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Old July 31st 03, 07:32 AM
D. Stussy
 
Posts: n/a
Default Some comments on the NCVEC petition

On Thu, 31 Jul 2003, N2EY wrote:
Amateur radio operators, however, use it extensively. On the HF/MF amateur
bands, it is the second most popular mode of communications, only slightly
behind SSB in popularity.


1) Just because it won't be tested for doesn't mean that it can't be used!
2) In this petition, they made NO adjustment to the "CW protected bands."

It is undoubted that someone will come along with a follow-up petition to
decrease or eliminate the CW bands. I would be in favor of reducing their size
to between 1/3 and 1/4 of each band (in many places, it's 1/2 of the band),
but not complete elimination. Along with CW in many places come some of the
digital operating modes (at least on HF) - and those too need protection from
voice.

PS: I haven't significantly used code since I passed it on the exam for my
license, nor do I plan to. (If you look me up, you'll know that I have at
least 13wpm because I held an Advanced as my prior license class from 10
years ago.)

There is no requirement that any radio amateur actually use Morse code. Radio
amateurs use it by choice.


Justification for it NOT to be a requirement.
(Do we all know what requirement means? :-) )

Written tests are a burden to the applicants, too.


Are you advocating no license testing at all? How about no licenses? Having
to fill out the paperwork is a burden too!

(I am not advocating dropping the license requirement; just showing that his
argument can be taken ad absurdium.)

However, it should be noted that most of the Commission's enforcement actions
for poor and illegal operating practices such as jamming, obscenity/profanity,
failure to identify, operation outside of license privileges and failure to
heed bandplans are against amateurs using voice modes, not Morse code or
digital modes.


Profanity, by itself, is illegal? The FCC has never said that. There may be
limits and conditions where it's inappropriate, but there have been findings
that in some very limited contexts that profanity by itself does NOT cause a
violation to have occurred.

Following this logic, the written exams should be stripped of anything a
licensee does not have an interest in.


Does that include having to answer ANY question? :-)

This proposal simply drops Element 1 without making any other changes. Oddly
enough, if it were adopted, Technicians would gain a bit of 10 meter SSB. Most
of the privileges Technicians would gain would be slices of 80, 40, 15 and 10
meter CW.


I don't see a problem with that. What's your problem with it?

This petition is meant to address the change in international agreement
dropping the code requirement as a license prerequisite and NOTHING MORE.
They're not out to overhaul the entire service; just this one part. At least
they're doing it in a way that has no impact on the rest of it.

If you want to mess with the mandated bandplans, file your own petition.

  #2   Report Post  
Old July 31st 03, 09:59 PM
N2EY
 
Posts: n/a
Default

"D. Stussy" wrote in message .org...
On Thu, 31 Jul 2003, N2EY wrote:


Amateur radio operators, however, use it extensively. On the HF/MF

amateur
bands, it is the second most popular mode of communications, only

slightly
behind SSB in popularity.


1) Just because it won't be tested for doesn't mean that it can't be

used!

Of course. That's not the point. The NCVEC petition tries to convey
the message of "nobody else uses Morse anymore" as if that has some
relevance to what hams do, and should be tested on.

2) In this petition, they made NO adjustment to the "CW protected

bands."

It is undoubted that someone will come along with a follow-up

petition to
decrease or eliminate the CW bands.


Except there aren't any "CW protected bands" or "CW bands". There are
'phone/image subbands and CW/data subbands, however. Decreasing or
eliminating them without other measures being taken is not a good idea
at all.

Is it really that much trouble for people to learn to write "CW/data
subbands"? Because that's what they are, despite the fact that some
people think they are CW only.

I would be in favor of reducing their size
to between 1/3 and 1/4 of each band (in many places, it's 1/2 of the

band),
but not complete elimination.


Let's take a look at what's in place now:

Band - Total kHz - CW-data/phone-image kHz %

160 - 200 - 0/200 - 0%/100%
80/75 - 500 - 250/250 - 50%/50%
40 - 300 - 150/150 - 50%/50%
30 - 50 - 50/0 -100%/0%
20 - 350 - 150/200 - 43%/57%
17 - 100 - 32/68 - 32%/68%
15 - 450 - 200/250 - 44%/56%
12 - 100 - 40/60 - 40%/60%
10 -1700 - 300/1400 - 18%/82%
Total
HF/MF 3750 - 1172/2578 - 31%/69%

So what we have right now is more than 2/3 of US HF/MF available to
phone-image use. Except for 30 meters, no band is less than 50%
phone-image. VHF/UHF is wide open for all modes except for two little
CW-only stretches at the bottom of 6 and 2 meters.

Isn't that adequate? Why should the modes which are least spectrally
efficent be rewarded with still more spectrum? NCVEC talks about new
modes, technically knowledgeable people, yada yada yada, all the
electropolitically correct buzzphrases. Will those people need wider
phone/image subbands to use their manufactured rigs on SSB?

There might be a case for some adjustments, though, like creating a
non-phone subband on 160, widening 75 a bit, adding modes other than
CW to the 6 and 2 meter subbands, and creating CW-only subbands on
each HF band.

Along with CW in many places come some of the
digital operating modes (at least on HF) - and those too need

protection from
voice.


"Many places"? Try "everywhere". CW has no exclusive subbands except
for those two on the bottom of 6 and 2. CW has to share every bit of
non-phone HF/MF space with data modes. In a nocodetest future, that
should change.

The petition talks about technically knowledgeable people and new
modes and technologies. On HF, that stuff is almost exclusively
happening in the CW/data subbands. Unless you count "single wideband"
as a progressive new mode....

PS: I haven't significantly used code since I passed it on the exam

for my
license, nor do I plan to.


That's fine. There's a bunch of modes I had to learn about for the
tests that I haven't used significantly, if at all, since I passed the
test. Nor do I plan to.

A lot of hams, including me, use Morse very significantly. The NCVEC
petition talks as if we code-using hams don't exist.

(If you look me up, you'll know that I have at
least 13wpm because I held an Advanced as my prior license class from

10
years ago.)


How do I know you didn't get the Advanced via medical waiver? ;-) (Not
that there's anything wrong with that!) Waivers have been available
for over 13 years.

There is no requirement that any radio amateur actually use Morse

code. Radio
amateurs use it by choice.


Justification for it NOT to be a requirement.


Perhaps. Yet NCVEC did not pursue that line of reasoning, which could
be a very powerful argument. Instead, they wrote as if they want code
USE by hams to go away.

But the petition claims that hams ONLY use it because of the test
requirement. That's just not true.

(Do we all know what requirement means? :-) )


The whole world wonders.

Written tests are a burden to the applicants, too.


Are you advocating no license testing at all?


Nope. Just the opposite.

How about no licenses?


Nope, just the opposite.

Having to fill out the paperwork is a burden too!


Exactly. And it turns away some people.

(I am not advocating dropping the license requirement; just showing

that his
argument can be taken ad absurdium.)


Reductio ad absurdum is a valid technique of showing the validity of a
hypothesis. If a hypothesis can be shown to logically lead to a
contradiction or absurdity, the hypothesis must be false.

However, it should be noted that most of the Commission's

enforcement actions
for poor and illegal operating practices such as jamming,

obscenity/profanity,
failure to identify, operation outside of license privileges and

failure to
heed bandplans are against amateurs using voice modes, not Morse

code or
digital modes.


Profanity, by itself, is illegal? The FCC has never said that.

There may be
limits and conditions where it's inappropriate, but there have been

findings
that in some very limited contexts that profanity by itself does NOT

cause a
violation to have occurred.


Doesn't change the basic fact of what I was pointing out: Phone
operation generates far more enforcement actions than CW/data
operations. Some of these enforcement actions are for behavior that is
truly awful, and very embarrassing to the ARS.

When I first started out, I recall there was a common philosophy that
'phone operators had to set the highest possible standards of
courtesy, respect and operating skill while on the air because anyone
and everyone could be listening. That philosphy seems to have become
inverted over the years.

Following this logic, the written exams should be stripped of

anything a
licensee does not have an interest in.


Does that include having to answer ANY question? :-)


Any question the examinee doesn't think is relevant. For example, why
should someone who never, ever intends to use voice modes, or who may
be physically unable to use them, have to learn about them? Isn't that
a burden on them? Why should they have to learn something they'll
never, ever use?

The NCVEC petition says it's a burden to require a code test to
operate voice modes. If that's valid, why isn't it a burden to require
questions on voice modes in order to operate CW or data modes? Look at
all the written testing a ham has to go through just to operate a
manufactured CW rig on 7005 kHz. Why?

Some might say "because it supports the basis and purposes of the
ARS". The obvious response is "How?" Also, there is no requirement
that each amateur support the basis and purposes of the ARS in any way
other than following the rules.

What it all boils down to is that except for some very basic rules,
regulations and safety considerations, most of the test requirements
for an amateur license come down to somebody's opinion about what
should be tested. Opinion and nothing more.

This proposal simply drops Element 1 without making any other

changes. Oddly
enough, if it were adopted, Technicians would gain a bit of 10

meter SSB. Most
of the privileges Technicians would gain would be slices of 80, 40,

15 and 10
meter CW.


I don't see a problem with that. What's your problem with it?


It's incomplete. It looks like the NCVEC had blinders on.

Do you really think that the very best we can do for entry-level HF
privileges for new hams in a nocodetest 21st century future is to give
them tiny slices of CW on four bands and SSB on one band, and at the
same time give them all of amateur VHF/UHF? Is that really what's best
for the ARS?

This petition is meant to address the change in international

agreement
dropping the code requirement as a license prerequisite and NOTHING

MORE.
They're not out to overhaul the entire service; just this one part.


Which means FCC may do the whole NPRM cycle again for just that. Why
not do something a little more comprehensive? Will the FCC be flooded
with followup petitions? Probably. Carl, WK3C, has said here that's
not the way to go. I agree with him. Are we both wrong?

At least they're doing it in a way that has no impact on the rest of

it.

If you want to mess with the mandated bandplans, file your own

petition.

Bandplans are voluntary. Subbands are part of the rules. I say the
subbands could use some work. Let's see....3500-3575, CW only.
3575-3675, data and CW. 3675-3725, Data modes including digital
voice, and CW. 3725-4000, phone....

73 de Jim, N2EY
  #3   Report Post  
Old July 31st 03, 10:58 PM
D. Stussy
 
Posts: n/a
Default

On Thu, 31 Jul 2003, N2EY wrote:
"D. Stussy" wrote in message .org...
On Thu, 31 Jul 2003, N2EY wrote:

....
Along with CW in many places come some of the
digital operating modes (at least on HF) - and those too need

protection from
voice.


"Many places"? Try "everywhere". CW has no exclusive subbands except
for those two on the bottom of 6 and 2. CW has to share every bit of
non-phone HF/MF space with data modes. In a nocodetest future, that
should change.


I said "many places" because it is NOT true for 6m and 2m. "Everywhere" is
wrong. I chose my words carefully here, and your carelessness has introduced
error.

The petition talks about technically knowledgeable people and new
modes and technologies. On HF, that stuff is almost exclusively
happening in the CW/data subbands. Unless you count "single wideband"
as a progressive new mode....

PS: I haven't significantly used code since I passed it on the exam for my
license, nor do I plan to.


That's fine. There's a bunch of modes I had to learn about for the
tests that I haven't used significantly, if at all, since I passed the
test. Nor do I plan to.

A lot of hams, including me, use Morse very significantly. The NCVEC
petition talks as if we code-using hams don't exist.

(If you look me up, you'll know that I have at
least 13wpm because I held an Advanced as my prior license class from

10
years ago.)


How do I know you didn't get the Advanced via medical waiver? ;-) (Not
that there's anything wrong with that!) Waivers have been available
for over 13 years.


Because if I had used the medical waiver procedure, I would have been an Extra
back then..... I passed all the written elements in 1992 (3 in one session),
but didn't get 20wpm within a year (but got 13, and element 4B expired). The
ease of element 4B back then should have clued you in....

There is no requirement that any radio amateur actually use Morse

code. Radio
amateurs use it by choice.


Justification for it NOT to be a requirement.


Perhaps. Yet NCVEC did not pursue that line of reasoning, which could
be a very powerful argument. Instead, they wrote as if they want code
USE by hams to go away.

But the petition claims that hams ONLY use it because of the test
requirement. That's just not true.


Their involvement is with testing, not operating....

(Do we all know what requirement means? :-) )


The whole world wonders.

Written tests are a burden to the applicants, too.


Are you advocating no license testing at all?


Nope. Just the opposite.

How about no licenses?


Nope, just the opposite.

Having to fill out the paperwork is a burden too!


Exactly. And it turns away some people.

(I am not advocating dropping the license requirement; just showing

that his
argument can be taken ad absurdium.)


Reductio ad absurdum is a valid technique of showing the validity of a
hypothesis. If a hypothesis can be shown to logically lead to a
contradiction or absurdity, the hypothesis must be false.


....But only if it's clear that's what you're doing. There are some on this
group for which such is beyond their comprehension.

However, it should be noted that most of the Commission's

enforcement actions
for poor and illegal operating practices such as jamming,

obscenity/profanity,
failure to identify, operation outside of license privileges and

failure to
heed bandplans are against amateurs using voice modes, not Morse

code or
digital modes.


Profanity, by itself, is illegal? The FCC has never said that.

There may be
limits and conditions where it's inappropriate, but there have been

findings
that in some very limited contexts that profanity by itself does NOT

cause a
violation to have occurred.


Doesn't change the basic fact of what I was pointing out: Phone
operation generates far more enforcement actions than CW/data
operations. Some of these enforcement actions are for behavior that is
truly awful, and very embarrassing to the ARS.

When I first started out, I recall there was a common philosophy that
'phone operators had to set the highest possible standards of
courtesy, respect and operating skill while on the air because anyone
and everyone could be listening. That philosphy seems to have become
inverted over the years.


Apparently, you've never been to Southern California. There were times where
one could count the violations on our "animal farm" repeater - and sometimes
the number of violations per minute would exceed the number of seconds in a
minute. Most of those misfits are still licensed. Watch out HF - here they
come!

Following this logic, the written exams should be stripped of

anything a
licensee does not have an interest in.


Does that include having to answer ANY question? :-)


Any question the examinee doesn't think is relevant. For example, why
should someone who never, ever intends to use voice modes, or who may
be physically unable to use them, have to learn about them? Isn't that
a burden on them? Why should they have to learn something they'll
never, ever use?


So, if I don't think any question is relevant, I can dispose of the entire
test? :-)

The NCVEC petition says it's a burden to require a code test to
operate voice modes. If that's valid, why isn't it a burden to require
questions on voice modes in order to operate CW or data modes? Look at
all the written testing a ham has to go through just to operate a
manufactured CW rig on 7005 kHz. Why?


They had to offer some justification.

Some might say "because it supports the basis and purposes of the
ARS". The obvious response is "How?" Also, there is no requirement
that each amateur support the basis and purposes of the ARS in any way
other than following the rules.

What it all boils down to is that except for some very basic rules,
regulations and safety considerations, most of the test requirements
for an amateur license come down to somebody's opinion about what
should be tested. Opinion and nothing more.


And if the FCC didn't like that, then they'd take testing back and do it
themselves.

This proposal simply drops Element 1 without making any other

changes. Oddly
enough, if it were adopted, Technicians would gain a bit of 10

meter SSB. Most
of the privileges Technicians would gain would be slices of 80, 40,

15 and 10
meter CW.


I don't see a problem with that. What's your problem with it?


It's incomplete. It looks like the NCVEC had blinders on.


I disagree. They aren't looking to refarm the service; just take "one bite
from the apple." (It may be the first bite, but not the last.) Perhaps they
believe in taking SMALL steps and seeing what happens. Alternatively, since
their involvement is with testing, perhaps that's all they felt they could
justify.

Do you really think that the very best we can do for entry-level HF
privileges for new hams in a nocodetest 21st century future is to give
them tiny slices of CW on four bands and SSB on one band, and at the
same time give them all of amateur VHF/UHF? Is that really what's best
for the ARS?


I don't pretend to speak for what is best for the entire service. I've posted
my thoughts about licensing elsewhere.

This petition is meant to address the change in international

agreement
dropping the code requirement as a license prerequisite and NOTHING

MORE.
They're not out to overhaul the entire service; just this one part.


Which means FCC may do the whole NPRM cycle again for just that. Why
not do something a little more comprehensive? Will the FCC be flooded
with followup petitions? Probably. Carl, WK3C, has said here that's
not the way to go. I agree with him. Are we both wrong?

At least they're doing it in a way that has no impact on the rest of

it.

If you want to mess with the mandated bandplans, file your own

petition.

Bandplans are voluntary. Subbands are part of the rules. I say the
subbands could use some work. Let's see....3500-3575, CW only.
3575-3675, data and CW. 3675-3725, Data modes including digital
voice, and CW. 3725-4000, phone....


Actually, bandplans aren't voluntary if someone can be cited for not following
them (and that has happened). If they were clearly voluntary, then such a
citation would be defeated (at least, defeatable) in an agency hearing.
  #4   Report Post  
Old July 31st 03, 11:48 PM
Dee D. Flint
 
Posts: n/a
Default


"N2EY" wrote in message
om...
Do you really think that the very best we can do for entry-level HF
privileges for new hams in a nocodetest 21st century future is to give
them tiny slices of CW on four bands and SSB on one band, and at the
same time give them all of amateur VHF/UHF? Is that really what's best
for the ARS?


No reason to give the Techs any more than what the current coded Techs get.
If they want more, they can take the General written. It's only slightly
harder than the Tech test.

Dee D. Flint, N8UZE

  #5   Report Post  
Old August 1st 03, 12:35 AM
Phil Kane
 
Posts: n/a
Default

On Thu, 31 Jul 2003 21:58:16 GMT, D. Stussy wrote:

What it all boils down to is that except for some very basic rules,
regulations and safety considerations, most of the test requirements
for an amateur license come down to somebody's opinion about what
should be tested. Opinion and nothing more.


And if the FCC didn't like that, then they'd take testing back and do it
themselves.


Thus substituting the judgment of the Chief,. Licensing and
Rxamination Branch (the guy - yes, one individual - who used to make
up the tests) for the judgment of the Question Pool Committee.

--
73 de K2ASP - Phil Kane

From a Clearing in the Silicon Forest
Beaverton (Washington County) Oregon




  #6   Report Post  
Old August 2nd 03, 06:20 AM
D. Stussy
 
Posts: n/a
Default

On Thu, 31 Jul 2003, Phil Kane wrote:
On Thu, 31 Jul 2003 21:58:16 GMT, D. Stussy wrote:
What it all boils down to is that except for some very basic rules,
regulations and safety considerations, most of the test requirements
for an amateur license come down to somebody's opinion about what
should be tested. Opinion and nothing more.


And if the FCC didn't like that, then they'd take testing back and do it
themselves.


Thus substituting the judgment of the Chief,. Licensing and
Rxamination Branch (the guy - yes, one individual - who used to make
up the tests) for the judgment of the Question Pool Committee.


That may be true. I never said it was a good idea. I only said that it's the
government's option, good or bad.
  #7   Report Post  
Old August 2nd 03, 06:22 AM
D. Stussy
 
Posts: n/a
Default

On Fri, 1 Aug 2003, Dick Carroll; wrote:
"D. Stussy" wrote:
Apparently, you've never been to Southern California. There were times where
one could count the violations on our "animal farm" repeater - and sometimes
the number of violations per minute would exceed the number of seconds in a
minute. Most of those misfits are still licensed. Watch out HF - here they
come!


Yep, just as they came to VHF/UHF ham radio from the never-never
land of 27 mhz via a no-code (and virtualy no-test) ham radio license.
Seems like the FCC just doesn't care, or they'd never allow it.


There's one and ONLY one reason why the So CA amateur community allows it - it
keeps them off the rest of the repeaters! :-)
  #8   Report Post  
Old August 2nd 03, 06:29 AM
D. Stussy
 
Posts: n/a
Default

On Fri, 1 Aug 2003, N2EY wrote:
....
There is no requirement that any radio amateur actually use Morse code. Radio
amateurs use it by choice.
Justification for it NOT to be a requirement.

Perhaps. Yet NCVEC did not pursue that line of reasoning, which could
be a very powerful argument. Instead, they wrote as if they want code
USE by hams to go away.

But the petition claims that hams ONLY use it because of the test
requirement. That's just not true.


Their involvement is with testing, not operating....


Then why talk about how much a mode is used and why?


So they can at least APPEAR to justify their position.

...
So, if I don't think any question is relevant, I can dispose of the entire
test? :-)


That's the ad absurdum that the NECVEC argument leads to.


But they didn't say that, nor does it necessarily lead all readers to that
conclusion....

It's incomplete. It looks like the NCVEC had blinders on.


I disagree. They aren't looking to refarm the service; just take "one bite
from the apple." (It may be the first bite, but not the last.)


Then it's sloppy. Or dishonest.


I disagree - neither sloppy nor dishonest. It's all that their function could
justify - and perhaps all that they really care about. Changing the bandplans
or anything else to have to do with morse code they simply leave for others,
because it's outside their little world.

  #9   Report Post  
Old August 2nd 03, 02:03 PM
Bill Sohl
 
Posts: n/a
Default


"N2EY" wrote in message
...
PETITION FOR RULE MAKING


The National Conference of Volunteer Examiner Coordinators (NCVEC) is
the umbrella organization comprised of the fourteen organizations
charged since 1984, under Section 97.519(a) of the rules of the Federal
Communications Commission, 47 CFR 97.519(a) to develop and administer
all Amateur Radio operator license testing and to electronically file
all successful license applications with the FCC. In total, the VECs
and their more than 30,000 VE teams have collectively administered
nearly two million examinations during the past twenty years and have
notified the FCC to issue approximately a million new and upgraded
Amateur Radio licenses.


The NCVEC is not, however, an organization where the VECs are elected, or

where
individual VE opinions were gathered or solicited.


So? Your point? Is that something that should call into question
the NCVEC as being invalid, illegal, or fattening?

Once a year, the various Volunteer Examiner Coordinator organizations
meet at their annual conference to discuss the various issues that
impact Amateur Radio operator testing. At their July 25, 2003, meeting
held with the FCC in Gettysburg, PA, the VECs overwhelmingly agreed
that Morse code testing should be immediately ended since it was now
possible to do so. It was also noted that countries have already begun
discontinuing Morse examinations. As a result the VECs voted to file
this Petition asking that the FCC take expedited action to allow them
to discontinue administering Element 1, the 5 words-per-minute
telegraphy examination as soon as possible.


No surprise there.

Pursuant to Section 1.405 of the Commission's procedural rules (47
C.F.R. 1.405), the NCVEC hereby respectfully requests that the
Commission issue a Notice of Proposed Rule Making at an early date
looking toward amendment of the rules governing the Amateur Radio
Service, 47 C.F.R. 97.1 et seq., as set forth herein and in the
attached Appendix.


No imagination, either.


When dis imagination or, for that matter, creativity have to be part
of the filling/process?

The rule changes requested herein would terminate the telegraphy
examination requirement and permit existing Technician Class operators
to access HF spectrum as provided in 47 C.F.R.  97.301(e) without the
necessity of passing a Morse code examination. This request to
eliminate the Morse code (Element 1) examination does not necessarily
have the support of the ARRL Board since they have yet to develop a
position on the matter. In support of its petition, NCVEC states as
follows:


I. Introduction and Background

Since the turn of the century, the Morse code, invented by American
Samuel Morse and first used in 1844, has been the foundation of early
distress and safety communications. Although Morse code (or CW, as it
is commonly called) was the primary mode of communications from the
late 19th Century through the early 20th Century, it has all but become
obsolete in practically all other contemporary communication systems.
Due to the emergence of satellite and digital communications, manual
telegraphy is no longer used or required in any radio service other
than in the Amateur Service.


Amateur radio operators, however, use it extensively. On the HF/MF amateur
bands, it is the second most popular mode of communications, only slightly
behind SSB in popularity.


So? Hams also use differnent languages (Engish, Spanish, Chineese, etc.)
yet no one is mandated to use or be tested in any language other than
that of their "home" country.

The Amateur Radio Service is unlike other radio services in its needs and
resources.


So are you sying amateur radio "needs" morse code testing? If so,
the burden of proof hasn't been met as per FCC R&O for 98-143.

Radiotelegraphy in the maritime service has been phased out in favor of
modern technology. The last vestige of manual telegraphy began being
phased out in the maritime service in 1988 when the International
Maritime Organization adopted the Global Maritime Distress and Safety
System (GMDSS).

In the 1990's, countries around the world began closing down their
distress 500 kHz calling frequency watch which had been in use since
1912. The final 500 kHz message sent by the U.S. Coast Guard took
place from station NMN (Chesapeake Virginia) on April 1, 1995, and they
no longer monitor the frequency.


Most radio amateurs are not on ships.


So the validity of having a trained morse pool even 20 years ago
wasn't or shouldn't have been because other services used morse.
Interesting, did you make that comment when no-code was first proposed?

Even though the commercial world eliminated Morse code as a
communications medium many years ago, it has continued on the Amateur
bands because manual Morse proficiency was an international Amateur
Service requirement when operating on spectrum under 30 MHz.


There is no requirement that any radio amateur actually use Morse code.

Radio
amateurs use it by choice.


The statement isn't one of USE, it is based on a prior
international requirement...now gone, dead, caput, finito, over.

Other services are constrained by considerations of cost, particularly

labor
cost. They consider elimination of the need for a skilled radio operator

to be
progress. Amateurs do not.


You speak for "all" amateurs? Perhaps you should have said "some"
amateurs. In any case, learning morse does have a cost to each
and every amateur that does so. I see no reason to "mandate"
that cost upfront for access to amateur radio.

To most other radio services, radio is but a means to an end, not an end

in
itself. Amateur radio, by contrast, is radio for its own sake.


So?

II. Telegraphy requirement in the Amateur Service

There are many communications modes and emissions available to the
radio amateur and manual CW is just another one that certainly deserves
no special priority. The amateur radio operator examination process
does not require a practical demonstration in the ability to use any
other mode - even though more than a thousand modes and emissions are
available to the Amateur Service.


Except for single sideband radiotelphony, none of those other modes

approaches
Morse code in popularity on the amateur bands below 30 MHz.


The point still comes back to the fact that NO other mode
requires any skill test. It is that simple.

The international law previously required unspecified proficiency in
the International Morse code when the operation takes place in the
medium or high frequency bands. Because of technological advances,
this regulation has become inconsistent with the goals of the Amateur
Service since it provides a barrier to otherwise qualified individuals
who wish to experiment and communicate below 30 MHz. There can be no
doubt that the Morse code proficiency requirements have constituted an
unnecessary and artificial impediment to fuller use of the Amateur
Radio Service for many potential and existing amateurs.


The removal of the code test requirement for amateur licenses above 30 MHz

has
not resulted in a technological revolution in amateur radio on those
frequencies. There is no reason to expect one below 30 MHz.


I never bought any great significance to that argument either.

It appears that the reason that many (no-code) Technician amateurs are
not upgrading to license classes that require telegraphy suggests that
the Morse code requirement may be a significant barrier.


III. Morse code testing is a burden to the applicant

It should be noted that while today's personal computers can easily
send and receive telegraphy, the international Morse code "sent by hand
and received by ear" requirement continued as a worldwide fundamental
requirement for an amateur operator license until the recent actions by
the International Telecommunications Union.

The taking of the telegraphy examination is an unnecessary burden upon
the applicant. Experience has shown that it is more often than not a
very stressful experience for the examinee. With the elimination of
the international requirement for skill in manual telegraphy, there is
no longer any reasonable justification for requiring an applicant to
demonstrate this antiquated skill.

It is one that must be acquired through rote memorization of the
character meanings of some 43 combinations of audible dots and dashes:
26 letters of the alphabet, numerals 0 through 9, four punctuation
marks and three characters unique to CW. This must be followed by
numerous practice sessions until the necessary skill is achieved. Most
applicants, once they pass the code exam, never use the mode on the
amateur airwaves. And many, perhaps most, could not pass it again if
required to do so.


Written tests are a burden to the applicants, too.


Are YOU proposing an end to written tests?

Most radio amateurs do not construct or repair their own equipment, yet

they
are required to know something about how it works.


Because they "can" if they wanted to. If a non-coded ham gets
on the air to learn using morse with another ham...what's the probably
harm to others and or anyone compared to constructing or repairing
equipment themselves?

While it continues to serve some amateur operators well, as it did in
the early days of radio, it is now but one of many modes available to
amateur operators. The lack of interest in CW has turned many
prospective amateur operators away from the Amateur Service. IV.
Morse proficiency is not an indication of a quality operator

Some amateurs believe that the effort and sacrifice needed to learn
Morse code indicates a more dedicated and, therefore, a better
candidate for Amateur Radio. No evidence exists, however, that
supports a relationship between manual telegraphy proficiency and the
quality, desirability or motivation of the operator.


However, it should be noted that most of the Commission's enforcement

actions
for poor and illegal operating practices such as jamming,

obscenity/profanity,
failure to identify, operation outside of license privileges and failure

to
heed bandplans are against amateurs using voice modes, not Morse code or
digital modes.


More because saying "FU" via code isn't likly to be listened to by
any non-coded ham or non-ham.

What the Morse code licensing requirement does do, however, is to
greatly reduce the number of applicants operating in the medium and
high frequencies. Many people question why an individual with vast
knowledge in the electronics field should be excluded from operating on
HF spectrum due to a personal disinterest in the Morse code.

Continuing the use of Morse code proficiency as a means with which to
gauge "quality" or to limit the number of amateur radio operators
accessing public spectrum is certainly at odds with the FCC's mandate
to promote the wider use of radio and its commitment to the use of
emerging technologies.

V. Morse proficiency should not be required to operate in the voice

mode

It appears that most amateurs want to communicate in the voice mode.
It makes no sense from a regulatory perspective to require radio
amateurs to be Morse proficient when the greater majority of radio
amateurs do not desire to use that mode and there is no regulatory
reason for them to do so.


Since most amateurs do not desire to build their own equipment.....


Are you proposing not allowing hams to build their own?

The future of Amateur Radio encompasses many modes undreamed of just a
few years ago. Although manual telegraphy is a noble part of the
Amateur Radio's past, it is no longer the prime emission mode.

In short, the Commission should ensure that the amateur examination
elements are appropriate for the types of operation that will be
performed by the licensee.


Following this logic, the written exams should be stripped of anything a
licensee does not have an interest in.


ZIP - false, since any one subject CAN be ingnored and the test
applicant can still pass. Not so with the separate morse
test element.

VI. An unnecessary burden upon the VEC system

The administration of a CW examination imposes an unnecessary burden
upon the VE teams who must prepare and administer the CW examinations.
It requires extensive preparation and special equipment to prepare and
administer properly. It is often disruptive and unsettling to those
other examinees who are taking one of the written examinations within
the same room.

Under  97.507(d), the VEs must prepare and record a series of messages
sufficient to preclude any one message from becoming known to the
examinees. Each message must contain every one of the 43 telegraphy
characters at least once during period of at least 5 minutes. At the
prescribed speed of 5 words per minute, and at the prescribed 5
characters per word, the message is little more than 25 words in
length. In practice, it is a difficult task to compose a realistic
message under these limitations. It is also an unnecessary burden upon
the coordinating VECs since most of them also prepare telegraphy
examinations for their VE teams.

VII. An unnecessary burden upon the amateur service community

The amateur service community suffers from the loss to its ranks of a
large number of potentially excellent operators who are turned away
because of the CW requirement. Either because of lack of the requisite
aptitude for sending and receiving CW or because of an unwillingness to
spend the time acquiring a skill for which they find of no value to
them, they forego becoming amateur operators.


Yet the growth in amateur radio from 1990 to 2000, when there were both

medical
waivers and a nocodetest license, was almost identical to that from 1980

to
1990, when all amateur licenses required code tests and there were no

waivers..

Again, I don't care about or argue the growth side of it.

VIII. An unnecessary burden upon the FCC

Now that the international (treaty) Morse code requirement is optional,
the FCC can expect to receive numerous requests for waivers of the
Morse code examination due to applicant hearing and other medical
conditions in order to be compliant with the Americans with
Disabilities Act (ADA).


Yet it was not compliance with the ADA that resulted in medical waivers

for the
13 and 20 wpm code tests.


If it hadn't happened otherwise, the ADA would have entered the
picture by now.

When there were multiple code tests, the FCC cited the international
(treaty) requirement, as the reason that the five word-per-minute code
test could not be waived. This case no longer applies and the FCC will
have to develop procedures to guide both themselves and the VECs/VEs in
handling requests for code exam waivers that are certain to come.

Dealing with requests for a waiver of the code exam could create an
unnecessary burden on the FCC and VECs/VEs and consume an excessive
amount of time and resources. It seems illogical to require all
amateur examinees to pass a requirement that could be waived by the
actions of a physician. History has shown that physician-initiated
waiver requests have been very controversial in the Amateur Service.


By this logic, the written tests will also be a target of waiver actions.

For
example, profoundly deaf people are currently required to study for exams

which
include numerous questions on SSB and other voice modes even though there

is
little chance they will ever use those modes.


Pure speculation and, IMHO, not likly to ever happen.

IX. World Administrative Radio Conference 2003

The only changes made to the international Amateur Service regulations
over the last 75 years concern the frequency above which amateurs may
operate without Morse testing. At their Washington, DC conference in
1927, the ITU (then called the International Telegraph Union) allocated
frequency bands to the various radio services and established operating
guidelines and operator qualifications. It was deemed important that
Amateurs prove an ability to transmit and receive communications in
Morse signals since, at the time, radiotelegraphy was the primary means
of long range communication.

Since then, the administrations comprising International
Telecommunication Union have reviewed and voted to relax the Amateur
Service's mandatory Morse proficiency requirement at every
international conference capable of doing so.

In 1947 (Atlantic City), the ITU agreed that Morse proficiency should
only be required when the operation took place on frequencies below
1000 MHz (1 GHz.) At WARC-59, the 1959 World Administrative Radio
Conference, this level dropped to 144 MHz. A further reduction was
made at WARC-79 to 30 MHz. Consequently, up until recently, Article
S25.5 3 read: 25.5  3. 1) Any person seeking a license to
operate the apparatus of an amateur station shall prove that he is able
to send correctly by hand and to receive correctly by ear, texts in
Morse code signals. The administrations concerned may, however, waive
this requirement in the case of stations making use exclusively of
frequencies above 30 MHz.

At WRC-2003, the international Radio Regulation Article S25.5  3 was
revised to make the Morse code testing requirement a matter for each
licensing administration to decide for itself. Effective July 5, 2003,
Article S25.5 3 reads: 25.5  3. 1) Administrations shall
determine whether or not a person seeking a license to operate an
amateur station shall demonstrate the ability to send and receive texts
in Morse code signals.

X. Summary of NCVEC proposal to end Morse testing

The attached appendix contains a list of the rules that must be amended
if Morse code examinations are to be discontinued. These amendments
propose merely to end the manual telegraphy examination and to permit
Technician Class operators the same frequency privileges as those
enjoyed by Technician Class operators who have passed a code exam.

Therefore, the foregoing considered, NCVEC, the National Conference of
Volunteer Examiner Coordinators, respectfully requests that the
Commission issue a Notice of Proposed Rule Making at any early date,
proposing the rule changes set forth herein, and in the appendix
attached hereto.

Respectfully submitted,

NCVEC, National Conference of VECs
P.O. Box 565101, Dallas, Texas 75356


This proposal simply drops Element 1 without making any other changes.

Oddly
enough, if it were adopted, Technicians would gain a bit of 10 meter SSB.

Most
of the privileges Technicians would gain would be slices of 80, 40, 15 and

10
meter CW.


Start simple...then, if it makes sense, look at the overall licensing
levels, etc. Makes sense to me.

Cheers,
Bill K2UNK




  #10   Report Post  
Old August 3rd 03, 09:21 PM
N2EY
 
Posts: n/a
Default

In article , "Bill Sohl"
writes:

"N2EY" wrote in message
...
PETITION FOR RULE MAKING


The National Conference of Volunteer Examiner Coordinators (NCVEC) is
the umbrella organization comprised of the fourteen organizations
charged since 1984, under Section 97.519(a) of the rules of the Federal
Communications Commission, 47 CFR 97.519(a) to develop and administer
all Amateur Radio operator license testing and to electronically file
all successful license applications with the FCC. In total, the VECs
and their more than 30,000 VE teams have collectively administered
nearly two million examinations during the past twenty years and have
notified the FCC to issue approximately a million new and upgraded
Amateur Radio licenses.


The NCVEC is not, however, an organization where the VECs are elected, or
where
individual VE opinions were gathered or solicited.


So? Your point? Is that something that should call into question
the NCVEC as being invalid, illegal, or fattening?


The point is that the petition is NOT necessarily the opinion of the majority
of VEs or VECs. It was cooked up by a few of the top guys, who were not
elected.

Once a year, the various Volunteer Examiner Coordinator organizations
meet at their annual conference to discuss the various issues that
impact Amateur Radio operator testing. At their July 25, 2003, meeting
held with the FCC in Gettysburg, PA, the VECs overwhelmingly agreed
that Morse code testing should be immediately ended since it was now
possible to do so. It was also noted that countries have already begun
discontinuing Morse examinations. As a result the VECs voted to file
this Petition asking that the FCC take expedited action to allow them
to discontinue administering Element 1, the 5 words-per-minute
telegraphy examination as soon as possible.


No surprise there.

Pursuant to Section 1.405 of the Commission's procedural rules (47
C.F.R. 1.405), the NCVEC hereby respectfully requests that the
Commission issue a Notice of Proposed Rule Making at an early date
looking toward amendment of the rules governing the Amateur Radio
Service, 47 C.F.R. 97.1 et seq., as set forth herein and in the
attached Appendix.


No imagination, either.


When dis imagination or, for that matter, creativity have to be part
of the filling/process?


When someone truly has the interests of the ARS in mind, they will look at the
complete picture rather than take a narrow view. This is particularly important
in dealing with FCC because we have seen how long it takes them to do an
amateur service NPRM cycle.

The rule changes requested herein would terminate the telegraphy
examination requirement and permit existing Technician Class operators
to access HF spectrum as provided in 47 C.F.R.  97.301(e) without the
necessity of passing a Morse code examination. This request to
eliminate the Morse code (Element 1) examination does not necessarily
have the support of the ARRL Board since they have yet to develop a
position on the matter. In support of its petition, NCVEC states as
follows:


I. Introduction and Background

Since the turn of the century, the Morse code, invented by American
Samuel Morse and first used in 1844, has been the foundation of early
distress and safety communications. Although Morse code (or CW, as it
is commonly called) was the primary mode of communications from the
late 19th Century through the early 20th Century, it has all but become
obsolete in practically all other contemporary communication systems.
Due to the emergence of satellite and digital communications, manual
telegraphy is no longer used or required in any radio service other
than in the Amateur Service.


Amateur radio operators, however, use it extensively. On the HF/MF amateur
bands, it is the second most popular mode of communications, only slightly
behind SSB in popularity.


So?


So it makes sense that the things that should be tested for an amateur radio
license should be derived from what hams actually do, rather than what other
services do. Would you support questions on multiplex stereo FM on the ham
test? That mode is widely used in the broadcast service.

Hams also use differnent languages (Engish, Spanish, Chineese, etc.)
yet no one is mandated to use or be tested in any language other than
that of their "home" country.


How many US hams regularly use a language other than English on the ham bands?
Betcha it's far, far below the number using Morse/CW.

The Amateur Radio Service is unlike other radio services in its needs and
resources.


So are you sying amateur radio "needs" morse code testing? If so,
the burden of proof hasn't been met as per FCC R&O for 98-143.


All I'm saying is that comparisons with other services are meaningless because
the ARS is completely different.

Radiotelegraphy in the maritime service has been phased out in favor of
modern technology. The last vestige of manual telegraphy began being
phased out in the maritime service in 1988 when the International
Maritime Organization adopted the Global Maritime Distress and Safety
System (GMDSS).

In the 1990's, countries around the world began closing down their
distress 500 kHz calling frequency watch which had been in use since
1912. The final 500 kHz message sent by the U.S. Coast Guard took
place from station NMN (Chesapeake Virginia) on April 1, 1995, and they
no longer monitor the frequency.


Most radio amateurs are not on ships.


So the validity of having a trained morse pool even 20 years ago
wasn't or shouldn't have been because other services used morse.


The validity of the "trained pool" argument depends on what you mean by
"trained". There's a lot more to it than a 5 wpm code test.

Interesting, did you make that comment when no-code was first proposed?


When was that? 1975?

Even though the commercial world eliminated Morse code as a
communications medium many years ago, it has continued on the Amateur
bands because manual Morse proficiency was an international Amateur
Service requirement when operating on spectrum under 30 MHz.


There is no requirement that any radio amateur actually use Morse code.
Radio amateurs use it by choice.


The statement isn't one of USE, it is based on a prior
international requirement...now gone, dead, caput, finito, over.


The NCVEC statement does indeed say that the USE of Morse has continued because
of the TEST. It gives no other reason.

Here's the statement again:

"Even though the commercial world eliminated Morse code as a communications
medium many years ago, it has continued on the Amateur bands because manual
Morse proficiency was an international Amateur Service requirement when
operating on spectrum under 30 MHz."

The word "it" refers to "Morse code as a communications medium" in the above
sentence. NCVEC is saying that hams continue to USE Morse because of the TEST.

That's just plain not true.

Other services are constrained by considerations of cost, particularly
labor cost. They consider elimination of the need for a skilled radio

operator
to be progress. Amateurs do not.


You speak for "all" amateurs?


Yes. Do you think hams want to be eliminated?

Perhaps you should have said "some"
amateurs.


Perhaps there are a few who want to be eliminated, but not many.

The point is that for other services radio is a means to an end. To hams it's
an end in itself.

In any case, learning morse does have a cost to each
and every amateur that does so. I see no reason to "mandate"
that cost upfront for access to amateur radio.

Your opinion, very reasonably stated and noted.

To most other radio services, radio is but a means to an end, not an end
in
itself. Amateur radio, by contrast, is radio for its own sake.


So?


So amateur radio should not be judged nor structured the way other services
are.

II. Telegraphy requirement in the Amateur Service

There are many communications modes and emissions available to the
radio amateur and manual CW is just another one that certainly deserves
no special priority. The amateur radio operator examination process
does not require a practical demonstration in the ability to use any
other mode - even though more than a thousand modes and emissions are
available to the Amateur Service.


Except for single sideband radiotelphony, none of those other modes
approaches
Morse code in popularity on the amateur bands below 30 MHz.


The point still comes back to the fact that NO other mode
requires any skill test. It is that simple.


No other mode requires the acquisition of skills the average person is not
likely to have in order to use it.

The international law previously required unspecified proficiency in
the International Morse code when the operation takes place in the
medium or high frequency bands. Because of technological advances,
this regulation has become inconsistent with the goals of the Amateur
Service since it provides a barrier to otherwise qualified individuals
who wish to experiment and communicate below 30 MHz. There can be no
doubt that the Morse code proficiency requirements have constituted an
unnecessary and artificial impediment to fuller use of the Amateur
Radio Service for many potential and existing amateurs.


The removal of the code test requirement for amateur licenses above 30 MHz
has
not resulted in a technological revolution in amateur radio on those
frequencies. There is no reason to expect one below 30 MHz.


I never bought any great significance to that argument either.

Yet it has been made repeatedly in the past, and is made several times in the
NCVEC petition. What does it matter if someone is a Ph.D in EE, has a bunch of
patents, etc., etc., if all they're going to do as a ham is work SSB DX with a
manufactured transceiver and antenna?

It appears that the reason that many (no-code) Technician amateurs are
not upgrading to license classes that require telegraphy suggests that
the Morse code requirement may be a significant barrier.


III. Morse code testing is a burden to the applicant

It should be noted that while today's personal computers can easily
send and receive telegraphy, the international Morse code "sent by hand
and received by ear" requirement continued as a worldwide fundamental
requirement for an amateur operator license until the recent actions by
the International Telecommunications Union.

The taking of the telegraphy examination is an unnecessary burden upon
the applicant. Experience has shown that it is more often than not a
very stressful experience for the examinee. With the elimination of
the international requirement for skill in manual telegraphy, there is
no longer any reasonable justification for requiring an applicant to
demonstrate this antiquated skill.

It is one that must be acquired through rote memorization of the
character meanings of some 43 combinations of audible dots and dashes:
26 letters of the alphabet, numerals 0 through 9, four punctuation
marks and three characters unique to CW. This must be followed by
numerous practice sessions until the necessary skill is achieved. Most
applicants, once they pass the code exam, never use the mode on the
amateur airwaves. And many, perhaps most, could not pass it again if
required to do so.


Written tests are a burden to the applicants, too.


Are YOU proposing an end to written tests?


Nope. Just the opposite.

Most radio amateurs do not construct or repair their own equipment, yet
they
are required to know something about how it works.


Because they "can" if they wanted to.


BINGO!

So since a ham can operate Morse if he/she wants to, why is it unreasonable to
have a basic Morse test? There are probably far more US hams using Morse today
(by choice) than there are US hams today using homebrew stations (by choice).

Of course there are some like me who use Morse with a homebrew station...

If a non-coded ham gets
on the air to learn using morse with another ham...what's the probably
harm to others and or anyone compared to constructing or repairing
equipment themselves?


Depends on the situation. I can tell you, however, that the knoweldge required
to pass all of the writtens is only a small subset of that needed to homebrew
even a simple amateur station.

While it continues to serve some amateur operators well, as it did in
the early days of radio, it is now but one of many modes available to
amateur operators. The lack of interest in CW has turned many
prospective amateur operators away from the Amateur Service. IV.
Morse proficiency is not an indication of a quality operator

Some amateurs believe that the effort and sacrifice needed to learn
Morse code indicates a more dedicated and, therefore, a better
candidate for Amateur Radio. No evidence exists, however, that
supports a relationship between manual telegraphy proficiency and the
quality, desirability or motivation of the operator.


However, it should be noted that most of the Commission's enforcement
actions
for poor and illegal operating practices such as jamming,
obscenity/profanity,
failure to identify, operation outside of license privileges and failure
to
heed bandplans are against amateurs using voice modes, not Morse code or
digital modes.


More because saying "FU" via code isn't likly to be listened to by
any non-coded ham or non-ham.


In 35+ years of mostly-CW amateur radio operation I have NEVER heard anything
like that. Have you?

What the Morse code licensing requirement does do, however, is to
greatly reduce the number of applicants operating in the medium and
high frequencies. Many people question why an individual with vast
knowledge in the electronics field should be excluded from operating on
HF spectrum due to a personal disinterest in the Morse code.

Continuing the use of Morse code proficiency as a means with which to
gauge "quality" or to limit the number of amateur radio operators
accessing public spectrum is certainly at odds with the FCC's mandate
to promote the wider use of radio and its commitment to the use of
emerging technologies.

V. Morse proficiency should not be required to operate in the voice

mode

It appears that most amateurs want to communicate in the voice mode.
It makes no sense from a regulatory perspective to require radio
amateurs to be Morse proficient when the greater majority of radio
amateurs do not desire to use that mode and there is no regulatory
reason for them to do so.


Since most amateurs do not desire to build their own equipment.....


Are you proposing not allowing hams to build their own?


No - just the opposite.

But note that NCVEC doesn't see a problem in requiring theory in the writtens
because *some* hams *might choose* to homebrew....

The future of Amateur Radio encompasses many modes undreamed of just a
few years ago. Although manual telegraphy is a noble part of the
Amateur Radio's past, it is no longer the prime emission mode.

In short, the Commission should ensure that the amateur examination
elements are appropriate for the types of operation that will be
performed by the licensee.


Following this logic, the written exams should be stripped of anything a
licensee does not have an interest in.


ZIP - false, since any one subject CAN be ingnored and the test
applicant can still pass. Not so with the separate morse
test element.


That depends on what you mean by a "subject". If you define a "subject"
narrowly, that's true. But not if you define it as, say, "theory".

VI. An unnecessary burden upon the VEC system

The administration of a CW examination imposes an unnecessary burden
upon the VE teams who must prepare and administer the CW examinations.
It requires extensive preparation and special equipment to prepare and
administer properly. It is often disruptive and unsettling to those
other examinees who are taking one of the written examinations within
the same room.

Under  97.507(d), the VEs must prepare and record a series of messages
sufficient to preclude any one message from becoming known to the
examinees. Each message must contain every one of the 43 telegraphy
characters at least once during period of at least 5 minutes. At the
prescribed speed of 5 words per minute, and at the prescribed 5
characters per word, the message is little more than 25 words in
length. In practice, it is a difficult task to compose a realistic
message under these limitations. It is also an unnecessary burden upon
the coordinating VECs since most of them also prepare telegraphy
examinations for their VE teams.

VII. An unnecessary burden upon the amateur service community

The amateur service community suffers from the loss to its ranks of a
large number of potentially excellent operators who are turned away
because of the CW requirement. Either because of lack of the requisite
aptitude for sending and receiving CW or because of an unwillingness to
spend the time acquiring a skill for which they find of no value to
them, they forego becoming amateur operators.


Yet the growth in amateur radio from 1990 to 2000, when there were both
medical
waivers and a nocodetest license, was almost identical to that from 1980
to
1990, when all amateur licenses required code tests and there were no
waivers..


Again, I don't care about or argue the growth side of it.


If we drop the code test and don't get lots more new hams, then Element 1
wasn't really a barrier or burden. QED

VIII. An unnecessary burden upon the FCC

Now that the international (treaty) Morse code requirement is optional,
the FCC can expect to receive numerous requests for waivers of the
Morse code examination due to applicant hearing and other medical
conditions in order to be compliant with the Americans with
Disabilities Act (ADA).


Yet it was not compliance with the ADA that resulted in medical waivers
for the
13 and 20 wpm code tests.


If it hadn't happened otherwise, the ADA would have entered the
picture by now.


I disagree. But we can't dig up a dead King and ask him.

When there were multiple code tests, the FCC cited the international
(treaty) requirement, as the reason that the five word-per-minute code
test could not be waived. This case no longer applies and the FCC will
have to develop procedures to guide both themselves and the VECs/VEs in
handling requests for code exam waivers that are certain to come.

Dealing with requests for a waiver of the code exam could create an
unnecessary burden on the FCC and VECs/VEs and consume an excessive
amount of time and resources. It seems illogical to require all
amateur examinees to pass a requirement that could be waived by the
actions of a physician. History has shown that physician-initiated
waiver requests have been very controversial in the Amateur Service.


By this logic, the written tests will also be a target of waiver actions.
For
example, profoundly deaf people are currently required to study for exams
which
include numerous questions on SSB and other voice modes even though there
is
little chance they will ever use those modes.


Pure speculation and, IMHO, not likly to ever happen.


But it logically proceeds from the argument that people shouldn't have to learn
stuff they won't use.

IX. World Administrative Radio Conference 2003

The only changes made to the international Amateur Service regulations
over the last 75 years concern the frequency above which amateurs may
operate without Morse testing. At their Washington, DC conference in
1927, the ITU (then called the International Telegraph Union) allocated
frequency bands to the various radio services and established operating
guidelines and operator qualifications. It was deemed important that
Amateurs prove an ability to transmit and receive communications in
Morse signals since, at the time, radiotelegraphy was the primary means
of long range communication.

Since then, the administrations comprising International
Telecommunication Union have reviewed and voted to relax the Amateur
Service's mandatory Morse proficiency requirement at every
international conference capable of doing so.

In 1947 (Atlantic City), the ITU agreed that Morse proficiency should
only be required when the operation took place on frequencies below
1000 MHz (1 GHz.) At WARC-59, the 1959 World Administrative Radio
Conference, this level dropped to 144 MHz. A further reduction was
made at WARC-79 to 30 MHz. Consequently, up until recently, Article
S25.5 3 read: 25.5  3. 1) Any person seeking a license to
operate the apparatus of an amateur station shall prove that he is able
to send correctly by hand and to receive correctly by ear, texts in
Morse code signals. The administrations concerned may, however, waive
this requirement in the case of stations making use exclusively of
frequencies above 30 MHz.

At WRC-2003, the international Radio Regulation Article S25.5  3 was
revised to make the Morse code testing requirement a matter for each
licensing administration to decide for itself. Effective July 5, 2003,
Article S25.5 3 reads: 25.5  3. 1) Administrations shall
determine whether or not a person seeking a license to operate an
amateur station shall demonstrate the ability to send and receive texts
in Morse code signals.

X. Summary of NCVEC proposal to end Morse testing

The attached appendix contains a list of the rules that must be amended
if Morse code examinations are to be discontinued. These amendments
propose merely to end the manual telegraphy examination and to permit
Technician Class operators the same frequency privileges as those
enjoyed by Technician Class operators who have passed a code exam.

Therefore, the foregoing considered, NCVEC, the National Conference of
Volunteer Examiner Coordinators, respectfully requests that the
Commission issue a Notice of Proposed Rule Making at any early date,
proposing the rule changes set forth herein, and in the appendix
attached hereto.

Respectfully submitted,

NCVEC, National Conference of VECs
P.O. Box 565101, Dallas, Texas 75356


This proposal simply drops Element 1 without making any other changes.
Oddly
enough, if it were adopted, Technicians would gain a bit of 10 meter SSB.
Most
of the privileges Technicians would gain would be slices of 80, 40, 15 and
10
meter CW.


Start simple...then, if it makes sense, look at the overall licensing
levels, etc. Makes sense to me.


At that rate and the typical FCC NPRM cycle, a couple decades should do it.

73 de Jim, N2EY


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