RadioBanter - Low reenlistment rate

Dick Carroll wrote

Nicer than usual no-code page, Hans. It's empty!

Then your browser must be broken. I just went there and copied the
material quoted below. (This is just the first few paragraphs of the
proposal --- I am not endorsing the proposal, but found the
"re-enlistment rate" information troubling.)

73, Hans, K0HB

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of
Rulemaking under Part 97 of
the Communications Act of 1934,
as amended, to Revise License
Classes, Privileges, and
Examination Requirements Related
to the Amateur Radio Service

Docket No.__________

To: The Commission
PETITION FOR RULEMAKING
Submitted by:
Robert G. Rightsell, AE4FA
Post Office Box 1492
Lexington, SC 29071-1492
,

Harry A. M. Kholer, N0PU
9125 Arvin Place
St Louis, Mo 63123
,

Petitioners.

--------------------------------------------------------------------------------
1. Introduction

This petition addresses the following areas with respect to the
Amateur Radio Service: 1. Consolidation of license classes;
2. Frequency and Mode Privilege reallocation; and
3. Examination Requirements.

Petitioners have designed this Petition with the goal of reducing the
Commission's workload and streamlining the Commission's record-keeping
requirements, as well as those of Volunteer Examiner Coordinators,
Volunteer Examiners, licensees, and candidates for license.

Petitioners suggest that implementation of these proposals would
provide encouragement to all Amateur Radio Service licensees to take
advantage of educational opportunities and individual experimentation,
thus further enhancing their ability to contribute to the radio art.

2. Background and Discussion

2.1 Consolidation of License Classes

Between February 14, 1991 and July 5, 1991, the Commission granted
1,925 new Technician class licenses under the no-code provisions.
Petitioners' research shows that 1,880 of those licenses have not been
renewed or upgraded to a higher class license and are beyond the two
year grace period. That equates to a retention rate of only 2.3%.

Petitioners' further research using the Universal Licensing System
search function was blocked because licenses are shown as 'active'
until the expiration of the grace period, and there is no provision
for search using multiple date parameters. However, based on this
limited data, one of two conclusions may be reached. Either the
no-code licensing provision did not attract individuals with any depth
of interest in radio communications, or the lack of access to
frequencies below 30MHz frustrated those newly licensed individuals to
the point of giving up. Given either interpretation, Petitioners
suggest the no-code Technician experiment did in fact attract larger
numbers of people, as was initially hoped, but apparently did not
offer sufficient opportunity for them to expand their knowledge and
skills, nor did these individuals bring long-term benefit to the
Amateur Radio Service.

On December 30, 1999 Report and Order, the Commission stated, 'We
observe that the primary difference between the Advanced Class
operator license and the Amateur Extra Class operator license is not
the difficulty of the Amateur Extra Class written examination but,
rather, the 20 wpm telegraphy examination which, as we explain below,
we are eliminating as a requirement to obtain the Amateur Extra Class
operator license. We also agree with NCVEC that the difference in
authorized frequency privileges between the Advanced Class operator
license and the Amateur Extra Class operator license is minimal and
does not alone warrant maintaining two separate license classes in the
future.'

The Commission declined, at that time, to 'undertake a comprehensive
restructuring of the amateur service operating privileges and
frequencies' until the amateur community reached consensus.

The Commission also left orphaned the Novice class amateur radio
license.

Petitioners suggest there is overwhelming consensus in the amateur
community that these two orphaned classes should be integrated back
into the mainstream of the amateur community.

2.2 Frequency and Mode Privilege reallocation

On December 30, 1999 the Commission released its Report and Order
revising the Amateur Radio Service license structure and International
Morse code testing requirements. The Commission declined, at that
time, to 'undertake a comprehensive restructuring of the amateur
service operating privileges and frequencies' until the amateur
community reached consensus.

As stated in 2.1 Petitioners suggest there is overwhelming consensus
in the amateur community to merge the two orphaned classes. This
action will streamline the Commission's record keeping needs and
simplify the maintenance of frequency and mode privilege allocations.

Upon merging the Novice and Technician as well as the Advanced and
Amateur Extra license classes, considering the ITU action and the
growing consensus among the Amateur community, given the no-code VHF
only Technician experiment has attracted far fewer dedicated, long
term operators than desired, and noting that a significant number of
new entrants into the Amateur Radio Service have a strong interest in
new technologies and digital modes, it seems only reasonable to modify
the frequency and mode allocations for the new, consolidated,
Technician class.

Petitioners have examined the history of U.S. frequency allocation. It
appears that the Commission has always tried to protect the new,
inexperienced, operators from their own lack of experience by putting
their privileges away from the band edges and by limiting them in
power output. Examples of this are the Novice allocations on 80, 40,
and 15 meters and the Novice and Technician Plus allocations on the
10-meter Band. Since the HF spectrum is the area in which
international communications are prevalent, these allocations
minimized the possibility of interference to other services. The
amateur community generally agrees this procedure is in the best
interest of the Amateur Radio Service.

2.3 Examination Requirements

On December 30, 1999 the Commission released its Report and Order
revising the Amateur Radio Service license structure and International
Morse code testing requirements. At that time, the Commission reduced
the telegraphy examinations from three elements to one, and set the
number of written examination questions required at 35 for Technician,
35 for General, and 50 for Extra, and left to the National Council of
Volunteer Examiner Coordinators (NCVEC) the task of the specific mix
and makeup of written examination tests.

The Commission did, however, encourage the Amateur Service to strive
to 'attract technically inclined persons, particularly the youth of
our country, and encourage them to learn and to prepare themselves in
the areas where the United States needs expertise.'

Further, the Commission specifically addressed its desire to 'provide
an incentive for licensees to continue the educational opportunities
offered by amateur radio as The American Radio Relay League, Inc.
(ARRL) requests, will continue to provide an incentive for amateur
radio operators to advance their communication and technical skills,'
and to encourage individuals in the Amateur Service to become 'trained
operators, technicians, and electronic experts.' The Commission also
said, 'In reaching this decision, we note that one of the fundamental
purposes underlying our Part 97 rules is to accommodate the amateur
radio operator's proven ability to contribute to the advancement of
the radio art.?'

The ITU has, in its 2003 Conference, left to individual
administrations whether candidates for the Amateur Radio Service
should demonstrate proficiency in International Morse code.

The ITU also adopted the following new language in Provision 25.6:
'Administrations shall verify the operational and technical
qualifications of any person wishing to operate an amateur station.
Guidance for standards of competence may be found in the most recent
version of Recommendation ITU-R M.1544.'

There has been great debate in the amateur community over the
retention of code testing. Petitioners observe that, in most of these
discussions, the issue of technical competence arises as a major
point. There appear to be three groups in these discussions, one which
advocates complete elimination of code testing. A majority of this
group either advocates increasing the difficulty of written elements
or concedes that it is necessary. A second group advocates nothing
short of retaining code testing as a 'make or break' element. Most
members of this group agree the current written test elements are
seriously deficient. The third falls in the middle ground on the code
issue. Amateurs in this group also agree that the written testing
elements should be enhanced to adequately assess a candidate's
knowledge and ability.

Based on these observations, Petitioners see a need for continued
International Morse code testing, but do not believe code testing
should be the main determining factor. Similarly, Petitioners see a
need for more comprehensive written examinations.

Petitioners have attempted to objectively analyze activity levels for
the various modes in three categories, International Morse code (CW),
Phone (primarily SSB), and Digital (all types) on the high frequency
bands. The complete study, prepared by Mr. Walter B. Fair, W5ALT, is
included with his permission as Attachment A. The following paragraph
in the conclusion section of this report should be noted:

"Based on the analyses presented below, it appears that the CW issue
in ham radio is often based on emotion rather than fact. The data do
not indicate an overall decrease in CW activity. The argument being
used by CW opponents that CW is dying seems to have no merit. On the
other hand, the argument that relaxing the CW test requirement to 5
WPM would lead to the destruction of the Amateur Radio Service does
not seem to have merit, either. The data show that when the code
testing was relaxed in 2000, CW activity remained stable in the
following years. Therefore, if more newer hams started using SSB, the
same percentage also started using CW. I interpret that to mean that
most hams will use the mode that meets their objectives, whether it is
CW or not. Of course, there will always be vocal minorities in both
the pro and con CW camps."

Petitioners suggest as a single mode of operation International Morse
code is alive, well, and apparently used by a large portion of the
Amateur Community. Especially in light of the major role the CW mode
plays in international communications, Petitioners suggest that
eliminating International Morse code testing altogether would be a
tremendous disservice to the U.S. amateur community.

Following the elimination of Amateur Radio Service testing at
Commission Field Offices, the concept of Certificate of Successful
Completion of Examination (CSCE) was introduced. The system of CSCEs
is now pervasive, and presents a significant paperwork and
record-keeping burden on Volunteer Examiner Coordinators, Volunteer
Examiners, licensees, and candidates for license.

3. Scope of Proposals

3.1 Consolidation of license classes

3.1.1 As per paragraph 2.1, Petitioners suggest it is time to
consolidate the Novice and Technician and Technician Plus licenses
into one Technician license. This would allow the Commission to
simplify record keeping and bring the orphaned Novice licensees back
into the Commission's license progression scheme. The upgrade
procedure would be automatic immediately and the new license issued at
the normal renewal time.

3.1.2 As per paragraph 2.1, Petitioners further suggest it is time to
consolidate the Advanced and Amateur Extra licenses. This would also
simplify the Commissions record keeping and upgrade these operators
who have all passed examination elements with requirements higher
than, or equal to those required today. The upgrade procedure would be
automatic immediately and the new license issued at the normal renewal
time.

3.2 Frequency, Power, and Mode Privilege reallocation;

3.2.1 Petitioners recommend that the newly revised Technician license
should have privileges as outlined in paragraph 4.2 below. This allows
in general:

.. 1. 80 meters: CW and data privileges on 3600 though 3750 kHz. This
is an increase of 100 kHz of bandwidth and the addition of data modes
to the present Novice allocation.
2. 40 meters: CW and data privileges on 7100 through 7150 kHz. This
adds data modes to the existing Novice allocations.

3. 15 meters: CW and data privileges on 21100 through 21200 kHz. This
adds data modes to the existing Novice frequency allocations.

4. 10 meters: CW and data privileges on 28100 through 28300 kHz. This
represents no change to the existing Novice and Technician Plus
allocations.

5. 10 meters: CW and Voice privileges on 28300 through 28600 kHz. This
is an increase of 100 kHz of bandwidth to the existing Novice and
Technician Plus allocations.

6. Above 30 Mhz: All frequencies, modes, and power levels as contained
in the current regulations.

3.2.2 Petitioners recommend that power limitations be placed on the
newly consolidated Technician Class in the same fashion as has been
historically imposed on the lowest beginner class of operator license
in the allocated HF frequencies. This limitation protects other users
of the HF spectrum from inadvertent errors commonly made by the
inexperienced operator. Petitioners recommend a 200 Watt limit for the
Technician class license on all frequencies below 30 Mhz as indicated
in paragraph 4.2.3.

3.2.3 Petitioners recommend, upon merging the Advanced and Amateur
Extra license classes, that the newly revised Amateur Extra class be
assigned all those privileges allowed the present Amateur Extra class
license.

3.3 Examination Requirements

3.3.1 As per paragraph 2.3, Petitioners suggest it is time to review
and make certain changes to the Element 1 (International Morse code)
testing requirement. In light of the ITU's actions it is indeed time
to regard the International Morse code as another mode of operation
equal to but of no greater importance than any other mode. As
demonstrating competence in other modes is not necessary to gain
access the HF frequencies, it occurs to the Petitioners that it is
time to remove this as an absolute requirement. Petitioners suggest,
however, that International Morse code testing should be continued as
part of the overall license examination for good reason, as discussed
in Section 2.3.3.

3.3.2 It is believed by the Petitioners that the International Morse
code remains a viable, valuable, and popular mode. See the discussion
in 2.3 above. When all else fails in emergency circumstances,
International Morse code remains as the only useable option. CW is
also an "International Language", by which, peoples of the world who
have differing spoken languages can communicate efficiently.
Petitioners note that written examinations for all classes include
questions designed to ascertain a candidate's knowledge of various
modes. This petition proposes that, while written examination
questions are sufficient to evaluate a license candidate's familiarity
with the basic concepts of other modes, such testing is not sufficient
for International Morse code.

Petitioners recommend that testing of International Morse code be
continued but that such testing should be integrated into the overall
test score in a more equitable fashion. It is recommended that the
Element 1 test should be scored such that the longest string of
continuous characters should be counted (with numbers and punctuation
being weighted as two characters) and such count, up to a maximum of
24, should be then divided by two and the result added to the score of
the written examination. This test would be available to all
candidates for every class of license.

3.3.3 As per paragraph 2.3 it is further believed by Petitioners that
is time to increase the number of written test items required to
successfully indicate competence at all license levels.

Petitioners have analyzed current and previous question pools
developed by the NCVEC and found that the current examinations do not
assess candidates' required knowledge of technical matters and the
Commission Rules and Regulations as thoroughly as in the past. This
due, in large measure, to the limitation of actual test question
numbers for Technician and General at 35, and for Amateur Extra at 50.
To its credit, the NCVEC has responded to this limitation by greatly
expanding the number of questions in each question pool.

Petitioners suggest the actual test questions, however, have been
significantly more slanted toward procedures, and less toward
technical competence and regulations. This is due to the limitation on
the number of actual examination questions.

Petitioners present the following examples:

.. 1. Individuals who achieved the 1997 Technician license had passed
two written examination elements totaling 65 questions, of which
fifteen (23%) were in the area of Commission Rules. Technicians today
encounter a total of just 35 written examination questions, only five
(14%) of which are in the Commission Rules category. All five may be
answered incorrectly, plus four more in other areas, and the candidate
will still achieve a passing score.
2. Of the 65 total questions in the Novice and Technician examinations
in 1997, there were four questions dealing with propagation. In the
current 35 question Technician examination, there are only two.

3. The Novice and Technician examinations in 1997, combined, had ten
questions (15%) dealing with electronic theory and components. The
current Technician examination has just three (8%).

4. A person achieving a General class license in 1998 encountered a
total of 95 test questions. Of those, nineteen were in the Commission
Rules category. A person-achieving General today faces 70 questions,
eleven of which fall in that category.

5. The cumulative examinations necessary for a General class license
in 1998 contained seven questions dealing with propagation. The
cumulative examinations necessary for General today contain only five
propagation questions.

6. The 95 questions leading to a General class license in 1998
included thirteen (13%) on electronic theory and components. The 70
questions leading to General today include only six (8%).

Petitioners' comparative research of prior question pools was
incomplete because neither the NCVEC nor, apparently, any of its
entities maintain them as archive material. Fortunately, some of the
question pools of interest were recovered from non-official sources.
Future studies undertaken as part of rule making proceedings would
benefit from their prolonged availability.

The increasing complexity of the radio art, combined with the
elimination of Novice and Advanced licenses, have outstripped the
ability of a 35 question examination for Technician and General, and a
50 question examination for Amateur Extra to sufficiently evaluate a
candidate's operational and technical qualifications. Petitioners
suggest that increasing both the number of questions required for each
class and the minimum passing scores, as well as assuring a technical
and regulatory focus are reasonable solutions. The testing
requirements as outlined below would restore the number of examination
questions and the number of required correct answers to an
approximation of the pre-April 15, 2000 requirements for Technician,
General, and Amateur Extra licenses.

Petitioners have observed a widespread recognition in the amateur
community that the current examination structure allows individuals
who learn published question and answer material quickly to rapidly
advance in license class without gaining real understanding of the
underlying material. Therefore, this proposal incorporates a
requirement for minimum experience in each class of license prior to
advancing to the next. Petitioners suggest this will provide practical
experience, encourage experimentation and help develop well trained
operators, technicians, and electronic experts.

3.3.4 Petitioners suggest it is incumbent on the Commission to mandate
the specific mix of topics, number of questions, and minimum passing
requirement for all Amateur Radio Service written examinations. It is
not, however, necessary at this time for the Commission to develop the
actual question pools. This task could very well remain in the hands
of the NCVEC.

Petitioners recommend a written test length of forty-four questions
for the Technician license (each question scored as two points) and
eighty-eight questions for the General and Amateur Extra license (each
question having a value of one point), with questions to be divided
into six categories as indicated in paragraph 4.3.

The final score for the license examination would be the sum of the
Element 1 exam and the score on the written portion giving a total
possible of 100 points. A total cumulative score of 75 points would be
the minimum passing grade. This method of integrating the Element 1
test and the written examination allows two paths for progression
within the Amateur Radio Service; first, for the technically talented
individual to obtain an amateur license in the upper levels of the
service without the absolute necessity of learning the International
Morse code and second, the more traditionally skilled communicator to
receive credit for his extended capabilities, thus bringing into
balance the mandates of 47CFR97.1.

3.3.5 Given the composite nature of the examinations suggested by
Petitioners, there would no longer be a need to issue CSCEs, and to
continue their issuance would in fact be impractical.

3.3.6 Petitioners recognize there have been thousands of CSCE
documents issued by VEs and that the holders of these documents should
be credited for the hard work the CSCE represents. Petitioners
recommend that the holder of an Element 1 CSCE issued prior to the
date of the Commission's Order in this matter be credited with 12
points in lieu of the Element 1 examination. Petitioners further
recommend the holder of an element 3 or 4 CSCE issued prior to the
date of the Commission's Order in this matter be credited with 65
points in lieu of the respective examination.

3.3.7 Petitioners have analyzed the existing testing procedure and
believe this proposal offers the most balanced and seamless
integration approach possible. Considering the following scenarios, it
will be seen that it offers more options for individuals to enter the
Amateur Radio Service while assuring the individual has the knowledge
necessary to properly control a radio station with minimum opportunity
for causing interference to other services.

Candidates scoring the maximum 12 points in the Element 1 portion of
the composite examination will need 63 additional points to obtain a
license. For the Technician license this would require 32 out of the
possible 44 questions. This would be 72.7% correct necessary to pass.
For the General or Amateur Extra, it would require 63 out of the
possible 88 questions, or 71.5% correct to pass. Both figures indicate
that the candidate has at least minimum knowledge to properly control
an amateur station and should be eligible for a license.

Candidates scoring a zero in the Element 1 portion of the composite
examination will need 75 additional points to obtain a license. For
the Technician license this would require 38 out of the possible 44
questions, or 86.3% correct to pass. For the General or Amateur Extra,
the minimum correct would be 75 out of the possible 88 questions, or
85.2% correct to pass. Both figures indicate that the candidate has a
superior knowledge to properly control an amateur station and, though
he does not demonstrate any skill with International Morse code,
should be eligible for a license.

In the case of a CSCE Element 3 holder, the candidate has two options;
he may take the Element 1 portion of the composite examination and add
the score of this exam to his allowed 65 points for a total score.
Should this candidate fail to obtain the minimum necessary 10 points,
he may elect to take the new Element 3 portion of the composite
examination and use the sum of the scores on the Element 1 and the
Element 3 portions to qualify for a license.