NCI filed Petition for Rulemaking Aug. 13
 

Hello all,

I just got back tonight from several days of meetings
in Washington.

Wed. when I arrived in Washington, one of the first things
I did was file NCI's Petition for Rulemaking with the FCC.

It is available in .pdf format at http://www.nocode.org
under the "Articles" link ...

Some will undoubtedly say "What took you so long?"

The answer is simply "We wanted to do the best possible
job of getting it right."

73,
--
Carl R. Stevenson - wk3c
Grid Square FN20fm
http://home.ptd.net/~wk3c
------------------------------------------------------
NCI-1052
Executive Director, No Code International
Fellow, The Radio Club of America
Senior Member, IEEE
Member, IEEE Standards Association
Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
Chair-elect, Wi-Fi Alliance Regulatory Committee
Co-Chair, Wi-Fi Alliance Legislative Committee
Member, QCWA (31424)
Member, ARRL
Member, TAPR
Member, The SETI League
------------------------------------------------------
Join No Code International! Hams for the 21st Century.
Help assure the survival and prosperity of ham radio.
http://www.nocode.org

"N2EY" wrote in message
om...
"Carl R. Stevenson" wrote in message
...

NCI's Petition for Rulemaking with the FCC.

It is available in .pdf format at http://www.nocode.org
under the "Articles" link ...

OK, let's cut to the chase.

Obviously the main request is to dump Element 1 ASAP. And there's
probably lots of reasons given for doing so, including the
Commission's own words "no regulatory purpose".

But what else was in the petition?

I gave you a URL where you could read it ...


Some will undoubtedly say "What took you so long?"

The answer is simply "We wanted to do the best possible
job of getting it right."

What did it take - six weeks? Not really long at all. Plus there was
always the chance FCC would have simply dumped Element 1 on its own,
instead of doing the whole NPRM thing.

What surprises me personally is that NCI didn't have a proposal ready
to go before WRC-03 even began. But that's all water under the bridge
now.

There was some question as to whether S25.5 would be suppressed
or modified (as it was) to eliminate the Morse requirement ... that
uncertainty made us decide to see the final outcome before developing
a final strategy/proposal.

As you have pointed out, Carl, FCC hasn't even given any of the
proposals an RM number yet. And it's reasonable to assume there will
be more proposals - from NCVEC, ARRL, and other groups. FCC may assign
numbers, or they may take ideas from each one and produce an NPRM.

NCVEC already filed a petition, as have several individuals.

From a meeting I had at FCC on Thursday, the indication is that
they will lump them all together in whatever course of action they
decide to take.

ARRL doesn't need to file a petition on the Morse issue, unless, of
course, they wise up and decide to ask the FCC to eliminate Morse
testing ASAP so they won't continue to alienate a portion of the
US amateur population that's larger than their current total membership :-)
(They don't need to file a petition to keep code testing, because that
is the status quo ...)

And of course those wheels turn slowly.

We shall see ...

73,
--
Carl R. Stevenson - wk3c
Grid Square FN20fm
http://home.ptd.net/~wk3c
------------------------------------------------------
NCI-1052
Executive Director, No Code International
Fellow, The Radio Club of America
Senior Member, IEEE
Member, IEEE Standards Association
Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
Chair-elect, Wi-Fi Alliance Regulatory Committee
Co-Chair, Wi-Fi Alliance Legislative Committee
Member, QCWA (31424)
Member, ARRL
Member, TAPR
Member, The SETI League
------------------------------------------------------
Join No Code International! Hams for the 21st Century.
Help assure the survival and prosperity of ham radio.
http://www.nocode.org

ARRL doesn't need to file a petition on the Morse issue, unless, of
course, they wise up and decide to ask the FCC to eliminate Morse
testing ASAP so they won't continue to alienate a portion of the
US amateur population that's larger than their current total membership :-)
(They don't need to file a petition to keep code testing, because that
is the status quo ...)

Well would there be much of a point in submitting a petition that would
be a duplication of
those already submitted? I'd just as soon let them focus on BPL....




And of course those wheels turn slowly.



We shall see ...

73,

"Dee D. Flint" wrote in message
gy.com...

No matter what stance the ARRL takes or no stance at all, they will
alienate
a portion of the US amateur population [CRS insert ... I think you meant
to
put a "larger" here] than their membership. The number of
non-ARRL members supporting code testing is larger than ARRL's membership
as
well as the group opposing code testing.

How did you arrive at that pseudo-fact?

The various surverys that have been taken indicate that the ham community
is
about 50/50 on this issue. That seems to hold true inside the ARRL
membership as well as outside it. Thus the ARRL will "alienate" half the
US
ham population no matter what stance they take.

The "various surveys" have all been self-selecting and have no scientific
validity.

Plus, they are all several years old and the demographic and thoughts have
changed a lot since "restructuring."

If you look at the numbers of licensees with less than General class
licenses,
do you really believe that anything approaching 50% of them are in favor
of continued Morse testing?

I seriously doubt it ...

Those licensees alone outnumber the ARRL's entire current membership.
Also, many current ARRL members (and a lot of NCI's members are
ARRL members, too), including holders of General, Advanced, and Extra
class licenses oppose continued Morse testing.

Have you read the NCI Petition? If not, I would suggest you read it
with an open mind and give due consideration to its content.

Carl - wk3c

"Carl R. Stevenson" wrote in message
...

"Dee D. Flint" wrote in message
gy.com...

No matter what stance the ARRL takes or no stance at all, they will
alienate
a portion of the US amateur population [CRS insert ... I think you meant
to
put a "larger" here] than their membership. The number of
non-ARRL members supporting code testing is larger than ARRL's
membership
as
well as the group opposing code testing.

How did you arrive at that pseudo-fact?

The size of the ARRL membership and its demographics is documented. The
size and demographics of the overall ham population are also documented.
Anyone can do the math.


The various surverys that have been taken indicate that the ham
community
is
about 50/50 on this issue. That seems to hold true inside the ARRL
membership as well as outside it. Thus the ARRL will "alienate" half
the
US
ham population no matter what stance they take.

The "various surveys" have all been self-selecting and have no scientific
validity.

Plus, they are all several years old and the demographic and thoughts have
changed a lot since "restructuring."


There have been internet surveys within the past year. Although they have
all been "self-selecting", it still shows a pretty even split. It's the data
that is available to us at this time.

If you look at the numbers of licensees with less than General class
licenses,
do you really believe that anything approaching 50% of them are in favor
of continued Morse testing?

I seriously doubt it ...


Based on the Techs I know, it's possible. But that is not the point. The
available data, although limited and not of the best quality, still
indicates that overall there is a 50/50 split.

And do you really believe that all Techs and down want to ditch the code
test and all Generals and up want to keep it? That's not a valid assumption
at all.

Those licensees alone outnumber the ARRL's entire current membership.
Also, many current ARRL members (and a lot of NCI's members are
ARRL members, too), including holders of General, Advanced, and Extra
class licenses oppose continued Morse testing.

Do you really believe that the ARRL's membership includes no Technicians?
Just as in the overall ham population, the number of members with less than
General class licenses is approximately 50%.


Have you read the NCI Petition? If not, I would suggest you read it
with an open mind and give due consideration to its content.

Carl - wk3c


I made no comment on the NCI petition. My comments were simply to
demonstrate that the ARRL is in a position where it may not even be
reasonable for them to take a stance either for or against code testing.
With the nearly even split within the ARRL, any position that they take
could alienate approximately half the hams in their own membership let alone
the overall ham community. How does this become a comment on the NCI
petition?

Dee D. Flint, N8UZE

"Carl R. Stevenson" wrote in message ...
"N2EY" wrote in message
om...
"Carl R. Stevenson" wrote in message
...

NCI's Petition for Rulemaking with the FCC.

It is available in .pdf format at http://www.nocode.org
under the "Articles" link ...

OK, let's cut to the chase.

Obviously the main request is to dump Element 1 ASAP. And there's
probably lots of reasons given for doing so, including the
Commission's own words "no regulatory purpose".

But what else was in the petition?

I gave you a URL where you could read it ...

That's not what I asked.

Here's the answer, to save others the bother of reading 20 pages to
get the answer to my question:

NOTHING.

The NCI petition consists of a request to drop Element 1 without
further delay or discussion and give Techs the same privileges as Tech
Pluses. No other changes proposed. Most of the 20 pages is supporting
reasons to make the change.

Some will undoubtedly say "What took you so long?"

The answer is simply "We wanted to do the best possible
job of getting it right."

What did it take - six weeks? Not really long at all. Plus there was
always the chance FCC would have simply dumped Element 1 on its own,
instead of doing the whole NPRM thing.

What surprises me personally is that NCI didn't have a proposal ready
to go before WRC-03 even began. But that's all water under the bridge
now.

There was some question as to whether S25.5 would be suppressed
or modified (as it was) to eliminate the Morse requirement ... that
uncertainty made us decide to see the final outcome before developing
a final strategy/proposal.

99% of what was in the petition would have been the same regardless.

As you have pointed out, Carl, FCC hasn't even given any of the
proposals an RM number yet. And it's reasonable to assume there will
be more proposals - from NCVEC, ARRL, and other groups. FCC may assign
numbers, or they may take ideas from each one and produce an NPRM.

NCVEC already filed a petition, as have several individuals.

It's clear NCVEC isn't done yet. They're talking about other changes
too.

From a meeting I had at FCC on Thursday, the indication is that
they will lump them all together in whatever course of action they
decide to take.

In terms of requested rules changes, the NCI and NCVEC petitions are
essentially identical.

ARRL doesn't need to file a petition on the Morse issue, unless, of
course, they wise up and decide to ask the FCC to eliminate Morse
testing ASAP so they won't continue to alienate a portion of the
US amateur population that's larger than their current total membership :-)

Who is this alienated population? You can't mean NCI members, because
they are less than 1% of US hams.

(They don't need to file a petition to keep code testing, because that
is the status quo ...)

They may want changes other than elimination of Element 1.

And of course those wheels turn slowly.

We shall see ...

You in The Pool yet? (see rrap thread by that name)


73 de Jim, N2EY

"N2EY" wrote in message
m...
You in The Pool yet? (see rrap thread by that name)


73 de Jim, N2EY

Hey Jim, can I change my response to The Pool? My new answer is NEVER! I
think they're going to grant Techs HF privies by allowing them on the
Novice/Tech "+" sub-bands and leave it at that. Element 1 lives on as a
requirement for General and Extra.

--
73 de Bert
WA2SI

"Carl R. Stevenson" wrote in message
...

"Dee D. Flint" wrote in message
gy.com...

No matter what stance the ARRL takes or no stance at all, they will
alienate
a portion of the US amateur population [CRS insert ... I think you meant
to
put a "larger" here] than their membership. The number of
non-ARRL members supporting code testing is larger than ARRL's
membership
as
well as the group opposing code testing.

How did you arrive at that pseudo-fact?

Dee, please allow me.

http://www.speroni.com/FCC/

The various surverys that have been taken indicate that the ham
community
is
about 50/50 on this issue. That seems to hold true inside the ARRL
membership as well as outside it. Thus the ARRL will "alienate" half
the
US
ham population no matter what stance they take.

The "various surveys" have all been self-selecting and have no scientific
validity.

http://www.eham.net/survey/539

Gee Carl, you're right. It's NOT 50%. Out of 5,020 votes, PCTA got 62% while
NCTA got 33%. I'll take that split, Dee. ;-)

Shall we try QRZ...?

Plus, they are all several years old and the demographic and thoughts have
changed a lot since "restructuring."

Late December, 2002 isn't "several years old," Carl.

If you look at the numbers of licensees with less than General class
licenses,
do you really believe that anything approaching 50% of them are in favor
of continued Morse testing?

Yes, I do.

--
73 de Bert
WA2SI

"Dee D. Flint" wrote in message
gy.com...

"Carl R. Stevenson" wrote in message
...


[snipped the unresolvable debate about survey validity, etc.]

Have you read the NCI Petition? If not, I would suggest you read it
with an open mind and give due consideration to its content.

Carl - wk3c


I made no comment on the NCI petition.

I didn't mean to imply that you did ... just encouraged you to read
it and give it due consideration.

My comments were simply to
demonstrate that the ARRL is in a position where it may not even be
reasonable for them to take a stance either for or against code testing.
With the nearly even split within the ARRL, any position that they take
could alienate approximately half the hams in their own membership let
alone
the overall ham community.

I agree that the ARRL is "between a rock and a hard place" with respect to
the split in their existing membership. However, outside of their
membership
(in the 75% of US hams who are NOT members of the ARRL), I believe
that the demographic is heavily tilted towards the no code test side ...
thus,
I believe that the ARRL stands to pick up more members than they stand
to lose if they take a position that it's time for Morse testing to go.
(Not
Morse use, not taking away spectrum where Morse can be used, just the
test requirement ...)


How does this become a comment on the NCI petition?

It didn't, and as I said above, I didn't mean to imply that it did.

Carl - wk3c

"N2EY" wrote in message
m...
"Carl R. Stevenson" wrote in message
...
"N2EY" wrote in message
om...
"Carl R. Stevenson" wrote in message
...

NCI's Petition for Rulemaking with the FCC.

It is available in .pdf format at http://www.nocode.org
under the "Articles" link ...

OK, let's cut to the chase.

Obviously the main request is to dump Element 1 ASAP. And there's
probably lots of reasons given for doing so, including the
Commission's own words "no regulatory purpose".

But what else was in the petition?

I gave you a URL where you could read it ...

That's not what I asked.

Here's the answer, to save others the bother of reading 20 pages to
get the answer to my question:

NOTHING.

Jim,

You say "NOTHING" ... but in the following paragraphs you admit
that "Most of the 20 pages is supporting reasons to make the change."
I think that's important information for folks to consider ... that's why
I encourage folks to actually READ and consider the NCI Petition,
rather than relying on your "5 cent synopsis."

Why do you want to "save others the bother" of reading the Petition?
(Could it be that you find the arguments so compelling that you don't
WANT others to read them???)

The NCI petition consists of a request to drop Element 1 without
further delay or discussion and give Techs the same privileges as Tech
Pluses. No other changes proposed. Most of the 20 pages is supporting
reasons to make the change.

As you have pointed out, Carl, FCC hasn't even given any of the
proposals an RM number yet. And it's reasonable to assume there will
be more proposals - from NCVEC, ARRL, and other groups. FCC may assign
numbers, or they may take ideas from each one and produce an NPRM.

NCVEC already filed a petition, as have several individuals.

It's clear NCVEC isn't done yet. They're talking about other changes
too.

That's their business ... NCI is focused on the Morse test issue and
is not proposing more sweeping changes that are outside of our
charter ...

Carl - wk3c