Comments submitted to the FCC,
advocating ARRL administration of
Morse license endorsment:
-------------------

18 Aug. 2005
WT Docket 05-235,
Amateur Radio Morse Code Testing Requirement.

I respectfully submit that we can relieve
the FCC of the burden and expense of administering
Amateur Radio Element One (Morse Code),
while preserving a skill which has both
a direct bearing on our nation's security
and a "global heritage" aspect.

We should maintain some level of incentive to
preserve and develop skill in Morse Code:

* Morse Code is still in use for covert
and intelligence operations throughout the world,
and will remain so for the foreseeable future.

* Morse code transmitters and receivers
are simple to make and operate,
needing only a handful of low-tech, inexpensive parts,
making them available even in less-developed
areas of the globe, where expensive and complicated
"hi-tech" systems are unavailable and, if present,
are subject to multiple failure modes.

* The only ready and sizable reservoir of trained
Morse operators is the Amateur Radio community.
If we remove any incentive to develop Morse skill,
this valuable asset will quickly cease to exist.

There is also a global historic and "Heritage of Humanity"
aspect to this issue. Morse Code has served as a
reliable means of communications for one and a half centuries.
It has been a primary tool in life-saving and part of
the great communication web that has knit us together,
first spanning neighborhoods, then continents, and
finally the world. As a tool in the evolution of
the global community, it ranks with the sailing ship,
steam ship, railroad and telephone. We preserve early
examples of these other means of connecting with
the larger world; Morse Code surely deserves at least
a modest effort at preservation, just as we preserve
these other "touch-stones" of our progress.
Without some form of incentive,
this important skill will be lost to us.

We can accomplish this while removing the burden
and expense from the FCC.
I respectfully suggest the following steps be adopted:

1. Drop the Element One (Morse Code) testing requirement
from Amateur Radio regulations. The FCC would
no longer be responsible for, or need to allocate
resources to, this task.

2. Reallocate the bottom 10 kiloHertz of each Amateur Radio
spectrum allocation to exclusive Morse Code use.
This is a small window, but is easily sufficient bandwidth
for skilled Morse operators.
It provides an "historic preserve," protected from
new and wider-bandwidth modes and will have
no impact on the development and use of new techniques.

3. Authorize the American Radio Relay League (ARRL) to
administer and issue, through the Volunteer Examiner
program, a license endorsement, attachable to any class
of Amateur Radio license, awarded for demonstration
of Morse skill at 5 WPM or better. Only those Amateur
operators with the endorsement could operate their stations
in the 10 kHz "historic preserves." The ARRL could
establish premiums for contesting and skill certifications
earned within the "preserves."
Continue to allow Morse Code use throughout
the remaining Amateur spectrum, subject to present rules
and/or future reallocations.

These modest steps will preserve this valuable and historic skill,
while removing the administrative burden from the FCC.
I respectfully submit them for your consideration.

Kind Regards,
David L. Stinson AB5S
Field Engineer
Wylie, Texas