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

Well said!

73, Leo

On 9 Oct 2003 14:13:43 -0700, (Hans K0HB)
wrote:

snip

It should be hurled aside with great force.

"Hans K0HB" wrote in message
om...
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

Mega Dittos. I especially like the "catch 22"
prohibition of new modes. Frankly I'm surprised
that Joe didn't think of that.

Cheers,
Bill K2UNK

"Bill Sohl" wrote


Mega Dittos. I especially like the "catch 22"
prohibition of new modes. Frankly I'm surprised
that Joe didn't think of that.

I sent a courtesy copy of my comments to the author of RM-10808. Here
is his response.

73, de Hans, K0HB
__________________________________________________ ______

RESPONSE FROM AH0A
__________________________________________________ ______

Thanks for taking the time to respond, although your last comment was
a bit
strong.

The idea behind the petition was to try to retain some "merit" badge
testing
and a "reward" for learning. I fail to understand why removing Morse
testing is any different from removing all aspects of RTTY knowledge
from
the written test, e.g. "T8A10. What would you connect to a transceiver
for
RTTY operation?". I've taught several courses in the last few years,
and
have come to the conclusion that so many different technologies are
very
difficult to get across in a three week course, and I question whether
it is
desirable to require it.

What is so special about Morse that it requires so much emotion? The
real
issue for those proposing to remove it is they want more Amateurs. If
the
market were growing fast enough, we would not see this much effort. I
felt
that my proposal to remove CW testing for phone privileges, but retain
it to
operate CW would be a compromise. How it could interfere in the
development
of amateur radio escapes me. It is less restrictive than current
rules.

I also thought that moving all testing requirements out of the FCC
would
make it more acceptable. The FCC clearly wants to get out of the
business
of regulating amateur radio. The question we amateurs need to address
is
what are the requirements to get a license? Questions about CW, RTTY,
SS,
EME, FM, repeaters, SSB, space communications, emergency
communications,
circuits, electric theory, regulations, etc. And which group of
amateurs
gets to make the decision?

Anyway I want to assure you I that I put thought into the petition and
sincerely believe that CW testing for CW privileges was a compromise.

Joe Speroni
Honolulu

"Hans K0HB" wrote in message
om...
"Bill Sohl" wrote


Mega Dittos. I especially like the "catch 22"
prohibition of new modes. Frankly I'm surprised
that Joe didn't think of that.

I sent a courtesy copy of my comments to the author of RM-10808. Here
is his response.

73, de Hans, K0HB
__________________________________________________ ______

RESPONSE FROM AH0A
__________________________________________________ ______

Thanks for taking the time to respond, although your last comment was
a bit strong.

The idea behind the petition was to try to retain some "merit" badge
testing

It's not govt's legitimate purpose to have "merit badge testing."

and a "reward" for learning. I fail to understand why removing Morse
testing is any different from removing all aspects of RTTY knowledge
from the written test, e.g. "T8A10. What would you connect to a
transceiver for RTTY operation?".

Clearly AH0A can't understand (or accept) that the RTTY example
is "theoretical knowledge" and the Morse test is a test of a mechanical
skill ... while I don't advocate it, a touch-typing test would be more
relevant to the future of ham radio than a Morse test.

[snip]

Anyway I want to assure you I that I put thought into the petition and
sincerely believe that CW testing for CW privileges was a compromise.

It appears that AH0A either did not read the R&O in 98-143 and the
denials of the Petitions for Reconsideration that were filed, or he didn't
understand/accept what the FCC clearly said.

Carl - wk3c

Carl R. Stevenson wrote:
"Hans K0HB" wrote in message
om...

"Bill Sohl" wrote


Mega Dittos. I especially like the "catch 22"
prohibition of new modes. Frankly I'm surprised
that Joe didn't think of that.

I sent a courtesy copy of my comments to the author of RM-10808. Here
is his response.

73, de Hans, K0HB
________________________________________________ ________

RESPONSE FROM AH0A
________________________________________________ ________

Thanks for taking the time to respond, although your last comment was
a bit strong.

The idea behind the petition was to try to retain some "merit" badge
testing


It's not govt's legitimate purpose to have "merit badge testing."

Seems to me that the amateur should be trusted to do the needed work to
get on the air with whatever method he or she chooses. The test should
reflect the level needed to gain that trust.

For me to get on for example, PSK31, I simply built an interface to
connect the computer to the rig. To have to be tested on that would be a
waste of time.

Odd that the proposer of that seemed to be worried about how much
burden was upon the VE's. his proposal would amount to a huge increase
in work for them. But then he seemed to say they could refuse to test
applicants except in element 2,3,4!



- Mike KB3EIA -

In article , "Carl R. Stevenson"
writes:

and a "reward" for learning. I fail to understand why removing Morse
testing is any different from removing all aspects of RTTY knowledge
from the written test, e.g. "T8A10. What would you connect to a
transceiver for RTTY operation?".

Clearly AH0A can't understand (or accept) that the RTTY example
is "theoretical knowledge" and the Morse test is a test of a mechanical
skill ...

You mean "a practical skill".

Both are valuable to the radio amateur. Whether either should be tested is a
matter of opinion, nothing more.

But if a person has no interest in RTTY, why should that person be subjected to
questions on the subject?

Why can't a ham be trusted to learn about RTTY if/when the desire to use that
mode arises? RTTY is "just another mode", is it not? There's no requirement for
any ham to ever use it.

while I don't advocate it, a touch-typing test would be more
relevant to the future of ham radio than a Morse test.

Why touch-typing? Isn't hunt-and-peck good enough?

5 wpm code is like being able to hunt-and-peck type at 10 wpm, not
touch-typing.

[snip]

Anyway I want to assure you I that I put thought into the petition and
sincerely believe that CW testing for CW privileges was a compromise.

It appears that AH0A either did not read the R&O in 98-143 and the
denials of the Petitions for Reconsideration that were filed, or he didn't
understand/accept what the FCC clearly said.

Or maybe he just disagrees. FCC's decisions are simply FCC opinion, not some
form of absolute proof. (Note what has happened to FCC's decision on broadcast
media ownership rules. While something like that won't happen to the amateur
rules, it proves the point).

Of course it's clear from FCC actions that any petition that *increases*
testing complexity is going to have a very very small chance of being acted
upon by FCC.

73 de Jim, N2EY

"N2EY" wrote in message
...
In article , "Carl R. Stevenson"
writes:

and a "reward" for learning. I fail to understand why removing Morse
testing is any different from removing all aspects of RTTY knowledge
from the written test, e.g. "T8A10. What would you connect to a
transceiver for RTTY operation?".

Clearly AH0A can't understand (or accept) that the RTTY example
is "theoretical knowledge" and the Morse test is a test of a mechanical
skill ...

You mean "a practical skill".

No, I meant "mechanical skill." (touch typing would be in the same
category ...)

Both are valuable to the radio amateur. Whether either should be tested is
a
matter of opinion, nothing more.

But if a person has no interest in RTTY, why should that person be
subjected to
questions on the subject?

Why can't a ham be trusted to learn about RTTY if/when the desire to use
that
mode arises? RTTY is "just another mode", is it not? There's no
requirement for
any ham to ever use it.

There is an ITU-R Recommendation that deals with the sorts of
THEORETICAL knowledge that hams should possess ... IIRC,
it's ITU-R Recommendation M.1544 ...

That recommendation is consistent with the basis and purpose
of the ARS, both as defined by the FCC and the ITU.

While not strictly mandatory, it is provided as "good advice to
administrations" on what sorts of theoretical knowledge hams
should possess.

Carl - wk3c

In article ,
(Hans K0HB) writes:

_________________________________________________ _______

RESPONSE FROM AH0A
_________________________________________________ _______

Thanks for taking the time to respond, although your last comment was
a bit
strong.

Do ya think?

73 de Larry, K3LT

Bill Sohl wrote:

Mega Dittos. I especially like the "catch 22"
prohibition of new modes. Frankly I'm surprised
that Joe didn't think of that.

The proposal in toto doesn't show much evidence of thought.

- Mike KB3EIA -