Joe Speroni, AH0A, has introduced a looney-tune petition, reminiscent
of Bob Wexelbaum, W2ILP "Amateur Radio Needs More Tests".

Below is my comment to the FCC.

73, de Hans, K0HB

-------

Before the
Federal Communications Commission
Washington, DC 20554

In the Matter of )
)
Amendment of Part 97 of the Commission's ) RM-10808
Rules to Drergulate Testing for Non-Voice )
Mode Allocation for Amateur Radio Licenses )


To: The Commission

PERSONAL COMMENTS OF HANS BRAKOB, K0HB



OVERVIEW

These comments are submitted in response to the petition of Joseph
Speroni (AH0A) which requests changes in the qualifications and
testing of applicants for new or upgraded licenses in the Amateur
Radio Service.

I. Discussion:

The instant petition requests the elimination of Element 1
(5WPM Morse code test) from the required test for General
and/or Extra Class licenses in the Amateur Radio service,
and goes on to request that the written examinations (elements
2, 3, and 4) be stripped of all mode-related questions except
those pertaining to Phone operation. Persons licensed under this
scheme would only be authorized to use Phone emissions, unless
they had additionally passed examinations related to other modes.

Petitioner further proposes that operation in ARES (Amateur
Radio Emergency Service) would be restricted to licensees who
had passed a written examination on that subject.

Petitioner also proposes that Volunteer Examiners would only
be required to administer the basic written examinations (elements
2, 3, and 4) and could decline to administer any of the proposed
mode-related examinations if they felt it were burdensome to them.


II. Comments:

I agree with the proposal to remove the requirement for a Morse
test (element 1) from the Amateur Radio Service rules.

However, I disagree with the remainder of his proposal.

Key to the concept of amateur radio regulation is the permission
(indeed encouragement) to tinker, experiment, and try different
(dare I say "sometimes new") things.

Under a system where "you can't use a mode until you've passed
a test on that mode" amateur radio experimentation would be
dramatically inhibited. The development of NEW modes of amateur
radio communications would in fact be PROHIBITED under a Catch-22
situation where "you can't play with it if you haven't been tested
and if it hasn't been developed yet we can't write test questions".

The current regulatory environment for Amateur Radio properly
allows significant latitude in selection of operating modes
and communications techniques, and the historical tendency of
the Commission to relax restrictions on new modes should be
continued, indeed accelerated.

All of the above aside, the proposal is fatally flawed in three
Regards:

1) Effective enforcement (detecting operators operating
outside their authorized mode) would be virtually impossible.

2) Allowing VEC's to pick-and-choose what tests they choose
to administer would deprive applicants in those localities
of reasonable access to the full range of amateur radio
activities.

3) Requiring a separate passing an examination to engage
in RACES/ARES activities would cripple the ability of the
Amateur Radio Service to adequately respond to the needs
of the public when our services are required in emergency
communications scenarious.

In summary, this petition should not be tossed aside lightly.
It should be hurled aside with great force.

Respectfully submitted,

H. Hans Brakob, K0HB
1610 Weston Lane
Plymouth, MN 55447