
Four of those slices (the lower 25 kHz of CW/data) are the same as for
General, too, so the effective difference is just the 'phone subbands
on 75/40/20/15.

An Advanced-class license is one more alternative to
program into the licensing computer,


It's already there!

one more piece of regulation to be
understood and enforced by regulators,


Already in place.

and overall, one more class of
amateurs to track and incorporate into any regulatory policies and
agendas. The implementation of all of that is significantly more than a
few sentences.


No, it isn't. Look at Part 97 and see just how much would come out if
all Advanceds were upgraded to Extra. It's not very much.

Also, note that the free upgrades would *create* work for FCC, by
requiring that the databases and licensing stuff be updated to change
all those licenses.

Will FCC issue a new license to every ham that gets a free upgrade, or
will they
keep their old ones until renewal/upgrade time, which may be 12 years
hence (if someone just renewed, and doesn't renew again until near the
end of the grace period).

If license classes are consolidated to a smaller number, one alternative
is simply to grandfather existing hams, which the ARRL has advocated.


A more accurate term is "free upgrade", because that's what it is.


"Grandfather" implies letting a person keep what they already have without
recertification. That's not what is proposed by the ARRL BoD for Techs and
Advanceds.


One other implicit alternative (say, #5), is to make every Novice,
Advanced (and possibly non-Plus, or would that be non-Plussed, Tech)
come back in to take written tests to upgrade to the next level, or
otherwise lose privileges.


That's the worst alternative.


Which is why I specifically identify it and dismiss it early.

I would argue against that also, for the
reasons I have also given previously (it is impractical to retest
everyone,


It could easily be done over time by saying that you either retest before Date
X
or you'll be reclassified at a lower license class.


There is a legitimate distinction between "easy" and "straightforward."


In this case they're the same. The VECs do the testing and most of the
paperwork. That's why FCC required existing Tech Pluses from before
March 21, 1987 to do a testless VE session in ordr to get Generals.

Anyone with engineering experience surely knows that something could be
conceptually simple, but still complex and time-consuming in its actual
implementation.


Been there, done that.

Mass re-testing might be straightforward, but would not
be easy within FCC and VEC budget/manpower constraints.


We're talking about spreading it out over many years. And there's an
upside - some of them will upgrade all the way to Extra while they're
at the VE session.

Besides, if things go the way NCVEC wants, they won't have the
"burden" of code tests anymore anyway, so what's the problem?

Mass re-testing would be a regulatory burden for the FCC,


Not if it were spread out over time, as outlined above.

a personal
burden on VEC's who would have play de-facto judge and jury for large
numbers of existing peers, friends, fellow club members, etc.,
concerning whether or not they could retain former privileges (what
volunteer would want to endure that for very long?),


How would that be any different than now? VECs don't pass judgement on
written tests, they simply proctor and grade them in multiple-choice
format. Where's the "personal burden" other than the crowd being a
little bigger?

Or do you imagine that the VECs would somehow sit in judgement?

and would go
against where the FCC is heading, which is towards less regulation and
fewer grand schemes.


Like BPL?

I might also argue that mass-retesting is sounding
very much like a repeat of the scenario played out in the 1960's with
Incentive Licensing.

And that would kill it stone dead.

There's another angle, too:

Mandatory retesting would reveal how many hams were either totally
inactive or had lost interest to the point that they'd let the license
expire. Would probably cause a massive drop in the number of hams on
the database. Not a good thing from a political point of view.

By the same token, if FCC automatically issues new licenses to all
free-upgraded hams, a number of them will come back labeled "not at
this address" or "deceased" or some such. Which could have a similar
effect to the above. And since it's a requirement to keep FCC aware of
address changes....

There's a lot of debate in this newsgroup about the Incentive Licensing
scheme of the 1960's, who initiated it, what was intended, who supported
it, why it failed, who was to blame, etc., but one thing that most can
agree on is that it's very easy to start out with good intentions, and
what comes out the exit door of regulatory agencies might be
unrecognizable as something that would give the desired result.


Agreed! The original 1963 ARRL IL proposal bore little resemblance to
what finally came out the door.

And in 1999, the R&O bore little resemblance to the NPRM. Example: The
NPRM called for Advanced to stay.

Hence
the expression, "The road to hell is paved with good intentions." Mass
re-testing could also be viewed as well-intentioned, but ultimately a
road to hell.

That argues for leaving everything just as it is now. OK, fine,
we'll just do that.

So, it's a good thing that neither of us are arguing in favor of testing
to avoid losing privileges, right?


Depends on whether privs are actually "lost".

and such existing hams are a large, stable user base such as
that in the definition of grandfathering below).


"Large, stable user base"? We don't really know about that. How many
of those folks are active? Why have so few Advanceds upgraded to
Extra?


You are teetering very close to making a non-falsifiable argument here.


A true statement is, by definition, non-falsifiable, is it not?

You argue here, and in other threads, that Advanced should be left alone
because:

- There are still quite a few of them, who are happy with their present
privileges, who would get a free upgrade unfairly, and crowd the Extra
phone bands.


Not just the phone bands!

*AND*

- There may not be very many of them, active at least, so any upgrade
would not give much benefit, anyway.


Covers all bases, doesn't it?

You also argue that Novice should be left alone because there aren't
very many of them, but then advocate restructuring that you believe
would bring back its "heyday" with many more licensees in that class,
which of course, should then be left alone.


The idea is that the Novice would be *changed*, not simply reopened.

Which is it? Too many, or too few, to justify elimination?


The idea is to cover all bases. Does anybody really know why so few
Advanceds have upgraded?

If neither
is a sufficient criteria to argue for or against elimination of a
license class, then that's a non-falsifiable argument.


The idea is to do what will give the best results for the ARS with the
minimum amount of negative effects.

IOW, we allow them to continue doing what they're doing because they've shown
a lack of problems in the past. But we require more of new systems.
It *doesn't* say we allow free upgrades.


When you say "we require more of new systems" above, are you referring
to people or license classes?


I'm referring to *systems*.

There is a subtle distinction. A group
of people may not want to change, but license classes may need to. A
set of license classes is a ladder, to be climbed as far as the licensee
wishes to develop his skills.


Some reject that idea, and say that there should be just one license
class. How do we answer them?

It is also a taxonomy, with a specific
regulatory purpose. That purpose is to ensure that limited frequency
spectrum is being put to the best and highest use via the distribution
of privileges over that spectrum. Implicit in this is structuring the
license class system to ensure that all amateur radio spectrum (HF, VHF,
UHF, Microwave) is not only used, but used well, in ways that fulfill
the Basis and Purpose (FCC Part 97.1).


But how can any license structure actually do that? Or, to take a
different
approach, why not have just one class (as some have argued here) with
all amateur privileges?

Since technologies, modes, and frequency usage patterns change over
time, the taxonomy should change as well, hence the need for periodic
restructuring over amateur radio's 100-year lifetime (Though I would
argue that not doing the "Giveway of 1953," and staying with the 1951
restructuring until the no-code issue came to a head in the 1980's,
would have avoided the backlash that resulted in Incentive Licensing of
1968).


I agree! So *why* was the "Great Giveaway" of December 1952 done,
particularly since FCC had just spent several years going in the
opposite direction? Why was the restructure of 1951 turned on its head
just as it was going into full effect?

Was it:

- Sudden personnel changes at FCC?
- Desire to push the use of SSB by hams?
- Desire to get hams off of 10-11 meters (the only HF bands open to
General and Conditional 'phone) to alleviate TVI?
- Desire to get more hams using HF mobile (which was only opened to
hams after WW2)?
- Combination of the above?

I have yet to find a definitive answer to why the "Great Giveaway" was
done, either in the written histories or in the recollections of hams
from that time. The answer could be as simple as "The Commissioner
changed his mind".


Out of time right now. Will answer the rest in Part Two

73 de Jim, N2EY