In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY) writes:


In article , Paul W. Schleck
writes:

In (N2EY)
writes:


In article om, "Dee D.
Flint" writes:

Basically I think the ARRL Board knows that the free upgrades means that
their proposal probably will not be adopted in this form. The FCC has
never
gone along with free upgrades before and there is no evidence that they
would do so now. However, I believe they tossed it in as another idea
for
the FCC to consider in developing whatever the FCC decides to do, if they
decide to do anything at all.

That's probably correct, Dee. And that's what bothers me!

As you say, FCC has never done free upgrades, and the last time the issue
came
up (98-143), the ARRL proposal was for existing Novices (!) and Tech
Pluses
to
get free upgrade to General. Of course, FCC said "no way", and has had no
problem whatever keeping the closed-to-new-issues classes in their
database.

So why propose something FCC obviously isn't going to do? Just wastes
everybody's time.

More important, it diverts attention from the other issues.

oh wait, I think I just answered my own question...;-)

73 de Jim, N2EY

I brought this subject up with someone in the League. This exact
thread, actually. I was told that the ARRL BoD sincerely believes (take
at face value, or not) that failure to upgrade licensees in the FCC R&O
for WT 98-143 was not a final "no" answer.

Maybe it wasn't. But are such freebies really a good idea?

It may be a realistic, and pragmatic, idea when considered against the
pros and cons:

Cons:

Provides a "free upgrade" to those that haven't explicitly tested for
it.

That's one. There are others:

- Allowing a free upgrade is proof that the material in the test which is not
taken is not necessary for the privileges.

To quote from the ARRL's FAQ on their proposal:

http://www.arrl.org/news/restructuring2/faq.html

"The fact is that the examination bar has never been at a uniform height
over ham radio's nearly 100-year history."

Were you also opposed to giving pre-1917 hams a waiver for the 20 WPM
code test?

- Amateurs who miss the one time upgrade have to take more tests than those
who didn't. How do we justify that?

It's called "grandfathering," which is done in more regulatory contexts
than can possibly be named here. Due to the need for certainty in the
law, it is nearly always based on hard cutoff dates. Technologies,
practices, and people change over the very long timeline that laws and
regulations are required to cover. It is not possible to predict the
future with certainty, so laws and regulations must change to reflect
current knowledge. It is also impractical for society to retest,
recertify, or revalidate every existing entity against current
requirements.

The web site for Malvern Instrumentation gives a good definition of
grandfathering in a technical context:

"Grandfathering is the practice of claiming exemption of older systems
from validation regulations and requirements on the basis that these
systems have proved their reliability by adoption for a long period of
time by a large user base."

Grandfathering in the context of ham radio recognizes that existing hams
have not only passed the tests in effect at the time, sometimes topics
not covered presently (Morse code, drawing circuit diagrams, etc.), but
have also gained experience beyond their initial exam topics. It is a
fair, and pragmatic, distinction between existing hams and entry-level
ones. Quoting again from the FAQ document:

"Passing any amateur examination does not magically result in a good
operator. It's just the key to the kingdom, so to speak. Experience and
good mentoring create skillful and knowledgeable operators, not the
relative difficulty or ease of the test."

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

- Decreased reason for more than half of all hams to upgrade by testing.

No proposal is perfect. Weigh this one against the pros.


Pros:

Avoids having to wait until the last Advanced class license expires to
refarm the Advanced phone bands.

Why does that have to be done at all?

So, are you advocating not refarming the Advanced phone bands even
*after* the last Advanced class license expires? Yeah, that's a
semantic nit-pick over what you wrote above, but then so is "You mean
the BoD. I'm the ARRL too, remember?" that you wrote below.

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus. That's still a long time in FCC
enforcement (and VEC administration) years. Even if you argue that FCC
action on further restructuring will take most of that six years anyway,
there are still all those Novice and Advanced class licenses that will
likely exist in the database for decades to come.

Why not just give all the existing Techs, Tech Pluses and Novices the
"NewNovice" privs, in addition to their existing privileges? The database
doesn't need to change at all.

Did you notice that Novices actually lose privileges? See the FAQ
document above for more details. In particular, power limits are
lowered from 200 Watts PEP to 100 Watts PEP on HF bands except for 10
meters, and 50 Watts PEP on 10 meters. From the FAQ:

"The reason behind the change in Novice power limits is to avoid having
to examine entry-level applicants about how to evaluate amateur stations
for RF safety. "

I'm sure that you would argue that Technicians should retain their power
limits (1500 Watts PEP) on 6 meters and up, and I would agree, but what
about HF? Should Technicians lose privileges on those bands, by having
their power limits lowered (from 200 Watts PEP), or should there be
separate power limits for Novice and Technician on HF? This is starting
to get more complicated than before.


Rather, it is just one of
the unresolved loose ends that was deliberately not tied up until better
consensus emerged from the amateur radio community about things like
Novice band refarming, etc. The League official noted that the ARRL's
band refarming proposal, RM-10413, has been sitting on an FCC official's
desk for about two years now (he claims to know the exact FCC official,
but did not name him). Because of this, as long a wait, if not longer,
is expected on a "final" answer concerning automatic upgrading.

I say we should judge by actions. When FCC thinksa proposal is a good or
bad
idea, they act. How long did the whole 98-143 process take, from initial
release of the NPRM to the new rules in April 2000?

More important, what would a lack of free upgrades hurt? Is it really such a
burden to require an Advanced to pass Element 4, or a Tech to pass Element
3, in order to get the next higher grade of license?

I think the ARRL may be politically shrewder than some would give them
credit.

You mean the BoD. I'm the ARRL too, remember?

Yes, I meant the governance of the ARRL when I used the shorthand "ARRL"
in the context of offering an opinion on a BoD decision. Only they can
establish ARRL official policy and petition the FCC in the name of the
ARRL. Who else did you think I meant?

How much of the ARRL proposal in 1998 got enacted?

You will need more than a rhetorical question to make an argument here.
Instead, why don't you just come right out and say, for the benefit of
the audience, which items in the ARRL proposal got enacted, and which
ones didn't? And, of those that didn't get enacted, which ones you
think have already been given a final "no" answer?

They can turn to the reformers and say, "See, we're giving you
a both a Novice and General HF-class license that doesn't require Morse
Code." To the old-school (and long-time, dues-paying) members they can
at least imply, "We recognize that the Morse Code tests you took in the
past are valuable, so we are going to reward you with a higher class of
license. Then you will always know that you are better than anyone who
gets a General or Extra class license under the reduced standards in the
future."

Avoids the subject of why free upgrades are needed.

But does address the subject of why they may be politically desirable,
not only by leading to simplified FCC regulations, but also resulting
in a more harmonious and productive amateur radio in the future by
addressing most of the concerns of most factions.

I say they're not.

So you've said. I'm sure that you will also say this to your
representatives within the ARRL and comment on any future FCC NPRM on
the subject. I will, too. For the record, I'm not in complete
agreement with the ARRL proposal, either. I don't see the regulatory
justification for the retention of 5 WPM Morse code for Extra, and I
remain skeptical that a Novice license (even a restructured one) is
viable today.

73 de Jim, N2EY

--
73, Paul W. Schleck, K3FU

http://www.novia.net/~pschleck/
Finger for PGP Public Key

In article , Paul W. Schleck
writes:

In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY)
writes:


In article , Paul W. Schleck
writes:

In (N2EY)
writes:


In article om, "Dee
D.
Flint" writes:

Basically I think the ARRL Board knows that the free upgrades means
that
their proposal probably will not be adopted in this form. The FCC has
never
gone along with free upgrades before and there is no evidence that they
would do so now. However, I believe they tossed it in as another idea
for
the FCC to consider in developing whatever the FCC decides to do, if
they
decide to do anything at all.

That's probably correct, Dee. And that's what bothers me!

As you say, FCC has never done free upgrades, and the last time the
issue
came
up (98-143), the ARRL proposal was for existing Novices (!) and Tech
Pluses
to
get free upgrade to General. Of course, FCC said "no way", and has had
no
problem whatever keeping the closed-to-new-issues classes in their
database.

So why propose something FCC obviously isn't going to do? Just wastes
everybody's time.

More important, it diverts attention from the other issues.

oh wait, I think I just answered my own question...;-)

73 de Jim, N2EY

I brought this subject up with someone in the League. This exact
thread, actually. I was told that the ARRL BoD sincerely believes (take
at face value, or not) that failure to upgrade licensees in the FCC R&O
for WT 98-143 was not a final "no" answer.

Maybe it wasn't. But are such freebies really a good idea?

It may be a realistic, and pragmatic, idea when considered against the
pros and cons:

Cons:

Provides a "free upgrade" to those that haven't explicitly tested for
it.

That's one. There are others:

- Allowing a free upgrade

*can be taken as*

proof that the material in the test which is not
taken is not necessary for the privileges.

To quote from the ARRL's FAQ on their proposal:

http://www.arrl.org/news/restructuring2/faq.html

"The fact is that the examination bar has never been at a uniform height
over ham radio's nearly 100-year history."

And I say: "So what? The question is whether there is any good reason to
give almost 60% of existing hams a free upgrade to the next license class,
even though the upgrade to that class requires only a written test from a
published pool.

Were you also opposed to giving pre-1917 hams a waiver for the 20 WPM
code test?

No such waiver ever existed. What *was* waived were the 20 wpm receiving and
sending code tests, plus the Extra written test. The person who got the waiver
had to hold at least a General license, too.

That was long before my time, too. And it affected maybe 2% of the licensed
hams at the time.

- Amateurs who miss the one time upgrade have to take more tests than those
who didn't. How do we justify that?

It's called "grandfathering," which is done in more regulatory contexts
than can possibly be named here. Due to the need for certainty in the
law, it is nearly always based on hard cutoff dates. Technologies,
practices, and people change over the very long timeline that laws and
regulations are required to cover. It is not possible to predict the
future with certainty, so laws and regulations must change to reflect
current knowledge. It is also impractical for society to retest,
recertify, or revalidate every existing entity against current
requirements.

None of which is proposed.

The web site for Malvern Instrumentation gives a good definition of
grandfathering in a technical context:

"Grandfathering is the practice of claiming exemption of older systems
from validation regulations and requirements on the basis that these
systems have proved their reliability by adoption for a long period of
time by a large user base."

Grandfathering in the context of ham radio recognizes that existing hams
have not only passed the tests in effect at the time, sometimes topics
not covered presently (Morse code, drawing circuit diagrams, etc.), but
have also gained experience beyond their initial exam topics. It is a
fair, and pragmatic, distinction between existing hams and entry-level
ones. Quoting again from the FAQ document:

"Passing any amateur examination does not magically result in a good
operator. It's just the key to the kingdom, so to speak. Experience and
good mentoring create skillful and knowledgeable operators, not the
relative difficulty or ease of the test."

I disagree with that assessment. YMMV.

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

I disagree. What's wrong with simply allowing Techs, Tech Pluses and Advanceds
to upgrade in their own time?

What is the sudden need to eliminate those license classes? The Novice and
Advanced have been closed off to new issues for almost 4 years, and their
numbers have declined. And from 1953 to 1967, no new Advanceds were issued. Did
any of that cause problems?

What's the rush?

Are the written tests too hard?

- Decreased reason for more than half of all hams to upgrade by testing.

No proposal is perfect. Weigh this one against the pros.

I have. The cons win.

Pros:

Avoids having to wait until the last Advanced class license expires to
refarm the Advanced phone bands.

Why does that have to be done at all?

So, are you advocating not refarming the Advanced phone bands even
*after* the last Advanced class license expires? Yeah, that's a
semantic nit-pick over what you wrote above, but then so is "You mean
the BoD. I'm the ARRL too, remember?" that you wrote below.

You're avoiding the question.

Why do the Advanced class subbands have to be "refarmed" at all? Who or what
would they be "refarmed" to? What's the longterm plan?

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Why does it need to be done at all? Is the Extra written that hard?

Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

I don't see any reason to "refarm" them at all. Not at this time, anyway.

Note that in 4 years, the number of Advanceds has dropped by only about 16%.
Seems to be a pretty popular license even today.

It sounds to me like you want all Advanceds to become Extras so that the
Advanced subbands can become General bandspace. That's not part of the ARRL
proposal, though.

Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus.

Whatever. I don't see why the 5 wpm code test is such a big deal as a
requirement.

That's still a long time in FCC
enforcement (and VEC administration) years.

Why? It's been almost 4 years since the last restructuring took effect. Look at
the enforcement letters - Techs without code masquerading as Tech Pluses isn't
a
big problem, from what I see.

Even if you argue that FCC
action on further restructuring will take most of that six years anyway,
there are still all those Novice and Advanced class licenses that will
likely exist in the database for decades to come.

It makes sense to grandfather existing Novices to the "NewNovice" (or whatever
it is called). There are only about 32,000 Novices left now, down from just
under 50,000 after restructuring.

What *is* the problem with Advanceds just staying as they are? Have you not
read from the Advanceds who say they *don't want* to become Extras?

Why not just give all the existing Techs, Tech Pluses and Novices the
"NewNovice" privs, in addition to their existing privileges? The database
doesn't need to change at all.

Did you notice that Novices actually lose privileges? See the FAQ
document above for more details. In particular, power limits are
lowered from 200 Watts PEP to 100 Watts PEP on HF bands except for 10
meters, and 50 Watts PEP on 10 meters.

Is that really much of a problem? How many Novices are on the air today running
more than those power levels?

From the FAQ:

"The reason behind the change in Novice power limits is to avoid having
to examine entry-level applicants about how to evaluate amateur stations
for RF safety. "

I'm sure that you would argue that Technicians should retain their power
limits (1500 Watts PEP) on 6 meters and up, and I would agree, but what
about HF? Should Technicians lose privileges on those bands, by having
their power limits lowered (from 200 Watts PEP), or should there be
separate power limits for Novice and Technician on HF? This is starting
to get more complicated than before.

Not at all! Where an existing ham has greater privs, those privs would be
retained. This has been done with Tech Pluses for almost 4 years now. FCC
proposed it and enacted it, btw. Why can't it be done for existing Novices and
Techs?

The 1998 proposal from ARRL Hq was for Tech Pluses and Novices to get a freebie
to General - and FCC said no. What has changed that suddenly makes free
upgrades a good idea?

Rather, it is just one of
the unresolved loose ends that was deliberately not tied up until better
consensus emerged from the amateur radio community about things like
Novice band refarming, etc. The League official noted that the ARRL's
band refarming proposal, RM-10413, has been sitting on an FCC official's
desk for about two years now (he claims to know the exact FCC official,
but did not name him). Because of this, as long a wait, if not longer,
is expected on a "final" answer concerning automatic upgrading.

I say we should judge by actions. When FCC thinksa proposal is a good or
bad
idea, they act. How long did the whole 98-143 process take, from initial
release of the NPRM to the new rules in April 2000?

More important, what would a lack of free upgrades hurt? Is it really such
a
burden to require an Advanced to pass Element 4, or a Tech to pass Element
3, in order to get the next higher grade of license?

I think the ARRL may be politically shrewder than some would give them
credit.

You mean the BoD. I'm the ARRL too, remember?

Yes, I meant the governance of the ARRL when I used the shorthand "ARRL"
in the context of offering an opinion on a BoD decision. Only they can
establish ARRL official policy and petition the FCC in the name of the
ARRL. Who else did you think I meant?

Those folks are elected and paid for by members like *me*. They supposedly
make those proposals in *my* name and with *my* support.

Well, I don't support everything in that proposal.

How much of the ARRL proposal in 1998 got enacted?

You will need more than a rhetorical question to make an argument here.
Instead, why don't you just come right out and say, for the benefit of
the audience, which items in the ARRL proposal got enacted, and which
ones didn't? And, of those that didn't get enacted, which ones you
think have already been given a final "no" answer?

All right.

Fact is, almost nothing proposed by ARRL Hq in 1998 got enacted. 5 wpm for
General, that's about it. On everything else, FCC either:

- said no: free upgrades, better written tests, Techs on HF CW without a formal
test

- went far beyond what was requested: 5 wpm Extra, Advanced closed off, written
testing reduced dramatically

They can turn to the reformers and say, "See, we're giving you
a both a Novice and General HF-class license that doesn't require Morse
Code." To the old-school (and long-time, dues-paying) members they can
at least imply, "We recognize that the Morse Code tests you took in the
past are valuable, so we are going to reward you with a higher class of
license. Then you will always know that you are better than anyone who
gets a General or Extra class license under the reduced standards in the
future."

Avoids the subject of why free upgrades are needed.

But does address the subject of why they may be politically desirable,
not only by leading to simplified FCC regulations, but also resulting
in a more harmonious and productive amateur radio in the future by
addressing most of the concerns of most factions.

I don't see that at all. Are the written tests so difficult, and the VE test
process so onerous, that free upgrades are the only answer?

I say they're not.

So you've said. I'm sure that you will also say this to your
representatives within the ARRL and comment on any future FCC NPRM on
the subject.

Already have. In detail. More to come, too.

I will, too. For the record, I'm not in complete
agreement with the ARRL proposal, either. I don't see the regulatory
justification for the retention of 5 WPM Morse code for Extra,

I do. Morse code is a big part of amateur radio, and having no code test at all
simply denies the reality of that.

and I
remain skeptical that a Novice license (even a restructured one) is
viable today.

What we have now is a system that tends to funnel newcomers into VHF/UHF
amateur radio, and manufactured equipment. And away from HF and homebrewing. A
restructured Novice could change that.

73 de Jim, N2EY

In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY)
writes:


In article , Paul W. Schleck
writes:

In (N2EY)
writes:


In article om, "Dee
D.
Flint" writes:

Basically I think the ARRL Board knows that the free upgrades means
that
their proposal probably will not be adopted in this form. The FCC has
never
gone along with free upgrades before and there is no evidence that they
would do so now. However, I believe they tossed it in as another idea
for
the FCC to consider in developing whatever the FCC decides to do, if
they
decide to do anything at all.

That's probably correct, Dee. And that's what bothers me!

As you say, FCC has never done free upgrades, and the last time the
issue
came
up (98-143), the ARRL proposal was for existing Novices (!) and Tech
Pluses
to
get free upgrade to General. Of course, FCC said "no way", and has had
no
problem whatever keeping the closed-to-new-issues classes in their
database.

So why propose something FCC obviously isn't going to do? Just wastes
everybody's time.

More important, it diverts attention from the other issues.

oh wait, I think I just answered my own question...;-)

73 de Jim, N2EY

I brought this subject up with someone in the League. This exact
thread, actually. I was told that the ARRL BoD sincerely believes (take
at face value, or not) that failure to upgrade licensees in the FCC R&O
for WT 98-143 was not a final "no" answer.

Maybe it wasn't. But are such freebies really a good idea?

It may be a realistic, and pragmatic, idea when considered against the
pros and cons:

Cons:

Provides a "free upgrade" to those that haven't explicitly tested for
it.

That's one. There are others:

- Allowing a free upgrade

*can be taken as*

proof that the material in the test which is not
taken is not necessary for the privileges.

To quote from the ARRL's FAQ on their proposal:

http://www.arrl.org/news/restructuring2/faq.html

"The fact is that the examination bar has never been at a uniform height
over ham radio's nearly 100-year history."

And I say: "So what? The question is whether there is any good reason to
give almost 60% of existing hams a free upgrade to the next license class,
even though the upgrade to that class requires only a written test from a
published pool.

Were you also opposed to giving pre-1917 hams a waiver for the 20 WPM
code test?

No such waiver ever existed. What *was* waived were the 20 wpm receiving and
sending code tests, plus the Extra written test. The person who got the waiver
had to hold at least a General license, too.

Now you're being pedantic. I was describing a subset of the waiver
given, enough for the purpose of the argument. You described the entire
waiver. Both are correct, and neither contradicts my arguments.

That was long before my time, too. And it affected maybe 2% of the licensed
hams at the time.

So you might accept grandfathering, if it occurred at some asymptotic
point in the past, and only affected a small minority of hams? What
percentage would be a threshold? You say that it is wrong to
grandfather 60% of all hams, but you might be willing to accept
grandfathering of 2% of all hams. What about a proposal that
grandfathers some percentage of hams in-between? What would be your
greater objection, grandfathering all of the Techs, or grandfathering
all of the Advanced?

Remember that at some time in the future, we may be looking on this
grandfathering as occurring at some asymptotic point in the past, as
with the pre-1917 waiver above. You ask below what is the long-term
plan. I say one aspect of the plan is to be able to look back on this
grandfathering in the same way that we look upon the pre-1917 waiver.

- Amateurs who miss the one time upgrade have to take more tests than those
who didn't. How do we justify that?

It's called "grandfathering," which is done in more regulatory contexts
than can possibly be named here. Due to the need for certainty in the
law, it is nearly always based on hard cutoff dates. Technologies,
practices, and people change over the very long timeline that laws and
regulations are required to cover. It is not possible to predict the
future with certainty, so laws and regulations must change to reflect
current knowledge. It is also impractical for society to retest,
recertify, or revalidate every existing entity against current
requirements.

None of which is proposed.

But when considering alternatives, one really has to identify all
implicit alternatives, and argue for or against them (avoiding the
logical pitfall of false dichotomies, trichotomies, etc.). The status
quo, which you have advocated, and might be labeled alternative #4 based
on your exchange with Bill Sohl, is one such implicit alternative. I
would argue against that, for the reasons I have given previously
(streamlining of license classes, streamlining of band plans, reduction
of regulatory burden, reduction in confusion for amateurs and the FCC,
harmonization with the deletion of S25.5 and with other countries'
regulations, etc.).

If license classes are consolidated to a smaller number, one alternative
is simply to grandfather existing hams, which the ARRL has advocated.
One other implicit alternative (say, #5), is to make every Novice,
Advanced (and possibly non-Plus, or would that be non-Plussed, Tech)
come back in to take written tests to upgrade to the next level, or
otherwise lose privileges. I would argue against that also, for the
reasons I have also given previously (it is impractical to retest
everyone, and such existing hams are a large, stable user base such as
that in the definition of grandfathering below).


The web site for Malvern Instrumentation gives a good definition of
grandfathering in a technical context:

"Grandfathering is the practice of claiming exemption of older systems
from validation regulations and requirements on the basis that these
systems have proved their reliability by adoption for a long period of
time by a large user base."

Grandfathering in the context of ham radio recognizes that existing hams
have not only passed the tests in effect at the time, sometimes topics
not covered presently (Morse code, drawing circuit diagrams, etc.), but
have also gained experience beyond their initial exam topics. It is a
fair, and pragmatic, distinction between existing hams and entry-level
ones. Quoting again from the FAQ document:

"Passing any amateur examination does not magically result in a good
operator. It's just the key to the kingdom, so to speak. Experience and
good mentoring create skillful and knowledgeable operators, not the
relative difficulty or ease of the test."

I disagree with that assessment. YMMV.

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

I disagree. What's wrong with simply allowing Techs, Tech Pluses and Advanceds
to upgrade in their own time?

What is the sudden need to eliminate those license classes? The Novice and
Advanced have been closed off to new issues for almost 4 years, and their
numbers have declined. And from 1953 to 1967, no new Advanceds were issued. Did
any of that cause problems?

What's the rush?

Are the written tests too hard?

- Decreased reason for more than half of all hams to upgrade by testing.

No proposal is perfect. Weigh this one against the pros.

I have. The cons win.

Pros:

Avoids having to wait until the last Advanced class license expires to
refarm the Advanced phone bands.

Why does that have to be done at all?

So, are you advocating not refarming the Advanced phone bands even
*after* the last Advanced class license expires? Yeah, that's a
semantic nit-pick over what you wrote above, but then so is "You mean
the BoD. I'm the ARRL too, remember?" that you wrote below.

You're avoiding the question.

Why do the Advanced class subbands have to be "refarmed" at all? Who or what
would they be "refarmed" to? What's the longterm plan?

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Why does it need to be done at all? Is the Extra written that hard?

So you would argue that any refarming would be done at some asymptotic
point in the far future, indistinguishable at present between "decades"
and "never."


Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

I don't see any reason to "refarm" them at all. Not at this time, anyway.

Note that in 4 years, the number of Advanceds has dropped by only about 16%.
Seems to be a pretty popular license even today.

It sounds to me like you want all Advanceds to become Extras so that the
Advanced subbands can become General bandspace. That's not part of the ARRL
proposal, though.

No, I never said that. I would combine Advanced and Extra phone bands
into just Extra phone bands, and leave the General bands as they are.
That doesn't mean that I wouldn't support frequency shifting, such as
that proposed to make 40 meters a primary amateur allocation, or part of
Novice band refarming. Just that I would keep the proportional amounts
roughly the same. I realize that the current ARRL proposal splits up
the Advanced phone bands, giving proportionally more to the General than
the Extra phone bands on 80 and 40 meters, and proportionally less on 15
meters (no changes on 20 meters). I do not strongly support that, but
even that proposal isn't giving the entire Advanced phone bandwidth to
the Generals.

Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus.

Whatever. I don't see why the 5 wpm code test is such a big deal as a
requirement.

Does your "Whatever" answer above mean that you support 5 WPM Morse code
for all HF license classes, or just for Extra? If the former, then
there is a very real distinction that will continue to exist in the
license ladder whether or not it continues to be recorded in the
database. If so, then the expiring of Tech-Plus license in 6 years is
not a simplification, it is a complication.

That's still a long time in FCC
enforcement (and VEC administration) years.

Why? It's been almost 4 years since the last restructuring took effect. Look at
the enforcement letters - Techs without code masquerading as Tech Pluses isn't
a
big problem, from what I see.

You argue that it's not an enforcement problem because few or none have
been caught. I would argue that it is an enforcement problem because it
would be very hard to catch someone, especially if confirming who has
what privileges requires documentation that is no longer in the FCC
database, and might no longer be retained by hams or VEC's. The FCC's
limited staff time is probably being aimed at big fish, such as Advanced
and Extra-class scofflaws engaging in power and interference violations.

Even if you argue that FCC
action on further restructuring will take most of that six years anyway,
there are still all those Novice and Advanced class licenses that will
likely exist in the database for decades to come.

It makes sense to grandfather existing Novices to the "NewNovice" (or whatever
it is called). There are only about 32,000 Novices left now, down from just
under 50,000 after restructuring.

What *is* the problem with Advanceds just staying as they are? Have you not
read from the Advanceds who say they *don't want* to become Extras?

Which is as much of an argument as "Have you not read from the hams who
say that they *don't want* to have ham radio examinations without Morse
code?"


Why not just give all the existing Techs, Tech Pluses and Novices the
"NewNovice" privs, in addition to their existing privileges? The database
doesn't need to change at all.

Did you notice that Novices actually lose privileges? See the FAQ
document above for more details. In particular, power limits are
lowered from 200 Watts PEP to 100 Watts PEP on HF bands except for 10
meters, and 50 Watts PEP on 10 meters.

Is that really much of a problem? How many Novices are on the air today running
more than those power levels?

From the FAQ:

"The reason behind the change in Novice power limits is to avoid having
to examine entry-level applicants about how to evaluate amateur stations
for RF safety. "

I'm sure that you would argue that Technicians should retain their power
limits (1500 Watts PEP) on 6 meters and up, and I would agree, but what
about HF? Should Technicians lose privileges on those bands, by having
their power limits lowered (from 200 Watts PEP), or should there be
separate power limits for Novice and Technician on HF? This is starting
to get more complicated than before.

Not at all! Where an existing ham has greater privs, those privs would be
retained. This has been done with Tech Pluses for almost 4 years now. FCC
proposed it and enacted it, btw. Why can't it be done for existing Novices and
Techs?

So, again, as part of your status-quo alternative, you want to keep in
place the regulations and bandplans for six classes of license, only
five of which will be tracked in the FCC database six years from now.

The 1998 proposal from ARRL Hq was for Tech Pluses and Novices to get a freebie
to General - and FCC said no. What has changed that suddenly makes free
upgrades a good idea?

The ARRL argues that this is now the second round of restructuring. The
FCC prefers to revisit things every few years, and do things in
manageable chunks. What is driving this second round is the lifting of
the S25.5 requirement, the eventual need (in the ARRL's opinion, and
mine) to address the shrinking pools of Novice and Advanced class
licenses, as well as the fact that there will be no distinction in the
FCC database between two classes of licenses with different privileges
(Tech and Tech Plus) in the very near future.

Rather, it is just one of
the unresolved loose ends that was deliberately not tied up until better
consensus emerged from the amateur radio community about things like
Novice band refarming, etc. The League official noted that the ARRL's
band refarming proposal, RM-10413, has been sitting on an FCC official's
desk for about two years now (he claims to know the exact FCC official,
but did not name him). Because of this, as long a wait, if not longer,
is expected on a "final" answer concerning automatic upgrading.

I say we should judge by actions. When FCC thinksa proposal is a good or
bad
idea, they act. How long did the whole 98-143 process take, from initial
release of the NPRM to the new rules in April 2000?

More important, what would a lack of free upgrades hurt? Is it really such
a
burden to require an Advanced to pass Element 4, or a Tech to pass Element
3, in order to get the next higher grade of license?

I think the ARRL may be politically shrewder than some would give them
credit.

You mean the BoD. I'm the ARRL too, remember?

Yes, I meant the governance of the ARRL when I used the shorthand "ARRL"
in the context of offering an opinion on a BoD decision. Only they can
establish ARRL official policy and petition the FCC in the name of the
ARRL. Who else did you think I meant?

Those folks are elected and paid for by members like *me*. They supposedly
make those proposals in *my* name and with *my* support.

Well, I don't support everything in that proposal.

Welcome to the realities of representative democracy. Both of us pay
dues to the ARRL and elect Directors. They make proposals in both of
our names. I don't support everything in that proposal either, but it
is an ARRL proposal. You and I are perfectly free to submit comments to
the FCC as "ARRL Members," but the ARRL Board of Directors will submit
comments to the FCC as "*The* ARRL."


How much of the ARRL proposal in 1998 got enacted?

You will need more than a rhetorical question to make an argument here.
Instead, why don't you just come right out and say, for the benefit of
the audience, which items in the ARRL proposal got enacted, and which
ones didn't? And, of those that didn't get enacted, which ones you
think have already been given a final "no" answer?

All right.

Fact is, almost nothing proposed by ARRL Hq in 1998 got enacted. 5 wpm for
General, that's about it. On everything else, FCC either:

- said no: free upgrades, better written tests, Techs on HF CW without a formal
test

- went far beyond what was requested: 5 wpm Extra, Advanced closed off, written
testing reduced dramatically

They can turn to the reformers and say, "See, we're giving you
a both a Novice and General HF-class license that doesn't require Morse
Code." To the old-school (and long-time, dues-paying) members they can
at least imply, "We recognize that the Morse Code tests you took in the
past are valuable, so we are going to reward you with a higher class of
license. Then you will always know that you are better than anyone who
gets a General or Extra class license under the reduced standards in the
future."

Avoids the subject of why free upgrades are needed.

But does address the subject of why they may be politically desirable,
not only by leading to simplified FCC regulations, but also resulting
in a more harmonious and productive amateur radio in the future by
addressing most of the concerns of most factions.

I don't see that at all. Are the written tests so difficult, and the VE test
process so onerous, that free upgrades are the only answer?

I say they're not.

So you've said. I'm sure that you will also say this to your
representatives within the ARRL and comment on any future FCC NPRM on
the subject.

Already have. In detail. More to come, too.

I will, too. For the record, I'm not in complete
agreement with the ARRL proposal, either. I don't see the regulatory
justification for the retention of 5 WPM Morse code for Extra,

I do. Morse code is a big part of amateur radio, and having no code test at all
simply denies the reality of that.

I'm sure that you will argue in more detail than "Morse code is a big
part of ham radio, and having no code test simply denies the reality of
that." You may also have to find new arguments beyond those that the
FCC rejected in Docket WT 98-143, including yours.

and I
remain skeptical that a Novice license (even a restructured one) is
viable today.

What we have now is a system that tends to funnel newcomers into VHF/UHF
amateur radio, and manufactured equipment. And away from HF and homebrewing. A
restructured Novice could change that.

Part of arguing for a new Novice license would involve identifying what
has not worked with the present Novice license, and what changes would
somehow "open the floodgates" with the proposed future one. You argue
that most entry-level hams are being funneled to VHF/UHF. I might also
argue that there are not very many entry-level hams at all, especially
younger people, regardless of where they are being funneled. The
youngest members in most clubs locally are well into their mid-30's.
The presence of teenagers has all but evaporated.

What types of realistic homebrewing are you advocating for "NewNovice"
hams beyond 3-transistor OOK transmitters and single-conversion
receivers? Please be specific. What aspects of current communications
technology, something that would be used and would not be a trophy or
shop-project to be put on a shelf, can be realistically homebrewed via
commercially-available (and presently-manufactured) parts by high-school
age hams?

When you argue for "NewNovice" privileges, are you supporting it with 5
WPM code, or without? What if almost no one wants to sign up for 5 WPM
code as an entry-level requirement?

73 de Jim, N2EY

--
73, Paul W. Schleck, K3FU

http://www.novia.net/~pschleck/
Finger for PGP Public Key

In article , Paul W. Schleck
writes:

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writes:

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writes:

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writes:

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writes:

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In article om, "Dee
D.
Flint" writes:


I brought this subject up with someone in the League. This exact
thread, actually. I was told that the ARRL BoD sincerely believes
(take
at face value, or not) that failure to upgrade licensees in the FCC R&O
for WT 98-143 was not a final "no" answer.

Maybe it wasn't. But are such freebies really a good idea?

It may be a realistic, and pragmatic, idea when considered against the
pros and cons:

Cons:

Provides a "free upgrade" to those that haven't explicitly tested for
it.

That's one. There are others:

- Allowing a free upgrade

*can be taken as*

proof that the material in the test which is not
taken is not necessary for the privileges.

To quote from the ARRL's FAQ on their proposal:

http://www.arrl.org/news/restructuring2/faq.html

"The fact is that the examination bar has never been at a uniform height
over ham radio's nearly 100-year history."

And I say: "So what? The question is whether there is any good reason to
give almost 60% of existing hams a free upgrade to the next license class,
even though the upgrade to that class requires only a written test from a
published pool.

Were you also opposed to giving pre-1917 hams a waiver for the 20 WPM
code test?

No such waiver ever existed. What *was* waived were the 20 wpm receiving and
sending code tests, plus the Extra written test. The person who got the
waiver had to hold at least a General license, too.

Now you're being pedantic.

I'm being *accurate*.

I was describing a subset of the waiver
given, enough for the purpose of the argument.
You described the entire
waiver. Both are correct, and neither contradicts my arguments.

I find it interesting that you mentioned only the code test part of the waiver,
not
the written test part. Some folks might think the waiver only applied to the
code
tests.

That was long before my time, too. And it affected maybe 2% of the licensed
hams at the time.

So you might accept grandfathering, if it occurred at some asymptotic
point in the past, and only affected a small minority of hams?

Depends on the situation. The old Extra waiver only began after there was no
difference
among the operating privileges of a General, Conditional, Advanced or Extra
(1952 or later). IOW it was
just a title sort of thing - didn't make any difference in practical
application. And anyone who qualified
for it was an OT from the very early days (35 years at least). By the time the
waiver meant anything
in terms of operating privileges, that gap was over 51 years.

That's a completely different scenario than offering a free *upgrade* to almost
60% of existing hams,
plus any that might get ham tickets before the rules change.

What
percentage would be a threshold? You say that it is wrong to
grandfather 60% of all hams, but you might be willing to accept
grandfathering of 2% of all hams.

And I might not. Depends on the situation.

And the more I think about it, the more I think the old Extra waiver was a bad
idea, and that there may be
no scenario that would be worthwhile.

What about a proposal that
grandfathers some percentage of hams in-between?

I say no to free upgrades, then.

What would be your
greater objection, grandfathering all of the Techs, or grandfathering
all of the Advanced?

What's the difference? They're both bad ideas.

Remember that at some time in the future, we may be looking on this
grandfathering as occurring at some asymptotic point in the past, as
with the pre-1917 waiver above.

You mean like when the Advanced has been unavailable for 35+ years and their
numbers are down to about 1% of the ARS total?

You ask below what is the long-term
plan. I say one aspect of the plan is to be able to look back on this
grandfathering in the same way that we look upon the pre-1917 waiver.

We don't look back on it the same way.

And why was it done?

- Amateurs who miss the one time upgrade have to take more tests than
those who didn't. How do we justify that?

It's called "grandfathering," which is done in more regulatory contexts
than can possibly be named here. Due to the need for certainty in the
law, it is nearly always based on hard cutoff dates. Technologies,
practices, and people change over the very long timeline that laws and
regulations are required to cover. It is not possible to predict the
future with certainty, so laws and regulations must change to reflect
current knowledge. It is also impractical for society to retest,
recertify, or revalidate every existing entity against current
requirements.

None of which is proposed.

But when considering alternatives, one really has to identify all
implicit alternatives, and argue for or against them (avoiding the
logical pitfall of false dichotomies, trichotomies, etc.). The status
quo, which you have advocated, and might be labeled alternative #4 based
on your exchange with Bill Sohl, is one such implicit alternative.

To put it simply: Just leave the closed-off classes alone, and let them
go away by attrition.

This is exactly what was done with the Advanced from the beginning of 1953
until 1967 - more than 14 years. What problems did it cause?

I
would argue against that, for the reasons I have given previously
(streamlining of license classes, streamlining of band plans, reduction
of regulatory burden, reduction in confusion for amateurs and the FCC,
harmonization with the deletion of S25.5 and with other countries'
regulations, etc.).

All it takes to keep those classes is a few sentences in Part 97.

If license classes are consolidated to a smaller number, one alternative
is simply to grandfather existing hams, which the ARRL has advocated.

A more accurate term is "free upgrade", because that's what it is.

"Grandfather" implies letting a person keep what they already have without
recertification. That's not what is proposed by the ARRL BoD for Techs and
Advanceds.

One other implicit alternative (say, #5), is to make every Novice,
Advanced (and possibly non-Plus, or would that be non-Plussed, Tech)
come back in to take written tests to upgrade to the next level, or
otherwise lose privileges.

That's the worst alternative.

I would argue against that also, for the
reasons I have also given previously (it is impractical to retest
everyone,

It could easily be done over time by saying that you either retest before Date
X
or you'll be reclassified at a lower license class.

and such existing hams are a large, stable user base such as
that in the definition of grandfathering below).

"Large, stable user base"? We don't really know about that. How many
of those folks are active? Why have so few Advanceds upgraded to
Extra?

The web site for Malvern Instrumentation gives a good definition of
grandfathering in a technical context:

"Grandfathering is the practice of claiming exemption of older systems
from validation regulations and requirements on the basis that these
systems have proved their reliability by adoption for a long period of
time by a large user base."

IOW, we allow them to continue doing what they're doing because they've shown
a lack of problems in the past. But we require more of new systems.

It *doesn't* say we allow free upgrades.

Grandfathering in the context of ham radio recognizes that existing hams
have not only passed the tests in effect at the time, sometimes topics
not covered presently (Morse code, drawing circuit diagrams, etc.), but
have also gained experience beyond their initial exam topics. It is a
fair, and pragmatic, distinction between existing hams and entry-level
ones. Quoting again from the FAQ document:

"Passing any amateur examination does not magically result in a good
operator. It's just the key to the kingdom, so to speak. Experience and
good mentoring create skillful and knowledgeable operators, not the
relative difficulty or ease of the test."

I disagree with that assessment. YMMV.

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

I disagree. What's wrong with simply allowing Techs, Tech Pluses and
Advanceds to upgrade in their own time?

What is the sudden need to eliminate those license classes? The Novice and
Advanced have been closed off to new issues for almost 4 years, and their
numbers have declined. And from 1953 to 1967, no new Advanceds were issued.
Did any of that cause problems?

What's the rush?

Are the written tests too hard?

Well? The current Extra was recently earned by a bright seven year old - can
we really say that it's unreasonable to expect others to do what she did for
the
same privileges?

- Decreased reason for more than half of all hams to upgrade by testing.

No proposal is perfect. Weigh this one against the pros.

I have. The cons win.

Pros:

Avoids having to wait until the last Advanced class license expires to
refarm the Advanced phone bands.

Why does that have to be done at all?

So, are you advocating not refarming the Advanced phone bands even
*after* the last Advanced class license expires? Yeah, that's a
semantic nit-pick over what you wrote above, but then so is "You mean
the BoD. I'm the ARRL too, remember?" that you wrote below.

You're avoiding the question.

Why do the Advanced class subbands have to be "refarmed" at all? Who or what
would they be "refarmed" to? What's the longterm plan?

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Why does it need to be done at all? Is the Extra written that hard?

Why do you avoid these simple questions?

So you would argue that any refarming would be done at some asymptotic
point in the far future, indistinguishable at present between "decades"
and "never."

I'm *asking* what the problem is with leaving some things alone.


Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

I don't see any reason to "refarm" them at all. Not at this time, anyway.

Note that in 4 years, the number of Advanceds has dropped by only about 16%.

Seems to be a pretty popular license even today.

Note also that several Advanceds have said they *don't* want an upgrade, free
or not.
I don't understand why, but that's what they've said.

It sounds to me like you want all Advanceds to become Extras so that the
Advanced subbands can become General bandspace. That's not part of the ARRL
proposal, though.

No, I never said that.

No, you didn't. That's why I wrote "sounds to me".

I would combine Advanced and Extra phone bands
into just Extra phone bands, and leave the General bands as they are.

That's the status quo! It's not "refarming" at all.

That doesn't mean that I wouldn't support frequency shifting, such as
that proposed to make 40 meters a primary amateur allocation, or part of
Novice band refarming. Just that I would keep the proportional amounts
roughly the same. I realize that the current ARRL proposal splits up
the Advanced phone bands, giving proportionally more to the General than
the Extra phone bands on 80 and 40 meters, and proportionally less on 15
meters (no changes on 20 meters). I do not strongly support that, but
even that proposal isn't giving the entire Advanced phone bandwidth to
the Generals.

And if nothing at all is done, the results are almost the same as what you
propose.

Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus.

Whatever. I don't see why the 5 wpm code test is such a big deal as a
requirement.

Does your "Whatever" answer above mean that you support 5 WPM Morse code
for all HF license classes, or just for Extra?

I support a code test for all amateur licenses, period. I think the dropping of
the
code test for the Tech back in 1991 was a mistake. I argued and commented
against it then, and much of what I said would happen has come to pass.

If the former, then
there is a very real distinction that will continue to exist in the
license ladder whether or not it continues to be recorded in the
database. If so, then the expiring of Tech-Plus license in 6 years is
not a simplification, it is a complication.

That's still a long time in FCC
enforcement (and VEC administration) years.

Why? It's been almost 4 years since the last restructuring took effect. Look
at the enforcement letters - Techs without code masquerading as Tech Pluses
isn't a big problem, from what I see.

You argue that it's not an enforcement problem because few or none have
been caught. I would argue that it is an enforcement problem because it
would be very hard to catch someone, especially if confirming who has
what privileges requires documentation that is no longer in the FCC
database, and might no longer be retained by hams or VEC's. The FCC's
limited staff time is probably being aimed at big fish, such as Advanced
and Extra-class scofflaws engaging in power and interference violations.

You might want to read the letters. They're pretty evenly distributed, license
clas wise, except for Novices.

Even if you argue that FCC
action on further restructuring will take most of that six years anyway,
there are still all those Novice and Advanced class licenses that will
likely exist in the database for decades to come.

It makes sense to grandfather existing Novices to the "NewNovice" (or
whatever
it is called). There are only about 32,000 Novices left now, down from just
under 50,000 after restructuring.

What *is* the problem with Advanceds just staying as they are? Have you not
read from the Advanceds who say they *don't want* to become Extras?

Which is as much of an argument as "Have you not read from the hams who
say that they *don't want* to have ham radio examinations without Morse
code?"

You keep avoiding the question.

Why not just give all the existing Techs, Tech Pluses and Novices the
"NewNovice" privs, in addition to their existing privileges? The database
doesn't need to change at all.

Did you notice that Novices actually lose privileges? See the FAQ
document above for more details. In particular, power limits are
lowered from 200 Watts PEP to 100 Watts PEP on HF bands except for 10
meters, and 50 Watts PEP on 10 meters.

Is that really much of a problem? How many Novices are on the air today
running more than those power levels?

Well? You know the answer as well as I: "Very few".

From the FAQ:

"The reason behind the change in Novice power limits is to avoid having
to examine entry-level applicants about how to evaluate amateur stations
for RF safety. "

I'm sure that you would argue that Technicians should retain their power
limits (1500 Watts PEP) on 6 meters and up, and I would agree, but what
about HF? Should Technicians lose privileges on those bands, by having
their power limits lowered (from 200 Watts PEP), or should there be
separate power limits for Novice and Technician on HF? This is starting
to get more complicated than before.

Not at all! Where an existing ham has greater privs, those privs would be
retained. This has been done with Tech Pluses for almost 4 years now. FCC
proposed it and enacted it, btw. Why can't it be done for existing Novices
and Techs?

So, again, as part of your status-quo alternative, you want to keep in
place the regulations and bandplans for six classes of license, only
five of which will be tracked in the FCC database six years from now.

Why not? Most of that is just a few lines in Part 97.

The 1998 proposal from ARRL Hq was for Tech Pluses and Novices to get a
freebie
to General - and FCC said no. What has changed that suddenly makes free
upgrades a good idea?

The ARRL argues that this is now the second round of restructuring.

Then why wasn't the BoD ready for it?

The
FCC prefers to revisit things every few years, and do things in
manageable chunks.

Meaning no disrespect, but - how do you know?

And if that is, indeed, the case, why not make a few changes now
(like the "NewNovice") and revisit in a few years?

What is driving this second round is the lifting of
the S25.5 requirement, the eventual need (in the ARRL's opinion, and
mine) to address the shrinking pools of Novice and Advanced class
licenses, as well as the fact that there will be no distinction in the
FCC database between two classes of licenses with different privileges
(Tech and Tech Plus) in the very near future.

Let's take those one at a time:

"shrinking pools of Novice and Advanced class licenses"

If the Novice is reopened to new issues and existing Novices get NewNovice
privileges as proposed by the BoD, the Novice shrinkage should stop.

Advanceds are shrinking at a very slow rate (16% in almost 4 years) so there's
no hurry in dealing with them.

"there will be no distinction in the FCC database between two classes of
licenses with different privileges
(Tech and Tech Plus) in the very near future"

Part of the proposal is for the code test for all but the Extra to go away, so
the difference between
Tech and Tech Plus becomes moot unless someone wants to get an Extra - at which
time all they
need do is present their old license or other document for Element 1 credit.

Or they can just take the code test!

So that's not an issue either.

Rather, it is just one of
the unresolved loose ends that was deliberately not tied up until
better
consensus emerged from the amateur radio community about things like
Novice band refarming, etc. The League official noted that the ARRL's
band refarming proposal, RM-10413, has been sitting on an FCC
official's
desk for about two years now (he claims to know the exact FCC official,
but did not name him). Because of this, as long a wait, if not longer,
is expected on a "final" answer concerning automatic upgrading.

I say we should judge by actions. When FCC thinksa proposal is a good or
bad
idea, they act. How long did the whole 98-143 process take, from initial
release of the NPRM to the new rules in April 2000?

More important, what would a lack of free upgrades hurt? Is it really
such a
burden to require an Advanced to pass Element 4, or a Tech to pass
Element 3, in order to get the next higher grade of license?

I think the ARRL may be politically shrewder than some would give them
credit.

You mean the BoD. I'm the ARRL too, remember?

Yes, I meant the governance of the ARRL when I used the shorthand "ARRL"
in the context of offering an opinion on a BoD decision. Only they can
establish ARRL official policy and petition the FCC in the name of the
ARRL. Who else did you think I meant?

Those folks are elected and paid for by members like *me*. They supposedly
make those proposals in *my* name and with *my* support.

Well, I don't support everything in that proposal.

Welcome to the realities of representative democracy.

Been there since 1968 with ARRL.

Both of us pay
dues to the ARRL and elect Directors. They make proposals in both of
our names. I don't support everything in that proposal either, but it
is an ARRL proposal. You and I are perfectly free to submit comments to
the FCC as "ARRL Members," but the ARRL Board of Directors will submit
comments to the FCC as "*The* ARRL."

Which will be done in my case, as was before. The BoD needs to realize,
however, that the ARRL's position is weakened by proposing things that
much if not most of the membership opposes.

How much of the ARRL proposal in 1998 got enacted?

You will need more than a rhetorical question to make an argument here.
Instead, why don't you just come right out and say, for the benefit of
the audience, which items in the ARRL proposal got enacted, and which
ones didn't? And, of those that didn't get enacted, which ones you
think have already been given a final "no" answer?

All right.

Fact is, almost nothing proposed by ARRL Hq in 1998 got enacted. 5 wpm for
General, that's about it. On everything else, FCC either:

- said no: free upgrades, better written tests, Techs on HF CW without a
formal test

- went far beyond what was requested: 5 wpm Extra, Advanced closed off,
written testing reduced dramatically

They can turn to the reformers and say, "See, we're giving you
a both a Novice and General HF-class license that doesn't require Morse
Code." To the old-school (and long-time, dues-paying) members they can
at least imply, "We recognize that the Morse Code tests you took in the
past are valuable, so we are going to reward you with a higher class of
license. Then you will always know that you are better than anyone who
gets a General or Extra class license under the reduced standards in the
future."

Avoids the subject of why free upgrades are needed.

But does address the subject of why they may be politically desirable,
not only by leading to simplified FCC regulations, but also resulting
in a more harmonious and productive amateur radio in the future by
addressing most of the concerns of most factions.

I don't see that at all. Are the written tests so difficult, and the VE test
process so onerous, that free upgrades are the only answer?

I say they're not.

So you've said. I'm sure that you will also say this to your
representatives within the ARRL and comment on any future FCC NPRM on
the subject.

Already have. In detail. More to come, too.

I will, too. For the record, I'm not in complete
agreement with the ARRL proposal, either. I don't see the regulatory
justification for the retention of 5 WPM Morse code for Extra,

I do. Morse code is a big part of amateur radio, and having no code test at
all simply denies the reality of that.

I'm sure that you will argue in more detail than "Morse code is a big
part of ham radio, and having no code test simply denies the reality of
that."

OK, here's some mo

One of the Basis and Purposes of the ARS is technical education and skill
development.
IOW, hams learning about how radio works. Morse skill helps in this area
because Morse-capable radio equipment can be made using a very wide variety of
technologies and complexities.

IOW, the beginner can build a very simple Morse station, and improve it as
knowledge and skill expand.

You may also have to find new arguments beyond those that the
FCC rejected in Docket WT 98-143, including yours.

That was 5 years ago. Things change. And if FCC just dumps Element 1, as they
may, the Tech and Tech plus can simply merge.

and I
remain skeptical that a Novice license (even a restructured one) is
viable today.

What we have now is a system that tends to funnel newcomers into VHF/UHF
amateur radio, and manufactured equipment. And away from HF and homebrewing.
A restructured Novice could change that.

Part of arguing for a new Novice license would involve identifying what
has not worked with the present Novice license, and what changes would
somehow "open the floodgates" with the proposed future one.

What didn't work was simply this: Getting a Novice required passing two tests
(code and theory) while getting a Tech after 1991 required passing just one. So
most new hams went for the Tech because it was perceived to be easier.

On top of that, the Novice didn't have 2 meters.

You argue
that most entry-level hams are being funneled to VHF/UHF.

They are. Look at the privileges. ALL of amateur VHF/UHF vs. four little slices
of HF.

might also
argue that there are not very many entry-level hams at all, especially
younger people, regardless of where they are being funneled.

Look at

http://www.ah0a.org

for numbers of new licenses granted each month.

In the past 12 months FCC issued 20,256 new amateur licenses. Is that "not very
many"?

The
youngest members in most clubs locally are well into their mid-30's.
The presence of teenagers has all but evaporated.

Why do you think that is?

What types of realistic homebrewing are you advocating for "NewNovice"
hams beyond 3-transistor OOK transmitters and single-conversion
receivers? Please be specific.

What's wrong with those sorts of rigs for a start? There are also
lots of good kits out there. And note that the "NewNovice" allows a wide
variety of modes.

What aspects of current communications
technology, something that would be used and would not be a trophy or
shop-project to be put on a shelf, can be realistically homebrewed via
commercially-available (and presently-manufactured) parts by high-school
age hams?

Lots of CW rigs, for a start. I built my first station from junk at age 13.

Do you think homebrewing is no longer practical? How about kits? Are
we to be nothing but appliance operators?

When you argue for "NewNovice" privileges, are you supporting it with 5
WPM code, or without?

I support a code test for *all* ham licenses. That probably won't happen, of
course.
But it's a good idea.

What if almost no one wants to sign up for 5 WPM
code as an entry-level requirement?

The ARRL proposal talks about how great the old Novice was in its heyday. 5 wpm
didn't stop hundreds of thousands of hams then - why should it do so now, when
we have more and better training methods?

The fact is that it's not the code test or the written test or the number of
license classes
which is/are the problem. It's things like lack of publicity, antenna
restrictions, and
competition from other activities.

73 de Jim, N2EY

"N2EY" wrote in message
...
[snip]
What didn't work was simply this: Getting a Novice required passing two
tests
(code and theory) while getting a Tech after 1991 required passing just
one. So
most new hams went for the Tech because it was perceived to be easier.


From the introduction of the no-code Tech until April of 2000, the no-code
Technician license required passing two tests: the Novice written and the
Technician written.

Dee D. Flint, N8UZE

In article , "Dee D. Flint"
writes:

"N2EY" wrote in message
...
[snip]
What didn't work was simply this: Getting a Novice required passing two
tests
(code and theory) while getting a Tech after 1991 required passing just
one. So
most new hams went for the Tech because it was perceived to be easier.


From the introduction of the no-code Tech until April of 2000, the no-code
Technician license required passing two tests: the Novice written and the
Technician written.

Right you are, Dee! I should have written "just one *type* of test".

Either way, the principle is the same - take two written tests on related
material, or one written and one code test.

73 de Jim, N2EY

In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY) writes:

In article , Paul W. Schleck
writes:

In (N2EY)
writes:

In article , Paul W. Schleck
writes:

In (N2EY)
writes:

In article , Paul W. Schleck
writes:

In (N2EY)
writes:

In article om, "Dee
D.
Flint" writes:


I brought this subject up with someone in the League. This exact
thread, actually. I was told that the ARRL BoD sincerely believes
(take
at face value, or not) that failure to upgrade licensees in the FCC R&O
for WT 98-143 was not a final "no" answer.

Maybe it wasn't. But are such freebies really a good idea?

It may be a realistic, and pragmatic, idea when considered against the
pros and cons:

Cons:

Provides a "free upgrade" to those that haven't explicitly tested for
it.

That's one. There are others:

- Allowing a free upgrade

*can be taken as*

proof that the material in the test which is not
taken is not necessary for the privileges.

To quote from the ARRL's FAQ on their proposal:

http://www.arrl.org/news/restructuring2/faq.html

"The fact is that the examination bar has never been at a uniform height
over ham radio's nearly 100-year history."

And I say: "So what? The question is whether there is any good reason to
give almost 60% of existing hams a free upgrade to the next license class,
even though the upgrade to that class requires only a written test from a
published pool.

Were you also opposed to giving pre-1917 hams a waiver for the 20 WPM
code test?

No such waiver ever existed. What *was* waived were the 20 wpm receiving and
sending code tests, plus the Extra written test. The person who got the
waiver had to hold at least a General license, too.

Now you're being pedantic.

I'm being *accurate*.

I was describing a subset of the waiver
given, enough for the purpose of the argument.
You described the entire
waiver. Both are correct, and neither contradicts my arguments.

I find it interesting that you mentioned only the code test part of the waiver,
not
the written test part. Some folks might think the waiver only applied to the
code
tests.

That was long before my time, too. And it affected maybe 2% of the licensed
hams at the time.

So you might accept grandfathering, if it occurred at some asymptotic
point in the past, and only affected a small minority of hams?

Depends on the situation. The old Extra waiver only began after there was no
difference
among the operating privileges of a General, Conditional, Advanced or Extra
(1952 or later). IOW it was
just a title sort of thing - didn't make any difference in practical
application. And anyone who qualified
for it was an OT from the very early days (35 years at least). By the time the
waiver meant anything
in terms of operating privileges, that gap was over 51 years.

According to W2XOY, the upgrade to Extra given to pre-1917 Hams with a
General or Advanced-class license started in 1951:

http://groups.yahoo.com/group/Ham-Ra...y/message/5330

along with the renaming of Class A to Advanced, Class B to General, C to
Conditional, and the introduction of the Novice and Technician.

So there was some short period of time (until the "Giveaway of 1953"),
where this "free upgrade" gave additional phone privileges on 75 and 20
meters for some of those pre-1917 hams. Specifically, those that held a
General class (formerly "Class B") license. That would be *accurate*.

More information on this, just received today, is given below.

That's a completely different scenario than offering a free *upgrade* to almost
60% of existing hams,
plus any that might get ham tickets before the rules change.

What
percentage would be a threshold? You say that it is wrong to
grandfather 60% of all hams, but you might be willing to accept
grandfathering of 2% of all hams.

And I might not. Depends on the situation.

And the more I think about it, the more I think the old Extra waiver was a bad
idea, and that there may be
no scenario that would be worthwhile.

What about a proposal that
grandfathers some percentage of hams in-between?

I say no to free upgrades, then.

So nearly all of the previous discussion above is moot because there is
no "free upgrade" scenario that you will support regardless of the
percentage of hams affected, or their status/seniority.

What would be your
greater objection, grandfathering all of the Techs, or grandfathering
all of the Advanced?

What's the difference? They're both bad ideas.

Prior to your latest reply, I might argue that since the latter would
affect a lower percentage of existing hams, who have held their class of
license since at least April 15th 2000, you might find it more
palatable. However, since you have decided that no such free upgrades
are a good idea, the distinction is now a moot point for the purpose of
this discussion.

Remember that at some time in the future, we may be looking on this
grandfathering as occurring at some asymptotic point in the past, as
with the pre-1917 waiver above.

You mean like when the Advanced has been unavailable for 35+ years and their
numbers are down to about 1% of the ARS total?

Well, yes, that's what I was driving at. You want to wait until then.
I want to deal with the matter sooner. At least I got you to explicitly
bound your answers tighter than "never" or 0%. And what would you do
then?

You ask below what is the long-term
plan. I say one aspect of the plan is to be able to look back on this
grandfathering in the same way that we look upon the pre-1917 waiver.

We don't look back on it the same way.

And why was it done?

The Restructuring FAQ at arrl.org omits the mention of waiver of the
written test, so it too is incomplete. I dropped a line to N1KB, who is
listed as the author of the document, with a request for correction and
clarification. He replied to me with pointers to some sources,
including Ham-Radio-History group noted above, which dates the origin of
the waiver, and "free upgrade," to 1951. W1UED just replied today with
an answer as to why. George E. Sterling, W1AE, was the first (and
likely only) radio amateur to come up through the ranks at the FCC and
be appointed Commissioner. The Amateur Extra license first appeared in
the 1920's and lasted through the 1930's, when it was discontinued as a
budget-cutting measure. During the 1951 restructuring, which restored
the Amateur Extra license, W1AE was an FCC Commissioner:

http://www.fcc.gov/commissioners/commish-list.html

As a pre-WWI licensee himself, he thought it would be an appropriate
honor to that group of hams if they were given the restored Amateur
Extra license, and had the political clout to make it happen. So, the
1951 restructuring gave anyone who was licensed prior to April 1917 and
who presently held a General or Advanced-class license, a "free upgrade"
to Extra.

The following QST article describes the 1951 Restructuring and FCC
Dockets 10073 and 10077:

http://www.arrl.org/members-only/qqn... 1&selpub=QST

(ARRL Members-Only Link)

A photocopy of the full article is available for $3 ($5 for non-members)
postpaid from the ARRL.

That still supports my original assertion that free upgrades given to
existing licensees, based on seniority or status, can be
non-controversial, especially when viewed from the long-term future.


- Amateurs who miss the one time upgrade have to take more tests than
those who didn't. How do we justify that?

It's called "grandfathering," which is done in more regulatory contexts
than can possibly be named here. Due to the need for certainty in the
law, it is nearly always based on hard cutoff dates. Technologies,
practices, and people change over the very long timeline that laws and
regulations are required to cover. It is not possible to predict the
future with certainty, so laws and regulations must change to reflect
current knowledge. It is also impractical for society to retest,
recertify, or revalidate every existing entity against current
requirements.

None of which is proposed.

But when considering alternatives, one really has to identify all
implicit alternatives, and argue for or against them (avoiding the
logical pitfall of false dichotomies, trichotomies, etc.). The status
quo, which you have advocated, and might be labeled alternative #4 based
on your exchange with Bill Sohl, is one such implicit alternative.

To put it simply: Just leave the closed-off classes alone, and let them
go away by attrition.

This is exactly what was done with the Advanced from the beginning of 1953
until 1967 - more than 14 years. What problems did it cause?

The Advanced-class was eventually opened back up to new licensees, so we
do not know what the longer-term effects would have been. I see no
realistic likelihood that Advanced will be (or even should be) reopened
in any foreseeable future. The outcome that you propose, which is to
carry them on the books for at least 35 more years or until they
constitute less than 1% of all hams, may introduce further problems than
the previous, and much shorter, 14-year period.

I
would argue against that, for the reasons I have given previously
(streamlining of license classes, streamlining of band plans, reduction
of regulatory burden, reduction in confusion for amateurs and the FCC,
harmonization with the deletion of S25.5 and with other countries'
regulations, etc.).

All it takes to keep those classes is a few sentences in Part 97.

"A few sentences" in laws or regulations can have non-trivial
implications about the regulatory infrastructure that is necessary to
give them force. An Advanced-class license is one more alternative to
program into the licensing computer, one more piece of regulation to be
understood and enforced by regulators, and overall, one more class of
amateurs to track and incorporate into any regulatory policies and
agendas. The implementation of all of that is significantly more than a
few sentences.


If license classes are consolidated to a smaller number, one alternative
is simply to grandfather existing hams, which the ARRL has advocated.

A more accurate term is "free upgrade", because that's what it is.

"Grandfather" implies letting a person keep what they already have without
recertification. That's not what is proposed by the ARRL BoD for Techs and
Advanceds.

One other implicit alternative (say, #5), is to make every Novice,
Advanced (and possibly non-Plus, or would that be non-Plussed, Tech)
come back in to take written tests to upgrade to the next level, or
otherwise lose privileges.

That's the worst alternative.

Which is why I specifically identify it and dismiss it early.

I would argue against that also, for the
reasons I have also given previously (it is impractical to retest
everyone,

It could easily be done over time by saying that you either retest before Date
X
or you'll be reclassified at a lower license class.

There is a legitimate distinction between "easy" and "straightforward."
Anyone with engineering experience surely knows that something could be
conceptually simple, but still complex and time-consuming in its actual
implementation. Mass re-testing might be straightforward, but would not
be easy within FCC and VEC budget/manpower constraints.

Mass re-testing would be a regulatory burden for the FCC, a personal
burden on VEC's who would have play de-facto judge and jury for large
numbers of existing peers, friends, fellow club members, etc.,
concerning whether or not they could retain former privileges (what
volunteer would want to endure that for very long?), and would go
against where the FCC is heading, which is towards less regulation and
fewer grand schemes. I might also argue that mass-retesting is sounding
very much like a repeat of the scenario played out in the 1960's with
Incentive Licensing.

There's a lot of debate in this newsgroup about the Incentive Licensing
scheme of the 1960's, who initiated it, what was intended, who supported
it, why it failed, who was to blame, etc., but one thing that most can
agree on is that it's very easy to start out with good intentions, and
what comes out the exit door of regulatory agencies might be
unrecognizable as something that would give the desired result. Hence
the expression, "The road to hell is paved with good intentions." Mass
re-testing could also be viewed as well-intentioned, but ultimately a
road to hell.

So, it's a good thing that neither of us are arguing in favor of testing
to avoid losing privileges, right?

and such existing hams are a large, stable user base such as
that in the definition of grandfathering below).

"Large, stable user base"? We don't really know about that. How many
of those folks are active? Why have so few Advanceds upgraded to
Extra?

You are teetering very close to making a non-falsifiable argument here.
You argue here, and in other threads, that Advanced should be left alone
because:

- There are still quite a few of them, who are happy with their present
privileges, who would get a free upgrade unfairly, and crowd the Extra
phone bands.

*AND*

- There may not be very many of them, active at least, so any upgrade
would not give much benefit, anyway.

You also argue that Novice should be left alone because there aren't
very many of them, but then advocate restructuring that you believe
would bring back its "heyday" with many more licensees in that class,
which of course, should then be left alone.

Which is it? Too many, or too few, to justify elimination? If neither
is a sufficient criteria to argue for or against elimination of a
license class, then that's a non-falsifiable argument.

The web site for Malvern Instrumentation gives a good definition of
grandfathering in a technical context:

"Grandfathering is the practice of claiming exemption of older systems
from validation regulations and requirements on the basis that these
systems have proved their reliability by adoption for a long period of
time by a large user base."

IOW, we allow them to continue doing what they're doing because they've shown
a lack of problems in the past. But we require more of new systems.
It *doesn't* say we allow free upgrades.

When you say "we require more of new systems" above, are you referring
to people or license classes? There is a subtle distinction. A group
of people may not want to change, but license classes may need to. A
set of license classes is a ladder, to be climbed as far as the licensee
wishes to develop his skills. It is also a taxonomy, with a specific
regulatory purpose. That purpose is to ensure that limited frequency
spectrum is being put to the best and highest use via the distribution
of privileges over that spectrum. Implicit in this is structuring the
license class system to ensure that all amateur radio spectrum (HF, VHF,
UHF, Microwave) is not only used, but used well, in ways that fulfill
the Basis and Purpose (FCC Part 97.1).

Since technologies, modes, and frequency usage patterns change over
time, the taxonomy should change as well, hence the need for periodic
restructuring over amateur radio's 100-year lifetime (Though I would
argue that not doing the "Giveway of 1953," and staying with the 1951
restructuring until the no-code issue came to a head in the 1980's,
would have avoided the backlash that resulted in Incentive Licensing of
1968). But what do you do when license classes change and people do
not? It is preferable to not have existing licensees lose privileges.
There is no compelling regulatory purpose to having both an Advanced and
Extra class license at present (if there ever was). So, given all of
that, combining both licenses into one class of license is a way of
making existing people fit new license classes without having them lose
privileges. Doing this constitutes a form of grandfathering.


Grandfathering in the context of ham radio recognizes that existing hams
have not only passed the tests in effect at the time, sometimes topics
not covered presently (Morse code, drawing circuit diagrams, etc.), but
have also gained experience beyond their initial exam topics. It is a
fair, and pragmatic, distinction between existing hams and entry-level
ones. Quoting again from the FAQ document:

"Passing any amateur examination does not magically result in a good
operator. It's just the key to the kingdom, so to speak. Experience and
good mentoring create skillful and knowledgeable operators, not the
relative difficulty or ease of the test."

I disagree with that assessment. YMMV.

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

I disagree. What's wrong with simply allowing Techs, Tech Pluses and
Advanceds to upgrade in their own time?

What is the sudden need to eliminate those license classes? The Novice and
Advanced have been closed off to new issues for almost 4 years, and their
numbers have declined. And from 1953 to 1967, no new Advanceds were issued.
Did any of that cause problems?

What's the rush?

Are the written tests too hard?

Well? The current Extra was recently earned by a bright seven year old - can
we really say that it's unreasonable to expect others to do what she did for
the
same privileges?

As others have pointed out in other threads, the 7-year old Extra is a
statistical outlier, one of a handful in amateur radio history, and not
a typical example. The more typical, and meaningful, example of an
entry-level ham would be one who was high school or college-age. The
greater numbers of these typical entry-level hams would mean that they
would have a more profound impact on the shaping of the future of
amateur radio, anyway.

- Decreased reason for more than half of all hams to upgrade by testing.

No proposal is perfect. Weigh this one against the pros.

I have. The cons win.

Pros:

Avoids having to wait until the last Advanced class license expires to
refarm the Advanced phone bands.

Why does that have to be done at all?

So, are you advocating not refarming the Advanced phone bands even
*after* the last Advanced class license expires? Yeah, that's a
semantic nit-pick over what you wrote above, but then so is "You mean
the BoD. I'm the ARRL too, remember?" that you wrote below.

You're avoiding the question.

Why do the Advanced class subbands have to be "refarmed" at all? Who or what
would they be "refarmed" to? What's the longterm plan?

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Why does it need to be done at all? Is the Extra written that hard?

Why do you avoid these simple questions?

Because sometimes simple questions are loaded with built-in assumptions
(e.g., "Why won't you join me in voting to ban COP-KILLER bullets?" or
even the classic, "Have you stopped beating your wife?"). Furthermore,
you see simplicity where I see complication, and vice-versa.


So you would argue that any refarming would be done at some asymptotic
point in the far future, indistinguishable at present between "decades"
and "never."

I'm *asking* what the problem is with leaving some things alone.

The question has been asked and answered, though I have given you an
answer you disagree with. Asking the question repeatedly will not
result in a different answer from me. Put away the rhetorical bludgeon.



Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

I don't see any reason to "refarm" them at all. Not at this time, anyway.

Note that in 4 years, the number of Advanceds has dropped by only about 16%.

Seems to be a pretty popular license even today.

Note also that several Advanceds have said they *don't* want an upgrade, free
or not.
I don't understand why, but that's what they've said.

It sounds to me like you want all Advanceds to become Extras so that the
Advanced subbands can become General bandspace. That's not part of the ARRL
proposal, though.

No, I never said that.

No, you didn't. That's why I wrote "sounds to me".

My first draft of my reply said, "No I never said nor implied that." I
edited it to achieve economy of words, because even if I somehow implied
that I supported the entire ARRL proposal, adoption of that proposal
would not giving the entire Advanced phone subbands to the Generals.

I would combine Advanced and Extra phone bands
into just Extra phone bands, and leave the General bands as they are.

That's the status quo! It's not "refarming" at all.

It still removes one color bar from the frequency allocation charts (for
Advanced), so is not strictly a "status quo" solution like you have
advocated.

I suppose a definition of refarming is necessary for this context. Even
the ITU seems to struggle with the meaning of this word (search for
"definition of refarming" on Google). A commonly-accepted definition
is:

"Moving one service out to make way for another that would use the
spectrum more optimally."

So, really, neither of us are using the word entirely according to this
definition. Even if we substitute "class" for "service" above, no
General, Advanced, or Extra is being moved out to make way for anyone
else under the two alternatives offered in this discussion (mine, and
the ARRL's). Even Novice and Tech Plus hams only face a "lose some, but
gain a lot more" prospect under the ARRL proposal. You would define
refarming as making different license classes within the same service
either gain or lose spectrum. I would agree that this would constitute
one kind of refarming. I would also assert that the elimination of
license classes within a service to simplify spectrum allocation is
another kind of refarming.

That doesn't mean that I wouldn't support frequency shifting, such as
that proposed to make 40 meters a primary amateur allocation, or part of
Novice band refarming. Just that I would keep the proportional amounts
roughly the same. I realize that the current ARRL proposal splits up
the Advanced phone bands, giving proportionally more to the General than
the Extra phone bands on 80 and 40 meters, and proportionally less on 15
meters (no changes on 20 meters). I do not strongly support that, but
even that proposal isn't giving the entire Advanced phone bandwidth to
the Generals.

And if nothing at all is done, the results are almost the same as what you
propose.

Emphasis on "almost." One of my motivations in this extended discussion
is to determine our agreements and disagreements, what are hard-and-fast
beliefs, and what might be open to compromise. In case you haven't
figured it out, I'm gathering verbage for a draft of my comments on any
future NPRM. You seem to be alternating between active opposition to,
and fatalistic acceptance of, the possibility that Element 1 will be
deleted. Perhaps you want to "go down fighting" on this issue with the
ARRL and the FCC. Your ideal-world position of no changes allows me to
rebut with the continued complications that it implies. On the other
hand, I too believe that Element 1 being dropped is likely, but I also
believe that changes to license classes and band allocations are still
very much up in the air at this point. Because of this, I will happily
play "what-if" with the various scenarios (as the FCC might do them in
any combination) while also indicating which ones that I favor.

So that there is no further confusion about what I favor, I support
dropping Element 1 (which would merge Technician with Technician-Plus),
giving present Advanced-class licensees a "free upgrade" to Extra, and
keeping General and Extra-class phone bands substantially and
proportionately the same (save for some small shifting/resizing for
Novice-band refarming and making all of 40 meters a primary amateur
radio allocation).


Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus.

Whatever. I don't see why the 5 wpm code test is such a big deal as a
requirement.

Does your "Whatever" answer above mean that you support 5 WPM Morse code
for all HF license classes, or just for Extra?

I support a code test for all amateur licenses, period. I think the dropping of
the
code test for the Tech back in 1991 was a mistake. I argued and commented
against it then, and much of what I said would happen has come to pass.

The FCC's Electronic Comment Filing System (EFCS) only goes back to 1992
and your callsign doesn't appear in Google Groups until 1997. Would you
mind elaborating on what you thought would happen, and what you think
has come to pass?

If the former, then
there is a very real distinction that will continue to exist in the
license ladder whether or not it continues to be recorded in the
database. If so, then the expiring of Tech-Plus license in 6 years is
not a simplification, it is a complication.

That's still a long time in FCC
enforcement (and VEC administration) years.

Why? It's been almost 4 years since the last restructuring took effect. Look
at the enforcement letters - Techs without code masquerading as Tech Pluses
isn't a big problem, from what I see.

You argue that it's not an enforcement problem because few or none have
been caught. I would argue that it is an enforcement problem because it
would be very hard to catch someone, especially if confirming who has
what privileges requires documentation that is no longer in the FCC
database, and might no longer be retained by hams or VEC's. The FCC's
limited staff time is probably being aimed at big fish, such as Advanced
and Extra-class scofflaws engaging in power and interference violations.

You might want to read the letters. They're pretty evenly distributed, license
clas wise, except for Novices.

I have read them. Even if they are evenly distributed in numbers, they
are not evenly distributed according to number of licensees in each
class. If they were, then there would be approximately one Extra-class
violator for every three Tech/Tech-Plus violators, or every 1.5
General-class violators. I stand by my original argument.
Specifically, that the FCC's enforcement agenda is mostly aimed at
high-yield (easier to catch/more serious punishment, aka "big fish")
violations "such as" (i.e., not limited to) power and interference
violations at higher classes of license. Such licensees are being
subject to proportionately more enforcement scrutiny than other classes
of license.

Even if you argue that FCC
action on further restructuring will take most of that six years anyway,
there are still all those Novice and Advanced class licenses that will
likely exist in the database for decades to come.

It makes sense to grandfather existing Novices to the "NewNovice" (or
whatever
it is called). There are only about 32,000 Novices left now, down from just
under 50,000 after restructuring.

What *is* the problem with Advanceds just staying as they are? Have you not
read from the Advanceds who say they *don't want* to become Extras?

Which is as much of an argument as "Have you not read from the hams who
say that they *don't want* to have ham radio examinations without Morse
code?"

You keep avoiding the question.

You keep avoiding my answers.


Why not just give all the existing Techs, Tech Pluses and Novices the
"NewNovice" privs, in addition to their existing privileges? The database
doesn't need to change at all.

Did you notice that Novices actually lose privileges? See the FAQ
document above for more details. In particular, power limits are
lowered from 200 Watts PEP to 100 Watts PEP on HF bands except for 10
meters, and 50 Watts PEP on 10 meters.

Is that really much of a problem? How many Novices are on the air today
running more than those power levels?

Well? You know the answer as well as I: "Very few".

The same argument could also apply to Tech/Tech-Plus, as "very few" of
them operate below 30 MHz between 100 and 200 Watts either (though
significantly more might operate between 50 and 100 Watts on 10 meters).
The simplest alternative is to make Tech lose privileges, in the form of
reduced power limits, below 30 MHz in order to have one Novice/Tech set
of privileges on those bands.

Did you change your mind on this issue? According to the following
recent posting of yours:

http://groups.google.com/groups?selm...mb-m14.aol.com

you advocate doing just that. No argument from me, but it does suggest
that you realized the additional complexity of trying to both fold
NewNovice privileges into Technician *and* keep Technician from losing
privileges, so decided against keeping the latter constraint.

From the FAQ:

"The reason behind the change in Novice power limits is to avoid having
to examine entry-level applicants about how to evaluate amateur stations
for RF safety. "

I'm sure that you would argue that Technicians should retain their power
limits (1500 Watts PEP) on 6 meters and up, and I would agree, but what
about HF? Should Technicians lose privileges on those bands, by having
their power limits lowered (from 200 Watts PEP), or should there be
separate power limits for Novice and Technician on HF? This is starting
to get more complicated than before.

Not at all! Where an existing ham has greater privs, those privs would be
retained. This has been done with Tech Pluses for almost 4 years now. FCC
proposed it and enacted it, btw. Why can't it be done for existing Novices
and Techs?


But you agree that it would be a better idea to have just one set of
Novice/Tech privileges below 30 MHz even if that means Tech might lose
privileges due to lower power limits on those bands?

So, again, as part of your status-quo alternative, you want to keep in
place the regulations and bandplans for six classes of license, only
five of which will be tracked in the FCC database six years from now.

Why not? Most of that is just a few lines in Part 97.

The 1998 proposal from ARRL Hq was for Tech Pluses and Novices to get a
freebie
to General - and FCC said no. What has changed that suddenly makes free
upgrades a good idea?

The ARRL argues that this is now the second round of restructuring.

Then why wasn't the BoD ready for it?

They were probably as "ready" for it as they were for the first round of
recent restructuring in 1998-2000, or even the multi-year build-up to
the 1991 Report and Order for the no-code license. Maybe they want to
cross bridges when they feel that they have come to them? Maybe they
will act decisively if and only if there is the possibility they will be
left behind (such as from other parties submitting competing proposals
that are assigned RM numbers)? Maybe their inside-the-FCC spy only now
just phoned Newington with the coded message, "Raven is moving on
Morris, repeat, Raven is moving on Morris," and they are now busy trying
to channel the spirits of Hiram Maxim and Vic Clark for guidance? You
tell me.

The FCC prefers to revisit things every few years, and do things in
manageable chunks.

Meaning no disrespect, but - how do you know?

Because an interested observer can see that this is how the FCC wants to
do business these days, via biennial regulatory reviews. Among other
things, it makes Congress happy that the FCC continues to "improve"
itself by reviewing regulations every couple of years. The FCC also
wants to make sure that it leaves enough for future rounds.

And if that is, indeed, the case, why not make a few changes now
(like the "NewNovice") and revisit in a few years?

It is likely that the FCC will move on deletion of Element 1 very
shortly, now that S25.5 is being deleted and there are several proposals
on the table that have been assigned RM numbers to deal with this event.
Your recent poll conducted on this newsgroup has most predicting action
on this matter sometime in 2004:

http://groups.google.com/groups?selm...mb-m11.aol.com

What is less clear is what other types of reorganization the FCC might
choose to adopt at this time. The Novice-band refarming proposal has
been on an FCC staffer's desk for about two years now. You might argue
that this is a sign that it would be rejected. I might argue instead
that the FCC is waiting for wrap-up of all related issues, including
S25.5, and to approach Novice-band refarming as part of a periodic
review. If this is a "window of opportunity" that might not come again
in a while, and it is uncertain which proposal items the FCC might
choose, a good strategy would be to put all reasonable proposal items on
the table, especially if they can be argued to be interrelated to one
another as part of an overall, long-term plan.

Your suggestion above, to "make a few changes now" and "revisit in a few
years" might be reasonable *if* we controlled the agenda. We don't, the
FCC does. Because of this, omission of some items now, in a misguided
attempt to dictate what should and shouldn't be done, and in what
timeframe, might cause FCC to later ask, "Why didn't you bring this up
before?" or worse, "What are you trying to hide?"

What is driving this second round is the lifting of
the S25.5 requirement, the eventual need (in the ARRL's opinion, and
mine) to address the shrinking pools of Novice and Advanced class
licenses, as well as the fact that there will be no distinction in the
FCC database between two classes of licenses with different privileges
(Tech and Tech Plus) in the very near future.

Let's take those one at a time:

"shrinking pools of Novice and Advanced class licenses"

If the Novice is reopened to new issues and existing Novices get NewNovice
privileges as proposed by the BoD, the Novice shrinkage should stop.

Advanceds are shrinking at a very slow rate (16% in almost 4 years) so there's
no hurry in dealing with them.

"there will be no distinction in the FCC database between two classes of
licenses with different privileges
(Tech and Tech Plus) in the very near future"

Part of the proposal is for the code test for all but the Extra to go away, so
the difference between
Tech and Tech Plus becomes moot unless someone wants to get an Extra - at which
time all they
need do is present their old license or other document for Element 1 credit.

Or they can just take the code test!

So that's not an issue either.

Rather, it is just one of
the unresolved loose ends that was deliberately not tied up until
better
consensus emerged from the amateur radio community about things like
Novice band refarming, etc. The League official noted that the ARRL's
band refarming proposal, RM-10413, has been sitting on an FCC
official's
desk for about two years now (he claims to know the exact FCC official,
but did not name him). Because of this, as long a wait, if not longer,
is expected on a "final" answer concerning automatic upgrading.

I say we should judge by actions. When FCC thinksa proposal is a good or
bad
idea, they act. How long did the whole 98-143 process take, from initial
release of the NPRM to the new rules in April 2000?

More important, what would a lack of free upgrades hurt? Is it really
such a
burden to require an Advanced to pass Element 4, or a Tech to pass
Element 3, in order to get the next higher grade of license?

I think the ARRL may be politically shrewder than some would give them
credit.

You mean the BoD. I'm the ARRL too, remember?

Yes, I meant the governance of the ARRL when I used the shorthand "ARRL"
in the context of offering an opinion on a BoD decision. Only they can
establish ARRL official policy and petition the FCC in the name of the
ARRL. Who else did you think I meant?

Those folks are elected and paid for by members like *me*. They supposedly
make those proposals in *my* name and with *my* support.

Well, I don't support everything in that proposal.

Welcome to the realities of representative democracy.

Been there since 1968 with ARRL.

Both of us pay
dues to the ARRL and elect Directors. They make proposals in both of
our names. I don't support everything in that proposal either, but it
is an ARRL proposal. You and I are perfectly free to submit comments to
the FCC as "ARRL Members," but the ARRL Board of Directors will submit
comments to the FCC as "*The* ARRL."

Which will be done in my case, as was before. The BoD needs to realize,
however, that the ARRL's position is weakened by proposing things that
much if not most of the membership opposes.

How much of the ARRL proposal in 1998 got enacted?

You will need more than a rhetorical question to make an argument here.
Instead, why don't you just come right out and say, for the benefit of
the audience, which items in the ARRL proposal got enacted, and which
ones didn't? And, of those that didn't get enacted, which ones you
think have already been given a final "no" answer?

All right.

Fact is, almost nothing proposed by ARRL Hq in 1998 got enacted. 5 wpm for
General, that's about it. On everything else, FCC either:

- said no: free upgrades, better written tests, Techs on HF CW without a
formal test

- went far beyond what was requested: 5 wpm Extra, Advanced closed off,
written testing reduced dramatically

They can turn to the reformers and say, "See, we're giving you
a both a Novice and General HF-class license that doesn't require Morse
Code." To the old-school (and long-time, dues-paying) members they can
at least imply, "We recognize that the Morse Code tests you took in the
past are valuable, so we are going to reward you with a higher class of
license. Then you will always know that you are better than anyone who
gets a General or Extra class license under the reduced standards in the
future."

Avoids the subject of why free upgrades are needed.

But does address the subject of why they may be politically desirable,
not only by leading to simplified FCC regulations, but also resulting
in a more harmonious and productive amateur radio in the future by
addressing most of the concerns of most factions.

I don't see that at all. Are the written tests so difficult, and the VE test
process so onerous, that free upgrades are the only answer?

I say they're not.

So you've said. I'm sure that you will also say this to your
representatives within the ARRL and comment on any future FCC NPRM on
the subject.

Already have. In detail. More to come, too.

I will, too. For the record, I'm not in complete
agreement with the ARRL proposal, either. I don't see the regulatory
justification for the retention of 5 WPM Morse code for Extra,

I do. Morse code is a big part of amateur radio, and having no code test at
all simply denies the reality of that.

I'm sure that you will argue in more detail than "Morse code is a big
part of ham radio, and having no code test simply denies the reality of
that."

OK, here's some mo

One of the Basis and Purposes of the ARS is technical education and skill
development.
IOW, hams learning about how radio works. Morse skill helps in this area
because Morse-capable radio equipment can be made using a very wide variety of
technologies and complexities.

IOW, the beginner can build a very simple Morse station, and improve it as
knowledge and skill expand.

You may also have to find new arguments beyond those that the
FCC rejected in Docket WT 98-143, including yours.

That was 5 years ago. Things change. And if FCC just dumps Element 1, as they
may, the Tech and Tech plus can simply merge.

Yes, but if you oppose dumping Element 1, then you oppose merging Tech
and Tech Plus. You assert that there isn't a problem either way. I
disagree. But there is that distinction, and two "what-if" scenarios.

and I
remain skeptical that a Novice license (even a restructured one) is
viable today.

What we have now is a system that tends to funnel newcomers into VHF/UHF
amateur radio, and manufactured equipment. And away from HF and homebrewing.
A restructured Novice could change that.

Part of arguing for a new Novice license would involve identifying what
has not worked with the present Novice license, and what changes would
somehow "open the floodgates" with the proposed future one.

What didn't work was simply this: Getting a Novice required passing two tests
(code and theory) while getting a Tech after 1991 required passing just one. So
most new hams went for the Tech because it was perceived to be easier.

On top of that, the Novice didn't have 2 meters.

All true. But if Element 1 is dropped, and no other changes are made,
then the current Tech becomes what the former Tech-Plus was, with HF
privileges and one exam. Sounds simple to me. Why can't that serve as
an entry-level license? Why try to resurrect the dead-horse of Novice?
Could it be that people are willing to take a harder exam to obtain more
attractive privileges?

You argue
that most entry-level hams are being funneled to VHF/UHF.

They are. Look at the privileges. ALL of amateur VHF/UHF vs. four little slices
of HF.

I don't disagree. That's why I said, "I might also argue..." below
instead of, "I might argue instead..."

I might also
argue that there are not very many entry-level hams at all, especially
younger people, regardless of where they are being funneled.

Look at

http://www.ah0a.org

for numbers of new licenses granted each month.

In the past 12 months FCC issued 20,256 new amateur licenses. Is that "not very
many"?

The answer is more complicated than that. Numbers of new amateur
licenses sounds great on paper, as it would be about 3% annual growth.
However, this does not take into account the number of amateurs leaving
from non-renewal, or even how many of them were very active in the first
place. Even AH0A touches on this subject at the following link on his
site:

http://www.ah0a.org/FCC/Rate.html

Quoting AH0A:

"If the number of new amateurs being added every month (through renewal,
upgrade, or as new amateurs) were equal to those expiring, the average
time to expiration should remain the same. Assuming that the
distribution of the times to expiration was constant over the future 120
months, the expected value would be 60 months.

A number less than 60 months would mean that the class of licensees is
decreasing. Looking at the Chart 1. you can see this is the case for
Novice, Technician, and Technician Plus licensees.

In Oct 2000, the average life of licenses for the entire Amateur
population will drop below 60 months. Within a year the number of
U.S. Amateurs will begin to decline."

Has AH0A's prediction come to pass? Well, according to:

http://www.ah0a.org/FCC/Licenses.html

we're not dropping precipitously (yet), but our total numbers have been
flat (within a variance of less than half of one percent) for at least
the past 6 years.

But let's look at those 20,000 or so new hams again, as I did argue
"new" and not "overall." Making the slightly inaccurate, but
simplifying, assumption that distribution of those new hams is
proportional to that of the entire U.S. population, that would mean 50
new hams being licensed last year in my local community (based on
population figures for my Metropolitan Statistical Area, or MSA). Wow!
*FIFTY* new amateurs per year! We could certainly make good use of each
and every one of them. We have lots of choices available that would
welcome new volunteers with open arms:

- Local ARES and RACES organizations (especially with a recent influx of
money and training opportunities due to Homeland Security)
- Weather training and spotting
- HF and VHF nets, including informal commute-time repeater nets
- DF Fox Hunts
- Field Day
- USAF MARS (where not only do you have HF privileges as a Technician, but
there is an active user community for more advanced digital modes like
MT63 and MFSK16)

or just as dues-paying members of local clubs, who can socialize with
our experienced members, learn things from club programs, and undertake
their own station projects with guidance from our Elmers. Field Day is
not the only opportunity to guest operate an HF station if you do not
have one of your own. We have even had local club members open their
homes and well-equipped HF stations to any and all interested guest
operators for special operating activities such as club anniversaries,
QSO parties, Veteran's Day, etc.

Oh wait, where did they all go? All of the above activities are starved
for new volunteers, and have exhibited flat or negative growth in recent
years. I look around at all of the above activities (metaphorically so
on the bands) and I see substantially the same people I have seen for
the last several years.

So, to answer your question, yes, that is "not very many."

The
youngest members in most clubs locally are well into their mid-30's.
The presence of teenagers has all but evaporated.

Why do you think that is?

Weeelll, since you asked...

One important feeder for amateur radio, especially those with strong
technical and operating skills, and who will persist in it well into
adulthood, is college radio clubs. Another is the military.

The ARRL, at least during the timeframe that I was involved in college
club leadership (mid to late 1980's), seemed to focus its youth programs
at too young an age to make a significant difference. A lot of focus
was on getting elementary school-age hams to qualify for Novice tickets,
despite the evidence that very few of them were going to stay with us
long-term. Individual Field Organization officials were supportive of
us (most notably W3ABC and the county EC, whose WB3 call I now can't
remember). However, the ARRL as a whole seemed rather indifferent to
college clubs, and not very helpful in providing publicity support in
the form of PSA's, pamphlets, etc. Their materials seemed to either be
aimed at children (Archie comics) or retirees (pursue a hobby with your
copious money and spare time!). When I discussed this with one of our
late-1970's alumni, who worked at the League for a while after
graduation, he agreed, stating that he wanted to update the materials,
but was overruled by higher-ups who wanted to persist with traditional
styles of recruitment.

League indifference was one issue. Perhaps they expected that we could
fend for ourselves. University indifference was another. EE students
found faculty either ignorant ("I didn't know there was a ham club on
campus") or hostile (One of our members raised his hand in a lecture, in
response to the professor asking if anyone was a ham, because the topic
of the lecture was SWR, and hams would have a good understanding of it.
Later discussion with the professor by that member indicated that he
disliked hams in general.) Efforts by some of our MSEE student members
to set up an analog RF design class (intended for upper-class
undergraduates who have already taken the introductory electronics,
electromagnetics, and modulation methods courses) were stymied by the
fact that the only faculty member who was interested in teaching such a
class was now retired. He might be able to teach such a course once,
but it would not be a well-integrated, and long-term, part of the
curriculum.

All of this was unfortunate, because word back from some of our EE
graduates who went on to RF engineering careers (one working on
microwave measurements at a government laboratory in Maryland, the other
working for a certain communications and avionics systems manufacturer
in Iowa) was that they found the BSEE curriculum oriented more towards
sorting and filtering of students than with actually educating those
students and imparting useful information. The oversized curriculum was
intended to cover state professional licensing exams and provide a
"grand tour" of topics to allow future graduate students to make an
informed choice when they later specialized. Both said that they would
have been at a significant professional disadvantage if they had not had
the hands-on background in RF that amateur radio offered them. Their
advice? Sure, pursue the degree, as that is the only way to get into a
professional engineering career these days. Just don't expect it to be
a climb-the-mountain-and-see-God experience. Take advantage of as many
opportunities as you can to get hands-on experience, including co-ops
and technical hobbies like amateur radio, because the curriculum alone
will not even come close to providing it.

It also saddens me to see a fine, mostly self-supporting, radio club
like W3ADO at the U.S. Naval Academy have to defend itself against
closure. It was even necessary to (politely) correct command's
perceptions, which was something like, "Amateur radio, is that still
around?" Though many midshipmen will graduate with engineering degrees,
very few officers will serve as professional engineers in the Navy.
Rather, they will draw on that expertise to command ships full of
highly-qualified technicians working on many advanced technological
systems. The radio club, with its well-equipped station and numerous
successful projects (enumerated in my letter linked below), offers one
of the few opportunities for such officers to gain hands-on experience
in RF engineering before joining the fleet, and thus be able to better
command that which they better understand.

A letter-writing campaign, in which I participated:

http://sacmarc.novia.net/hypermail/a...0/01-w3ado.txt

helped save the club, for now. I would like to thank fellow newsgroup
participant Larry Roll, K3LT, for joining me in this campaign. However
indifferent the League may have been to college clubs in the past, they
also wrote in defense of W3ADO.


What types of realistic homebrewing are you advocating for "NewNovice"
hams beyond 3-transistor OOK transmitters and single-conversion
receivers? Please be specific.

What's wrong with those sorts of rigs for a start? There are also
lots of good kits out there. And note that the "NewNovice" allows a wide
variety of modes.

Actually using a CW rig requires at least some proficiency in Morse
code. Not only are entry-level hams eschewing that, but so are most
experienced hams, if trends and surveys are any indication.
Furthermore, the ARRL-proposed NewNovice does not require a Morse code
test. Such a CW rig could be built, but would it be used? Even if it
is just a base project for learning purposes that would later be
extended, what kind of homebrewing agenda, and timeline, would you
advocate to get to something that would be practically usable in modes
other than CW?

What aspects of current communications
technology, something that would be used and would not be a trophy or
shop-project to be put on a shelf, can be realistically homebrewed via
commercially-available (and presently-manufactured) parts by high-school
age hams?

Lots of CW rigs, for a start. I built my first station from junk at age 13.

I left the door wide open for you to suggest lots of other kinds of
homebrewing, but you went right back to CW rigs, using examples of what
you built over 35 years ago. I can think of a few others that I think
entry-level hams should attempt in the present day. For example:

High school students should be able to homebrew:

- Patch cables, control harnesses, and connection terminations from bulk
wire and connectors

- Antennas and feed systems, again from bulk materials

- IC-based timer and microcontroller circuits from commonly-available
electronic parts

Implicit in the above is learning to make the correct choice of
components, both parts and bulk materials, appropriate for the desired
performance, specifications, and overall design. These types of
projects would be a good opportunity to learn how to use a multimeter
and an oscilloscope. Mechanical and fabrication skills, including
soldering, would also be developed.

For college students:

- Software-based radios (ever heard of GnuRadio)?

I put this one in the college-age category, because being able to design
and implement software-based radios would be helped by sufficient
knowledge of Digital Signal Processing (DSP) theory, and much of that
(at least the derivations and proofs) is based on calculus and
differential equations. Proper computer programming education would
occur at this time, also.

Do you think homebrewing is no longer practical? How about kits? Are
we to be nothing but appliance operators?

No, I think that homebrewing is practical, I just disagree with what
kinds of homebrewing are desirable. I read your comments in FCC Docket
WT 98-143, did you read mine? They are available in the ECFS. I do
address this issue there.

Kits are now enjoying increased popularity even without changes to
amateur radio licensing, though they no longer have the cost advantage
over commercially-built gear that they did when Heathkit was in its
heyday.

When you argue for "NewNovice" privileges, are you supporting it with 5
WPM code, or without?

I support a code test for *all* ham licenses. That probably won't happen, of
course.
But it's a good idea.

One simple, nearly status-quo, outcome that the FCC might pursue in
response to the deletion of S25.5 is to drop the 5 WPM code requirement
by eliminating Element 1. If so, then the Tech/Tech-Plus distinction
goes away, and the Novice/Tech HF privileges would be usable by
operators from the numerous ranks of Technician. That might also be
considered a "good idea."

What if almost no one wants to sign up for 5 WPM
code as an entry-level requirement?

The ARRL proposal talks about how great the old Novice was in its heyday. 5 wpm
didn't stop hundreds of thousands of hams then - why should it do so now, when
we have more and better training methods?

Because we are long past the Novice's heyday, and few want to sign up
for Novice today. Prospective amateurs "vote with their feet" in
seeking out the Technician class license as an entry-level license. One
plausible reason for this is the CW test, as even you alluded to above.
Maintain the CW test, and you continue to funnel amateurs away from
Novice and HF. As noted above, a simpler test is not a panacea, because
people are willing to take a harder test to get more desirable
privileges. Again, what is the necessary ingredient that is missing?
We already have "more and better training methods", we have a pool of
applicants that are willing to take a harder test to get more desirable
privileges, and we even have lots of potential homebrew projects to make
simple CW transmitters and receivers. Why do few people want to sign up
for that nowadays?

Even under the ARRL proposal, the proposed NewNovice license does not
impart enough knowledge, nor does it grant enough privileges, to be
suitably attractive to make it a viable entry-level license, in my
opinion. Especially if it has to be justified strongly enough either to
exist as a fourth open class of license, or introduce more free upgrades
(such as from Tech/Tech-Plus to General) to keep the number of open
classes limited to three.

The fact is that it's not the code test or the written test or the number of
license classes
which is/are the problem. It's things like lack of publicity, antenna
restrictions, and
competition from other activities.

All of the above are challenges for amateur radio, but which of the
above do we have the most control over, and thus the greatest ability to
solve? How would you propose to solve each of them?

I notice you making the "lack of publicity" argument in this newsgroup
since at least 2000, and discussing some specifics in later postings.
Obviously you and I don't have the budget and manpower to do national
campaigns. Only the ARRL is big enough to do that. Have you talked to
ARRL officials about this? What are their answers? Even if the ARRL is
unmoveable on this issue, we can still make a difference locally. What
have you done locally in the past four years to better publicize amateur
radio? How did it work out?

73 de Jim, N2EY

--
73, Paul W. Schleck, K3FU

http://www.novia.net/~pschleck/
Finger for PGP Public Key

Paul W. Schleck wrote in message ...
In (N2EY) writes:


(old stuff snipped to save bw)

So you might accept grandfathering, if it occurred at some asymptotic
point in the past, and only affected a small minority of hams?

Depends on the situation. The old Extra waiver only began after there was no
difference
among the operating privileges of a General, Conditional, Advanced or Extra
(1952 or later). IOW it was
just a title sort of thing - didn't make any difference in practical
application. And anyone who qualified
for it was an OT from the very early days (35 years at least). By the time the
waiver meant anything
in terms of operating privileges, that gap was over 51 years.

According to W2XOY, the upgrade to Extra given to pre-1917 Hams with a
General or Advanced-class license started in 1951:

http://groups.yahoo.com/group/Ham-Ra...y/message/5330

along with the renaming of Class A to Advanced, Class B to General, C to
Conditional, and the introduction of the Novice and Technician.

That's correct.

So there was some short period of time (until the "Giveaway of 1953"),
where this "free upgrade" gave additional phone privileges on 75 and 20
meters for some of those pre-1917 hams. Specifically, those that held a
General class (formerly "Class B") license. That would be *accurate*.

Yes, it would be! I should have mentioned that earlier.

However, very few actually used that waiver, because

- there were not that many hams before May 1917
- there were fewer who had a Class B/General license
- full privs could be had with an Advanced, which was still available
until the end of 1952.

More information on this, just received today, is given below.

And the more I think about it, the more I think the old Extra waiver was a bad
idea, and that there may be
no scenario that would be worthwhile.

What about a proposal that
grandfathers some percentage of hams in-between?

I say no to free upgrades, then.

So nearly all of the previous discussion above is moot because there is
no "free upgrade" scenario that you will support regardless of the
percentage of hams affected, or their status/seniority.

There may be a free upgrade scenario that I would support, but I have
not seen one yet.

Remember that at some time in the future, we may be looking on this
grandfathering as occurring at some asymptotic point in the past, as
with the pre-1917 waiver above.

You mean like when the Advanced has been unavailable for 35+ years and their
numbers are down to about 1% of the ARS total?

Well, yes, that's what I was driving at. You want to wait until then.

I want to wait until someone presents a convincing argument as to why
such giveaways are needed for the good of the ARS.

I want to deal with the matter sooner. At least I got you to explicitly
bound your answers tighter than "never" or 0%. And what would you do
then?

Depends entirely on the situation at the time.

You ask below what is the long-term
plan. I say one aspect of the plan is to be able to look back on this
grandfathering in the same way that we look upon the pre-1917 waiver.

We don't look back on it the same way.

And why was it done?

The Restructuring FAQ at arrl.org omits the mention of waiver of the
written test, so it too is incomplete. I dropped a line to N1KB, who is
listed as the author of the document, with a request for correction and
clarification. He replied to me with pointers to some sources,
including Ham-Radio-History group noted above, which dates the origin of
the waiver, and "free upgrade," to 1951. W1UED just replied today with
an answer as to why. George E. Sterling, W1AE, was the first (and
likely only) radio amateur to come up through the ranks at the FCC and
be appointed Commissioner. The Amateur Extra license first appeared in
the 1920's and lasted through the 1930's, when it was discontinued as a
budget-cutting measure.

It didn't grant much in the way of more privileges, either, and very
few were actually issued.

During the 1951 restructuring, which restored
the Amateur Extra license, W1AE was an FCC Commissioner:

http://www.fcc.gov/commissioners/commish-list.html

As a pre-WWI licensee himself, he thought it would be an appropriate
honor to that group of hams if they were given the restored Amateur
Extra license, and had the political clout to make it happen. So, the
1951 restructuring gave anyone who was licensed prior to April 1917 and
who presently held a General or Advanced-class license, a "free upgrade"
to Extra.

IOW it was one guy's idea, and nobody was going to tell The
Commissioner that it wasn't a good one. Particularly since it only
affected a few hams anyway.

The following QST article describes the 1951 Restructuring and FCC
Dockets 10073 and 10077:

http://www.arrl.org/members-only/qqn... 1&selpub=QST

(ARRL Members-Only Link)

A photocopy of the full article is available for $3 ($5 for non-members)
postpaid from the ARRL.

Don't need it - I have those QSTs.

That still supports my original assertion that free upgrades given to
existing licensees, based on seniority or status, can be
non-controversial, especially when viewed from the long-term future.

Perhaps. Or perhaps they were "noncontroversial" because nobody wanted
The Commisioner mad at them.


To put it simply: Just leave the closed-off classes alone, and let them
go away by attrition.

This is exactly what was done with the Advanced from the beginning of 1953
until 1967 - more than 14 years. What problems did it cause?

The Advanced-class was eventually opened back up to new licensees, so we
do not know what the longer-term effects would have been.

True - but it was well over a decade before that reopening was even
discussed! And FCC had no problem with keeping those folks on the
records, even with a noncomputerized database.

I see no
realistic likelihood that Advanced will be (or even should be) reopened
in any foreseeable future.

That's what folks said exactly 50 years ago, too.

The outcome that you propose, which is to
carry them on the books for at least 35 more years or until they
constitute less than 1% of all hams, may introduce further problems than
the previous, and much shorter, 14-year period.

But all that avoids the main question of "what's the problem"? If
those Advanceds are satisfied with their license, why not let them
alone? If
they're not satisfied, is the Extra written test so difficult that
they
need a waiver?

In 4 years the number of Advanced has dropped by about 17,000. If it
keeps dropping in a linear (not asymptotic) fashion, the last one will
be gone
in less than 20 years.

I
would argue against that, for the reasons I have given previously
(streamlining of license classes, streamlining of band plans, reduction
of regulatory burden, reduction in confusion for amateurs and the FCC,
harmonization with the deletion of S25.5 and with other countries'
regulations, etc.).

All it takes to keep those classes is a few sentences in Part 97.

"A few sentences" in laws or regulations can have non-trivial
implications about the regulatory infrastructure that is necessary to
give them force.

OK, fine.

The difference between an Advanced and an Extra for enforcement
purposes is just 8 little slices on 4 HF ham bands. Is that a real
enforcement burden?
Four of those slices (the lower 25 kHz of CW/data) are the same as for
General, too, so the effective difference is just the 'phone subbands
on 75/40/20/15.

An Advanced-class license is one more alternative to
program into the licensing computer,

It's already there!

one more piece of regulation to be
understood and enforced by regulators,

Already in place.

and overall, one more class of
amateurs to track and incorporate into any regulatory policies and
agendas. The implementation of all of that is significantly more than a
few sentences.

No, it isn't. Look at Part 97 and see just how much would come out if
all Advanceds were upgraded to Extra. It's not very much.

Also, note that the free upgrades would *create* work for FCC, by
requiring that the databases and licensing stuff be updated to change
all those licenses.

Will FCC issue a new license to every ham that gets a free upgrade, or
will they
keep their old ones until renewal/upgrade time, which may be 12 years
hence (if someone just renewed, and doesn't renew again until near the
end of the grace period).

If license classes are consolidated to a smaller number, one alternative
is simply to grandfather existing hams, which the ARRL has advocated.

A more accurate term is "free upgrade", because that's what it is.

"Grandfather" implies letting a person keep what they already have without
recertification. That's not what is proposed by the ARRL BoD for Techs and
Advanceds.

One other implicit alternative (say, #5), is to make every Novice,
Advanced (and possibly non-Plus, or would that be non-Plussed, Tech)
come back in to take written tests to upgrade to the next level, or
otherwise lose privileges.

That's the worst alternative.

Which is why I specifically identify it and dismiss it early.

I would argue against that also, for the
reasons I have also given previously (it is impractical to retest
everyone,

It could easily be done over time by saying that you either retest before Date
X
or you'll be reclassified at a lower license class.

There is a legitimate distinction between "easy" and "straightforward."

In this case they're the same. The VECs do the testing and most of the
paperwork. That's why FCC required existing Tech Pluses from before
March 21, 1987 to do a testless VE session in ordr to get Generals.

Anyone with engineering experience surely knows that something could be
conceptually simple, but still complex and time-consuming in its actual
implementation.

Been there, done that.

Mass re-testing might be straightforward, but would not
be easy within FCC and VEC budget/manpower constraints.

We're talking about spreading it out over many years. And there's an
upside - some of them will upgrade all the way to Extra while they're
at the VE session.

Besides, if things go the way NCVEC wants, they won't have the
"burden" of code tests anymore anyway, so what's the problem?

Mass re-testing would be a regulatory burden for the FCC,

Not if it were spread out over time, as outlined above.

a personal
burden on VEC's who would have play de-facto judge and jury for large
numbers of existing peers, friends, fellow club members, etc.,
concerning whether or not they could retain former privileges (what
volunteer would want to endure that for very long?),

How would that be any different than now? VECs don't pass judgement on
written tests, they simply proctor and grade them in multiple-choice
format. Where's the "personal burden" other than the crowd being a
little bigger?

Or do you imagine that the VECs would somehow sit in judgement?

and would go
against where the FCC is heading, which is towards less regulation and
fewer grand schemes.

Like BPL?

I might also argue that mass-retesting is sounding
very much like a repeat of the scenario played out in the 1960's with
Incentive Licensing.

And that would kill it stone dead.

There's another angle, too:

Mandatory retesting would reveal how many hams were either totally
inactive or had lost interest to the point that they'd let the license
expire. Would probably cause a massive drop in the number of hams on
the database. Not a good thing from a political point of view.

By the same token, if FCC automatically issues new licenses to all
free-upgraded hams, a number of them will come back labeled "not at
this address" or "deceased" or some such. Which could have a similar
effect to the above. And since it's a requirement to keep FCC aware of
address changes....

There's a lot of debate in this newsgroup about the Incentive Licensing
scheme of the 1960's, who initiated it, what was intended, who supported
it, why it failed, who was to blame, etc., but one thing that most can
agree on is that it's very easy to start out with good intentions, and
what comes out the exit door of regulatory agencies might be
unrecognizable as something that would give the desired result.

Agreed! The original 1963 ARRL IL proposal bore little resemblance to
what finally came out the door.

And in 1999, the R&O bore little resemblance to the NPRM. Example: The
NPRM called for Advanced to stay.

Hence
the expression, "The road to hell is paved with good intentions." Mass
re-testing could also be viewed as well-intentioned, but ultimately a
road to hell.

That argues for leaving everything just as it is now. OK, fine,
we'll just do that.

So, it's a good thing that neither of us are arguing in favor of testing
to avoid losing privileges, right?

Depends on whether privs are actually "lost".

and such existing hams are a large, stable user base such as
that in the definition of grandfathering below).

"Large, stable user base"? We don't really know about that. How many
of those folks are active? Why have so few Advanceds upgraded to
Extra?

You are teetering very close to making a non-falsifiable argument here.

A true statement is, by definition, non-falsifiable, is it not?

You argue here, and in other threads, that Advanced should be left alone
because:

- There are still quite a few of them, who are happy with their present
privileges, who would get a free upgrade unfairly, and crowd the Extra
phone bands.

Not just the phone bands!

*AND*

- There may not be very many of them, active at least, so any upgrade
would not give much benefit, anyway.

Covers all bases, doesn't it?

You also argue that Novice should be left alone because there aren't
very many of them, but then advocate restructuring that you believe
would bring back its "heyday" with many more licensees in that class,
which of course, should then be left alone.

The idea is that the Novice would be *changed*, not simply reopened.

Which is it? Too many, or too few, to justify elimination?

The idea is to cover all bases. Does anybody really know why so few
Advanceds have upgraded?

If neither
is a sufficient criteria to argue for or against elimination of a
license class, then that's a non-falsifiable argument.

The idea is to do what will give the best results for the ARS with the
minimum amount of negative effects.

IOW, we allow them to continue doing what they're doing because they've shown
a lack of problems in the past. But we require more of new systems.
It *doesn't* say we allow free upgrades.

When you say "we require more of new systems" above, are you referring
to people or license classes?

I'm referring to *systems*.

There is a subtle distinction. A group
of people may not want to change, but license classes may need to. A
set of license classes is a ladder, to be climbed as far as the licensee
wishes to develop his skills.

Some reject that idea, and say that there should be just one license
class. How do we answer them?

It is also a taxonomy, with a specific
regulatory purpose. That purpose is to ensure that limited frequency
spectrum is being put to the best and highest use via the distribution
of privileges over that spectrum. Implicit in this is structuring the
license class system to ensure that all amateur radio spectrum (HF, VHF,
UHF, Microwave) is not only used, but used well, in ways that fulfill
the Basis and Purpose (FCC Part 97.1).

But how can any license structure actually do that? Or, to take a
different
approach, why not have just one class (as some have argued here) with
all amateur privileges?

Since technologies, modes, and frequency usage patterns change over
time, the taxonomy should change as well, hence the need for periodic
restructuring over amateur radio's 100-year lifetime (Though I would
argue that not doing the "Giveway of 1953," and staying with the 1951
restructuring until the no-code issue came to a head in the 1980's,
would have avoided the backlash that resulted in Incentive Licensing of
1968).

I agree! So *why* was the "Great Giveaway" of December 1952 done,
particularly since FCC had just spent several years going in the
opposite direction? Why was the restructure of 1951 turned on its head
just as it was going into full effect?

Was it:

- Sudden personnel changes at FCC?
- Desire to push the use of SSB by hams?
- Desire to get hams off of 10-11 meters (the only HF bands open to
General and Conditional 'phone) to alleviate TVI?
- Desire to get more hams using HF mobile (which was only opened to
hams after WW2)?
- Combination of the above?

I have yet to find a definitive answer to why the "Great Giveaway" was
done, either in the written histories or in the recollections of hams
from that time. The answer could be as simple as "The Commissioner
changed his mind".


Out of time right now. Will answer the rest in Part Two

73 de Jim, N2EY

Paul W. Schleck wrote in message ...
In (N2EY) writes:

This is Part Two - previous stuff removed to save space)

You might argue that not every existing ham has obtained the same degree
of experience, or even a minimum necessary level of experience to be
given a free upgrade. That would be true, but ultimately would be
self-limiting, as experience would correlate with participation. An
inactive ham using no privileges today would be using no more privileges
if the FCC gave him a free upgrade tomorrow. Free upgrades are not a
perfect solution, ideal in all cases, but are a good solution overall.

I disagree. What's wrong with simply allowing Techs, Tech Pluses and
Advanceds to upgrade in their own time?

What is the sudden need to eliminate those license classes? The Novice and
Advanced have been closed off to new issues for almost 4 years, and their
numbers have declined. And from 1953 to 1967, no new Advanceds were issued.
Did any of that cause problems?

What's the rush?

Are the written tests too hard?

Well? The current Extra was recently earned by a bright seven year old - can
we really say that it's unreasonable to expect others to do what she did for
the same privileges?

As others have pointed out in other threads, the 7-year old Extra is a
statistical outlier, one of a handful in amateur radio history, and not
a typical example.

It's true that there have only been a few hams younger than about 10
years of age. And in most cases these young hams were in somewhat
exceptional circumstances.

Add a few years, however, and the numbers explode. Tens of thousands,
if not hundreds of thousands of present-day hams started as preteens
or young teenagers, often with no other hams in the family and no real
parental support other than "don't electrocute yourself or burn the
house down". So we still have the nagging question of why it's
unreasonable to expect others to do what they did for the same
privileges?

The more typical, and meaningful, example of an
entry-level ham would be one who was high school or college-age.

Why?

I got my first ham license at the beginning of 7th grade. What is now
middle school. No other hams in my family or neighborhood. There were
many like me,
limited mostly by lack of money and transportation.

The
greater numbers of these typical entry-level hams would mean that they
would have a more profound impact on the shaping of the future of
amateur radio, anyway.

Agreed! But note this: When the ARRL paid READEX to do a survey back
in 1996, the most strongly procodetest age group was the *youngest*
group - 15 and under. 85% were in support of code testing, only 15%
opposed. Time after time, when Morse code is demonstrated to young
prospective hams, they *like* it and are eager to learn it. The idea
that a 5 wpm code test is somehow a barrier to young people is not
borne out by actual experience.

Why do the Advanced class subbands have to be "refarmed" at all? Who or what
would they be "refarmed" to? What's the longterm plan?

If you do agree that the Advanced phone bands should be refarmed at some
point in the future, at what point would you have it done? Would you
leave it to Extras, give it to Generals, or would you otherwise split it
up in some way?

Why does it need to be done at all? Is the Extra written that hard?

Why do you avoid these simple questions?

Because sometimes simple questions are loaded with built-in assumptions

Mine aren't.

(e.g., "Why won't you join me in voting to ban COP-KILLER bullets?" or
even the classic, "Have you stopped beating your wife?").

I am simply asking why it is so urgent to get rid of closed-off
license classes. Where is the "loading" in such a question?

Furthermore, you see simplicity where I see complication, and vice-versa.

I don't see what the problem is with simply keeping the Advanced and
Tech. Allow those who hold them to upgrade in their own time.


So you would argue that any refarming would be done at some asymptotic
point in the far future, indistinguishable at present between "decades"
and "never."

I'm *asking* what the problem is with leaving some things alone.

The question has been asked and answered, though I have given you an
answer you disagree with. Asking the question repeatedly will not
result in a different answer from me. Put away the rhetorical bludgeon.

All I see is the answer that "we need to simplify!" but not *why* that
simplification is so needed right now, when it wasn't needed 4 years
ago.

Alternatively, avoids opening up the
Advanced class phone bands to General-class hams (an effective downgrade
in privileges for Advanced, and crowding out DX users with more
U.S. hams in those bands) or opening up the Extra class phone bands to
Advanced-class hams (which would be a "free upgrade" in all but name).

Again, why not just leave those subbands as they are now?

In this day and age, regulatory agencies seem more eager to simplify
regulations. Removing regulations that are obsolete, or cover too small
an intended audience to be justified on a cost basis, is likely a top
priority for such agencies. Again, what is your timeline for change?
Decades in the future, or never?

I don't see any reason to "refarm" them at all. Not at this time, anyway.

Note that in 4 years, the number of Advanceds has dropped by only about 16%.

Seems to be a pretty popular license even today.

Note also that several Advanceds have said they *don't* want an upgrade, free
or not.
I don't understand why, but that's what they've said.

It sounds to me like you want all Advanceds to become Extras so that the
Advanced subbands can become General bandspace. That's not part of the ARRL
proposal, though.

No, I never said that.

No, you didn't. That's why I wrote "sounds to me".

My first draft of my reply said, "No I never said nor implied that." I
edited it to achieve economy of words, because even if I somehow implied
that I supported the entire ARRL proposal, adoption of that proposal
would not giving the entire Advanced phone subbands to the Generals.

The word "refarmed" was used, which is a euphemism for "reallocated".

If all Advanceds get Extras, but Generals get no more bandspace, then
what is actually "refarmed"?

I would combine Advanced and Extra phone bands
into just Extra phone bands, and leave the General bands as they are.

That's the status quo! It's not "refarming" at all.

It still removes one color bar from the frequency allocation charts (for
Advanced), so is not strictly a "status quo" solution like you have
advocated.

The point is that by using the word "refarming", you implied that
Generals would get more bandspace.

I suppose a definition of refarming is necessary for this context. Even
the ITU seems to struggle with the meaning of this word (search for
"definition of refarming" on Google). A commonly-accepted definition
is:

"Moving one service out to make way for another that would use the
spectrum more optimally."

So, really, neither of us are using the word entirely according to this
definition. Even if we substitute "class" for "service" above, no
General, Advanced, or Extra is being moved out to make way for anyone
else under the two alternatives offered in this discussion (mine, and
the ARRL's). Even Novice and Tech Plus hams only face a "lose some, but
gain a lot more" prospect under the ARRL proposal. You would define
refarming as making different license classes within the same service
either gain or lose spectrum. I would agree that this would constitute
one kind of refarming. I would also assert that the elimination of
license classes within a service to simplify spectrum allocation is
another kind of refarming.

I say it would be clearer to avoid such euphemistic words and be more
direct. "Reallocate" or, better yet, "widen the phone bands". Because
that's what it comes down to.

That doesn't mean that I wouldn't support frequency shifting, such as
that proposed to make 40 meters a primary amateur allocation, or part of
Novice band refarming. Just that I would keep the proportional amounts
roughly the same. I realize that the current ARRL proposal splits up
the Advanced phone bands, giving proportionally more to the General than
the Extra phone bands on 80 and 40 meters, and proportionally less on 15
meters (no changes on 20 meters). I do not strongly support that, but
even that proposal isn't giving the entire Advanced phone bandwidth to
the Generals.

And if nothing at all is done, the results are almost the same as what you
propose.

Emphasis on "almost." One of my motivations in this extended discussion
is to determine our agreements and disagreements, what are hard-and-fast
beliefs, and what might be open to compromise.

Good idea.

In case you haven't
figured it out, I'm gathering verbage for a draft of my comments on any
future NPRM. You seem to be alternating between active opposition to,
and fatalistic acceptance of, the possibility that Element 1 will be
deleted.

That's one way to look at it.

The fact is that there are more issues to be addressed than just the 5
wpm code test. It's important to not lose sight of the fact that
whether the code test stays or goes, those other issues should not be
forgotten.

Perhaps you want to "go down fighting" on this issue with the
ARRL and the FCC.

Why not? If those of us who support code testing don't ask, we'll
never get.

Is the current 5 wpm test, with all its accomodations, *really* too
much to
ask of new hams? The ARRL proposal writeups wax nostalgic about the
old Novice license, but carefully avoid mentioning that
part-and-parcel of the old Novice was the 5 wpm code test.


Your ideal-world position of no changes allows me to
rebut with the continued complications that it implies.

My ideal-world position isn't one of no changes. I've outlined it here
before, and can dig it up again if you want to see it.


On the other
hand, I too believe that Element 1 being dropped is likely, but I also
believe that changes to license classes and band allocations are still
very much up in the air at this point. Because of this, I will happily
play "what-if" with the various scenarios (as the FCC might do them in
any combination) while also indicating which ones that I favor.

So that there is no further confusion about what I favor, I support
dropping Element 1 (which would merge Technician with Technician-Plus),

For all license classes or just Tech Plus?

giving present Advanced-class licensees a "free upgrade" to Extra, and
keeping General and Extra-class phone bands substantially and
proportionately the same (save for some small shifting/resizing for
Novice-band refarming and making all of 40 meters a primary amateur
radio allocation).

So the Tech would remain the entry level license?

Also avoids having to accommodate a license class (Tech Plus) that isn't
even carried in the FCC database anymore, which is a records/
enforcement problem for the FCC, and requires the licensee to keep
documentation forever.

If the current rules are left alone, all Tech Pluses will be Techs in six
years, two months and 20 days or so.

If by saying, "If the current rules are left alone..." you really meant
leaving alone everything *except* the 5 WPM Morse code requirement
(which would be eliminated for these General and below under the ARRL
proposal), then, and only then, Technician-class hams will assume the
HF privileges of Technician-Plus.

Whatever. I don't see why the 5 wpm code test is such a big deal as a
requirement.

Does your "Whatever" answer above mean that you support 5 WPM Morse code
for all HF license classes, or just for Extra?

I support a code test for all amateur licenses, period. I think the dropping of
the
code test for the Tech back in 1991 was a mistake. I argued and commented
against it then, and much of what I said would happen has come to pass.

The FCC's Electronic Comment Filing System (EFCS) only goes back to 1992
and your callsign doesn't appear in Google Groups until 1997. Would you
mind elaborating on what you thought would happen, and what you think
has come to pass?

OK, here's the short list:

First off, dropping the code test from the Tech in 1991 re-created a
ham license that was VHF-UHF centric. New hams were funneled to start
off on VHF/UHF FM phone with new manufactured equipment, rather than
HF CW, where homebrew, kit and used equipment were more prevalent.
This created a divide between those hams who had some or all HF and
those who had none, centered around the code test. Such divisions are
not a good thing. The resulting division has diverted attention from
other, more important issues such as publicity, antenna restrictions,
and limits to growth.

Second, the change brought about a surge in new hams (good) but not
sustained growth (bad).

Third, one of the things promised back in 1991 was that there would be
more and more "technical people" becoming hams if the code test were
dropped for VHF/UHF. Did not happen.

Most of all, the continual tinkering with the license system has
perpetuated and expanded the myth that the license tests are "too
hard", and that all will be well if we just make this change or that
change. Yet history tells a very different story. Look at the growth
in US ham radio from 1991 to the present, and compare it to an
identical length of time before 1991. Was there a big, sustained
increase in the number of new hams because of the Tech losing its code
test?

Look at the growth since April 2000. Mostly existing hams getting
upgrades, but not a huge jump in the number of new hams.

And the issue isn't just code tests. The *written* tests have been
reduced in number, size and complexity, too. Is that really a good
thing?

If the former, then
there is a very real distinction that will continue to exist in the
license ladder whether or not it continues to be recorded in the
database. If so, then the expiring of Tech-Plus license in 6 years is
not a simplification, it is a complication.

That's still a long time in FCC
enforcement (and VEC administration) years.

Why? It's been almost 4 years since the last restructuring took effect. Look
at the enforcement letters - Techs without code masquerading as Tech Pluses
isn't a big problem, from what I see.

You argue that it's not an enforcement problem because few or none have
been caught. I would argue that it is an enforcement problem because it
would be very hard to catch someone, especially if confirming who has
what privileges requires documentation that is no longer in the FCC
database, and might no longer be retained by hams or VEC's. The FCC's
limited staff time is probably being aimed at big fish, such as Advanced
and Extra-class scofflaws engaging in power and interference violations.

You might want to read the letters. They're pretty evenly distributed, license
clas wise, except for Novices.

I have read them. Even if they are evenly distributed in numbers, they
are not evenly distributed according to number of licensees in each
class. If they were, then there would be approximately one Extra-class
violator for every three Tech/Tech-Plus violators, or every 1.5
General-class violators. I stand by my original argument.
Specifically, that the FCC's enforcement agenda is mostly aimed at
high-yield (easier to catch/more serious punishment, aka "big fish")
violations "such as" (i.e., not limited to) power and interference
violations at higher classes of license. Such licensees are being
subject to proportionately more enforcement scrutiny than other classes
of license.

What about the new ham who was found transmitting false distress calls
on a marine VHF frequency using a modified ham rig? As I recall,
intentional false distress is one of the most serious infractions
possible.

There is also the factor of enforcement being complaint-driven.
Someone who acts up on a 2 meter repeater can be heard over a radius
of perhaps a few dozen miles, and the repeater control ops can shut
down the machine. But on HF, a single bad apple can be heard for
hundreds or thousands of miles, and there's no way to "shut down the
machine".

Please note, too, that the enforcement actions for on-air behavior are
almost entirely directed against those using voice modes. Enforcement
actions against hams using Morse code in the CW/data parts of the
bands are almost nonexistent. The disparity is far more than can be
explained by the relative popularity of the modes.

Out of time again. More to come in Part Three

73 de Jim, N2EY