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-   -   FCC Morse, restructuring proposals could hit the street by mid-year (https://www.radiobanter.com/policy/65733-fcc-morse-restructuring-proposals-could-hit-street-mid-year.html)

Alun L. Palmer March 2nd 05 04:06 AM

wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:

Alun L. Palmer wrote:
"Vince Fiscus, KB7ADL" wrote in
nk.net:


wrote in news:1109689325.032940.133970
@o13g2000cwo.googlegroups.com:

http://www.arrl.org

scroll down about 3 stories

Article sez FCC is working on NPRM that will address all 18
existing proposals. Expected to become public about the middle of
2005. With the usual comment period, etc., Report and Order by
maybe late 2006/early 2007.

73 de Jim, N2EY


If the ARRL has a proposal, could you post it here for review. I
refuse to visit their site anymore. TNX 73

KB7ADL


I don't have the full details of the ARRL petition to hand, but
basically it brings back the Novice licence (without the code), makes
Techs into Generals and Advanceds into Extras, and dumps ths code test
except for Extras, who would still have to pass it.


Basically a compromise that gives everybody something they want but
doesn't give anybody everything.

Two comments on the Antique Radio Relay League's news item.


Your bias is showing, Alun.


Sure. I don't think the League is a very progressive organisation.

Firstly, it's
very telling that they buried it down the page, just as they did with
the announcement that the code test was abolished by the ITU.


They post the stories in chronological order. If it's not at the top,
that's because a newer story has displaced it. They did not "bury"
anything.


I see. Well, I guess the're not journalists.

And the code test was not abolished by ITU. All that changed was that
the treaty no longer requires such a test. Signatory countries are now
no longer *required by treaty* to have a code test, that's all.


Same thing.


Secondly, it does say at the end that "it's possible the Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.


Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.

IMHO, the FCC will not adopt the League's proposal as such.


Probably not. Nor will they adopt anyone's proposal as presented, IMHO.

The FCC say
that they are looking for a consensus amongst us, and they are also on
record as saying that the code test useful doesn't serve any useful
purpose.


When did they say those things?


They said that they wouldn't restructure until a consensus emerged


btw, the FCC's words were "serves no *REGULATORY* purpose" (emphasis
added) not "useful purpose". BIG difference!


Thanks for correcting the wording, but it really isn't much of a difference

And if FCC still thinks the code test serves no regulatory purpose, why
didn't they just dump Element 1 in late summer 2003, as proposed by at
least two groups?


I don't know, but you admit they said it serves no regulatory purpose

All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they could
have simply ordered that anyone who passed Element 2, 3 or 4 gets
Element 1 credit.

But they didn't.


Maybe they didn't feel that they could do that when they had 19 petitions
dumped on them?


There
is no consensus, so I think they will choose from whatever has been
proposed those things that suit their own organisational objectives,
i.e. reducing administrative burden. IOW, fewer tests and fewer
licence classes suits the FCC.


Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out classes.
Others have proposed similar freebies. FCC has consistently said no,
and keeps the Tech Plus, Advanced and Novice alive in their rules and
database. At the current rate of decline, it may be 15 more years
before the last Advanced is gone.


A mistake IMO. I don't think closed classes are a good idea. It's better to
make a clean break and get everybody in the same system.


I predict the code test will not be a continuing feature in the NPRM,


whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.


Yet they have not done so. If they really think Element 1 should go,
why wasn't it dumped in 2003?


See above. They will have to consider all the petitions and then write an
NPRM that either does or doesn't restructure the licence classes.

Reducing the number of classes also appeals to the FCC, so maybe they
might even adopt most of the League's proposal but get rid of element
1 as well? I don't think so, though, as the line of least resistance
is to keep the current test elements as they are. This means
grandfathering Novice to Tech instead of Tech to General, so that is
what I predict they will do.


Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as the
last Tech Plus is renewed as Tech. The other two closed-out classes are
slowly dropping, yet may last a lot longer because of renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY


It's just an unnecessary complication. Three classes are easier to enforce
than six.

73 de Alun, N3KIP

[email protected] March 2nd 05 10:43 AM


Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:

Alun L. Palmer wrote:
"Vince Fiscus, KB7ADL" wrote in
nk.net:


wrote in news:1109689325.032940.133970
@o13g2000cwo.googlegroups.com:

http://www.arrl.org

scroll down about 3 stories

Article sez FCC is working on NPRM that will address all 18
existing proposals. Expected to become public about the middle

of
2005. With the usual comment period, etc., Report and Order by
maybe late 2006/early 2007.

73 de Jim, N2EY


If the ARRL has a proposal, could you post it here for review. I
refuse to visit their site anymore. TNX 73

KB7ADL


I don't have the full details of the ARRL petition to hand, but
basically it brings back the Novice licence (without the code),

makes
Techs into Generals and Advanceds into Extras, and dumps ths code

test
except for Extras, who would still have to pass it.


Basically a compromise that gives everybody something they want but
doesn't give anybody everything.

Two comments on the Antique Radio Relay League's news item.


Your bias is showing, Alun.


Sure. I don't think the League is a very progressive organisation.


At least you admit your bias. Can't argue with that!

Firstly, it's
very telling that they buried it down the page, just as they did

with
the announcement that the code test was abolished by the ITU.


They post the stories in chronological order. If it's not at the

top,
that's because a newer story has displaced it. They did not "bury"
anything.


I see. Well, I guess the're not journalists.


The webpage isn't a newspaper. By listing the stories in chrono order,
you always have the newest stuff on top.

And the code test was not abolished by ITU. All that changed was

that
the treaty no longer requires such a test. Signatory countries are

now
no longer *required by treaty* to have a code test, that's all.


Same thing.


No, completely different things. The change does not require member
countries to drop the code test.



Secondly, it does say at the end that "it's possible the

Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.


Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.

IMHO, the FCC will not adopt the League's proposal as such.


Probably not. Nor will they adopt anyone's proposal as presented,

IMHO.

The FCC say
that they are looking for a consensus amongst us, and they are

also on
record as saying that the code test useful doesn't serve any

useful
purpose.


When did they say those things?


They said that they wouldn't restructure until a consensus emerged


*When* did FCC say that? They restructured in 2000 without a consensus.


btw, the FCC's words were "serves no *REGULATORY* purpose"

(emphasis
added) not "useful purpose". BIG difference!


Thanks for correcting the wording, but it really isn't much of a

difference

Yes, it is. Since FCC's role is regulatory, their interest is in what
should be regulated, not what's good and bad.

And if FCC still thinks the code test serves no regulatory purpose,

why
didn't they just dump Element 1 in late summer 2003, as proposed by

at
least two groups?


I don't know, but you admit they said it serves no regulatory purpose


When did FCC say it?

All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they

could
have simply ordered that anyone who passed Element 2, 3 or 4 gets
Element 1 credit.

But they didn't.


Maybe they didn't feel that they could do that when they had 19

petitions
dumped on them?


Maybe. Or maybe their mind has changed on the subject.


There
is no consensus, so I think they will choose from whatever has

been
proposed those things that suit their own organisational

objectives,
i.e. reducing administrative burden. IOW, fewer tests and fewer
licence classes suits the FCC.


Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out

classes.
Others have proposed similar freebies. FCC has consistently said

no,
and keeps the Tech Plus, Advanced and Novice alive in their rules

and
database. At the current rate of decline, it may be 15 more years
before the last Advanced is gone.


A mistake IMO. I don't think closed classes are a good idea.


Why not?

It's better to
make a clean break and get everybody in the same system.


All US hams are in the same system. IMHO, and FCC's to date, free
upgrades are *not* a good idea.


I predict the code test will not be a continuing feature in the

NPRM,

whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.



Yet they have not done so. If they really think Element 1 should

go,
why wasn't it dumped in 2003?


See above. They will have to consider all the petitions and then

write an
NPRM that either does or doesn't restructure the licence classes.


They don't have to do that to dump Element 1. They can say the issue
was dealt with in the past and there's no new info and since there's no
regulatory purpose served, bye bye Element 1. But they haven't.


Reducing the number of classes also appeals to the FCC, so maybe

they
might even adopt most of the League's proposal but get rid of

element
1 as well? I don't think so, though, as the line of least

resistance
is to keep the current test elements as they are. This means
grandfathering Novice to Tech instead of Tech to General, so that

is
what I predict they will do.


Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as

the
last Tech Plus is renewed as Tech. The other two closed-out classes

are
slowly dropping, yet may last a lot longer because of renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY


It's just an unnecessary complication. Three classes are easier to

enforce
than six.


Yet FCC *turned down* such proposals in the past. They prefer more
classes to free automatic upgrades. Enforcement is a nonissue; the FCC
folks know where the subbands are. And it's the rare ham who strays,
judging by enforcement actions.

73 de Jim, N2EY


Michael Coslo March 2nd 05 03:31 PM

Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:


snip

Your bias is showing, Alun.



Sure. I don't think the League is a very progressive organisation.



What would make the league progressive Alun?


Firstly, it's
very telling that they buried it down the page, just as they did with
the announcement that the code test was abolished by the ITU.


They post the stories in chronological order. If it's not at the top,
that's because a newer story has displaced it. They did not "bury"
anything.



I see. Well, I guess the're not journalists.


I don't understand. Chronological order seems a good way to post articles.



And the code test was not abolished by ITU. All that changed was that
the treaty no longer requires such a test. Signatory countries are now
no longer *required by treaty* to have a code test, that's all.



Same thing.


Here is a question:

If a country were to require higher standards for their version of the
ARS, are they hazing their applicants? If country A requ



Secondly, it does say at the end that "it's possible the Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.


Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.

IMHO, the FCC will not adopt the League's proposal as such.


Probably not. Nor will they adopt anyone's proposal as presented, IMHO.


The FCC say
that they are looking for a consensus amongst us, and they are also on
record as saying that the code test useful doesn't serve any useful
purpose.


When did they say those things?



They said that they wouldn't restructure until a consensus emerged


Hehe, that could be a long long time.


btw, the FCC's words were "serves no *REGULATORY* purpose" (emphasis
added) not "useful purpose". BIG difference!



Thanks for correcting the wording, but it really isn't much of a difference



I respectfully disagree. That is a huge difference. If we were tested
for our knowledge of Electron tube circuitry, it would not be serving a
useful purpose.


And if FCC still thinks the code test serves no regulatory purpose, why
didn't they just dump Element 1 in late summer 2003, as proposed by at
least two groups?



I don't know, but you admit they said it serves no regulatory purpose


Despite the hand wringing, Element 1 is just another part of the test.
A good case can be made that its inclusion or exclusion makes no
particular difference pro or con to the ARS. So they probably didn't
feel the need to mess with it.


All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they could
have simply ordered that anyone who passed Element 2, 3 or 4 gets
Element 1 credit.

But they didn't.



Maybe they didn't feel that they could do that when they had 19 petitions
dumped on them?


I doubt that. Maybe the No coders can try to throttle the petition
process so that messy things like the law, due process and free speech
can be eliminated for expediency?

(major tongue in cheek mode here, I know you would never seriously
suggest that people should be able to speak their mind)


There
is no consensus, so I think they will choose from whatever has been
proposed those things that suit their own organisational objectives,
i.e. reducing administrative burden. IOW, fewer tests and fewer
licence classes suits the FCC.


Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out classes.
Others have proposed similar freebies. FCC has consistently said no,
and keeps the Tech Plus, Advanced and Novice alive in their rules and
database. At the current rate of decline, it may be 15 more years
before the last Advanced is gone.



A mistake IMO. I don't think closed classes are a good idea. It's better to
make a clean break and get everybody in the same system.


I predict the code test will not be a continuing feature in the NPRM,


whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.


Yet they have not done so. If they really think Element 1 should go,
why wasn't it dumped in 2003?



See above. They will have to consider all the petitions and then write an
NPRM that either does or doesn't restructure the licence classes.



Reducing the number of classes also appeals to the FCC, so maybe they
might even adopt most of the League's proposal but get rid of element
1 as well? I don't think so, though, as the line of least resistance
is to keep the current test elements as they are. This means
grandfathering Novice to Tech instead of Tech to General, so that is
what I predict they will do.


Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as the
last Tech Plus is renewed as Tech. The other two closed-out classes are
slowly dropping, yet may last a lot longer because of renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY



It's just an unnecessary complication. Three classes are easier to enforce
than six.


Exactly what would be so difficult about it?


- Mike KB3EIA -


Alun L. Palmer March 2nd 05 06:10 PM

wrote in news:1109760226.362991.253290
@o13g2000cwo.googlegroups.com:


Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:

Alun L. Palmer wrote:
"Vince Fiscus, KB7ADL" wrote in
nk.net:

wrote in news:1109689325.032940.133970
@o13g2000cwo.googlegroups.com:

http://www.arrl.org

scroll down about 3 stories

Article sez FCC is working on NPRM that will address all 18
existing proposals. Expected to become public about the middle
of 2005. With the usual comment period, etc., Report and Order
by maybe late 2006/early 2007.

73 de Jim, N2EY


If the ARRL has a proposal, could you post it here for review. I
refuse to visit their site anymore. TNX 73

KB7ADL


I don't have the full details of the ARRL petition to hand, but
basically it brings back the Novice licence (without the code),
makes Techs into Generals and Advanceds into Extras, and dumps ths
code test except for Extras, who would still have to pass it.

Basically a compromise that gives everybody something they want but
doesn't give anybody everything.

Two comments on the Antique Radio Relay League's news item.

Your bias is showing, Alun.


Sure. I don't think the League is a very progressive organisation.


At least you admit your bias. Can't argue with that!

Firstly, it's
very telling that they buried it down the page, just as they did
with the announcement that the code test was abolished by the ITU.

They post the stories in chronological order. If it's not at the
top, that's because a newer story has displaced it. They did not
"bury" anything.


I see. Well, I guess the're not journalists.


The webpage isn't a newspaper. By listing the stories in chrono order,
you always have the newest stuff on top.

And the code test was not abolished by ITU. All that changed was
that the treaty no longer requires such a test. Signatory countries
are now no longer *required by treaty* to have a code test, that's
all.


Same thing.


No, completely different things. The change does not require member
countries to drop the code test.


Making a requirement optional is indistinguishable from abolishing it. It's
just a different form of words used to keep some countries happy.



Secondly, it does say at the end that "it's possible the Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.

Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.

IMHO, the FCC will not adopt the League's proposal as such.

Probably not. Nor will they adopt anyone's proposal as presented,
IMHO.

The FCC say
that they are looking for a consensus amongst us, and they are also
on record as saying that the code test useful doesn't serve any
useful purpose.

When did they say those things?


They said that they wouldn't restructure until a consensus emerged


*When* did FCC say that? They restructured in 2000 without a consensus.


Maybe a google search would find the answer to that



btw, the FCC's words were "serves no *REGULATORY* purpose" (emphasis
added) not "useful purpose". BIG difference!


Thanks for correcting the wording, but it really isn't much of a
difference


Yes, it is. Since FCC's role is regulatory, their interest is in what
should be regulated, not what's good and bad.


i.e. no regulatory purpose means no purpose useful to them as regulators -
no contradiction there


And if FCC still thinks the code test serves no regulatory purpose,
why didn't they just dump Element 1 in late summer 2003, as proposed
by at least two groups?


I don't know, but you admit they said it serves no regulatory purpose


When did FCC say it?


I can't recall, but you know they did. You've admitted it.


All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they
could have simply ordered that anyone who passed Element 2, 3 or 4
gets Element 1 credit.

But they didn't.


Maybe they didn't feel that they could do that when they had 19
petitions dumped on them?


Maybe. Or maybe their mind has changed on the subject.


I think they have beleived that since the '70s, but have hung onto the code
test under pressure from some hams, including the League. The question is
not whether their minds have changed (I beleive they haven't) but whether
they beleive they can get rid of the pesky code test without upsetting too
many hams. At this point in time I think they can, but it depends on one's
definition of 'too many'.

Of course, prior to 2003 they couldn't do it, but they had long since
abolished the sending test anyway, even though that was required by the
ITU. Talk to Phil Kane and see what he thinks of that from a purely legal
perspective. You can't construe a statute in such a way as to ignore it's
plain language by arguing that meeting one of the requirements indicates
that you _could_meet_ (NB: not _have_met_) the other requirement. I am
talking about _sending_ and receiving Morse code by _hand_ and by ear. Of
course, it was a treaty, not a statute, but that should make no difference.



There
is no consensus, so I think they will choose from whatever has been
proposed those things that suit their own organisational
objectives, i.e. reducing administrative burden. IOW, fewer tests
and fewer licence classes suits the FCC.

Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out
classes. Others have proposed similar freebies. FCC has consistently
said no, and keeps the Tech Plus, Advanced and Novice alive in their
rules and database. At the current rate of decline, it may be 15
more years before the last Advanced is gone.


A mistake IMO. I don't think closed classes are a good idea.


Why not?

It's better to
make a clean break and get everybody in the same system.


All US hams are in the same system. IMHO, and FCC's to date, free
upgrades are *not* a good idea.


Look at it from the other way around. It's not right to have a closed
Advanced licence with some of the theory and some of the privileges of an
Extra and not admit new people to it. That's not fair to the new Generals.
IF OTOH, you counter that by saying that there's little difference in the
theory level, then why not grandfather the Advanceds to Extra?

If everything were done your way you could only create licence classes and
never abolish them. Eventually you would have Heinz 57 varieties of
licence, but only two or three that you could actually apply for, a system
that only a civil servant could love. The only way to avoid that would be
to change nothing, ever, which may be your hidden agenda.



I predict the code test will not be a continuing feature in the
NPRM,

whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.



Yet they have not done so. If they really think Element 1 should go,
why wasn't it dumped in 2003?


See above. They will have to consider all the petitions and then write
an NPRM that either does or doesn't restructure the licence classes.


They don't have to do that to dump Element 1. They can say the issue
was dealt with in the past and there's no new info and since there's no
regulatory purpose served, bye bye Element 1. But they haven't.


Reducing the number of classes also appeals to the FCC, so maybe
they might even adopt most of the League's proposal but get rid of
element 1 as well? I don't think so, though, as the line of least
resistance is to keep the current test elements as they are. This
means grandfathering Novice to Tech instead of Tech to General, so
that is what I predict they will do.

Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as
the last Tech Plus is renewed as Tech. The other two closed-out
classes are slowly dropping, yet may last a lot longer because of
renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY


It's just an unnecessary complication. Three classes are easier to
enforce than six.


Yet FCC *turned down* such proposals in the past. They prefer more
classes to free automatic upgrades. Enforcement is a nonissue; the FCC
folks know where the subbands are. And it's the rare ham who strays,
judging by enforcement actions.

73 de Jim, N2EY


I think they turned them down for lack of consensus on our part. If we
agree, then they'll do it.

73 de Alun, N3KIP

Vince Fiscus, KB7ADL March 2nd 05 06:28 PM

"Dan/W4NTI" wrote in news:3j4Vd.11600
:


"Vince Fiscus, KB7ADL" wrote in message
nk.net...
wrote in news:1109689325.032940.133970
@o13g2000cwo.googlegroups.com:

http://www.arrl.org

scroll down about 3 stories

Article sez FCC is working on NPRM that will address all 18 existing
proposals. Expected to become public about the middle of 2005. With the
usual comment period, etc., Report and Order by maybe late 2006/early
2007.

73 de Jim, N2EY



If the ARRL has a proposal, could you post it here for review. I refuse

to
visit their site anymore. TNX 73

KB7ADL


Then why do you give a rip about what the proposal says?

Dan/W4NTI



Me give a rip? More like Amateur radio R.I.P(rest in peace)

You've heard of out-come based education, well the ARRL wants out-come
based licensing. They don't care about about quality anymore, only
quantity. I just want to see they are still continuing their campaign to
destroy the integrity of the service.

KB7ADL

Alun L. Palmer March 2nd 05 06:32 PM

Michael Coslo wrote in
:

Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:


snip

Your bias is showing, Alun.



Sure. I don't think the League is a very progressive organisation.



What would make the league progressive Alun?


Good question. Damned if I know!


Firstly, it's
very telling that they buried it down the page, just as they did with
the announcement that the code test was abolished by the ITU.

They post the stories in chronological order. If it's not at the top,
that's because a newer story has displaced it. They did not "bury"
anything.



I see. Well, I guess the're not journalists.


I don't understand. Chronological order seems a good way to post
articles.


Newspapers put the big headlines at the top of page one in large print.
however, if that's too much work for them I can accept that (especially as
I'm not even a member!). Chronological order does take out any value
judgements at least.



And the code test was not abolished by ITU. All that changed was that
the treaty no longer requires such a test. Signatory countries are now
no longer *required by treaty* to have a code test, that's all.



Same thing.


Here is a question:

If a country were to require higher standards for their version of
the
ARS, are they hazing their applicants? If country A requ


Maybe, maybe not. It depends what those requirements are. For example,
maybe a lack of an entry level licence is not hazing, but too hard a
regular licence might be.



Secondly, it does say at the end that "it's possible the Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.

Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.

IMHO, the FCC will not adopt the League's proposal as such.

Probably not. Nor will they adopt anyone's proposal as presented,
IMHO.


The FCC say
that they are looking for a consensus amongst us, and they are also
on record as saying that the code test useful doesn't serve any
useful purpose.

When did they say those things?



They said that they wouldn't restructure until a consensus emerged


Hehe, that could be a long long time.


Indeed


btw, the FCC's words were "serves no *REGULATORY* purpose" (emphasis
added) not "useful purpose". BIG difference!



Thanks for correcting the wording, but it really isn't much of a
difference



I respectfully disagree. That is a huge difference. If we were
tested
for our knowledge of Electron tube circuitry, it would not be serving a
useful purpose.


Testing electron tube knowledge or sending and receiving Morse by hand and
by ear serves no useful/regulatory purpose, but electron tube knowledge and
CW are useful.


And if FCC still thinks the code test serves no regulatory purpose,
why didn't they just dump Element 1 in late summer 2003, as proposed
by at least two groups?



I don't know, but you admit they said it serves no regulatory purpose


Despite the hand wringing, Element 1 is just another part of the
test.
A good case can be made that its inclusion or exclusion makes no
particular difference pro or con to the ARS.


In a sense it makes no particular difference to me or you, but we are not
the whole ARS. No-coders are hams too, and there are other people who are
not yet hams to consider as well.

So they probably didn't
feel the need to mess with it.


All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they
could have simply ordered that anyone who passed Element 2, 3 or 4
gets Element 1 credit.

But they didn't.



Maybe they didn't feel that they could do that when they had 19
petitions dumped on them?


I doubt that. Maybe the No coders can try to throttle the petition
process so that messy things like the law, due process and free speech
can be eliminated for expediency?


NCI did try to get the FCC to issue a Memorandum Report and Order, but as
you say, the FCC probably thought that would deny due process to all the
people who filed petitions, which is probably fair comment.

(major tongue in cheek mode here, I know you would never seriously
suggest that people should be able to speak their mind)


I'm all for free speech. Why do you think otherwise?


There
is no consensus, so I think they will choose from whatever has been
proposed those things that suit their own organisational objectives,
i.e. reducing administrative burden. IOW, fewer tests and fewer
licence classes suits the FCC.

Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out classes.
Others have proposed similar freebies. FCC has consistently said no,
and keeps the Tech Plus, Advanced and Novice alive in their rules and
database. At the current rate of decline, it may be 15 more years
before the last Advanced is gone.



A mistake IMO. I don't think closed classes are a good idea. It's
better to make a clean break and get everybody in the same system.


I predict the code test will not be a continuing feature in the NPRM,

whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.

Yet they have not done so. If they really think Element 1 should go,
why wasn't it dumped in 2003?



See above. They will have to consider all the petitions and then write
an NPRM that either does or doesn't restructure the licence classes.



Reducing the number of classes also appeals to the FCC, so maybe they
might even adopt most of the League's proposal but get rid of element
1 as well? I don't think so, though, as the line of least resistance
is to keep the current test elements as they are. This means
grandfathering Novice to Tech instead of Tech to General, so that is
what I predict they will do.

Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as
the last Tech Plus is renewed as Tech. The other two closed-out
classes are slowly dropping, yet may last a lot longer because of
renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY



It's just an unnecessary complication. Three classes are easier to
enforce than six.


Exactly what would be so difficult about it?


- Mike KB3EIA -



It's not particurly difficult, but I can see no need to continue the closed
classes. All those who would get a 'free upgrade' have held their licences
for some time, so I foresee no impact whatsoever from eliminating those
licences and upgrading them.

Alun N3KIP

Michael Coslo March 2nd 05 08:03 PM

Alun L. Palmer wrote:

Michael Coslo wrote in
:


Alun L. Palmer wrote:

wrote in news:1109706299.033324.211320
:


snip


Your bias is showing, Alun.



Sure. I don't think the League is a very progressive organisation.



What would make the league progressive Alun?



Good question. Damned if I know!


Firstly, it's
very telling that they buried it down the page, just as they did with
the announcement that the code test was abolished by the ITU.

They post the stories in chronological order. If it's not at the top,
that's because a newer story has displaced it. They did not "bury"
anything.



I see. Well, I guess the're not journalists.


I don't understand. Chronological order seems a good way to post
articles.



Newspapers put the big headlines at the top of page one in large print.
however, if that's too much work for them I can accept that (especially as
I'm not even a member!). Chronological order does take out any value
judgements at least.


There are plenty enough people - like myself - that don't see the Morse
code issue as the big headline. Despite my support for the continuance
of the test, I think there are more important issues in the ARS. Morse
code testing is probably about 4th or 5th. Not in the noise, but far
enough down.




And the code test was not abolished by ITU. All that changed was that
the treaty no longer requires such a test. Signatory countries are now
no longer *required by treaty* to have a code test, that's all.


Same thing.


Here is a question:

If a country were to require higher standards for their version of
the
ARS, are they hazing their applicants? If country A requ



Maybe, maybe not. It depends what those requirements are. For example,
maybe a lack of an entry level licence is not hazing, but too hard a
regular licence might be.



Secondly, it does say at the end that "it's possible the Commission
could wrap up the proceeding before that time frame", so IOW the
2006/7 is just the League's guesswork.

Of course - and they make that clear in the article.

Back in summer 2003, ARRL said at least two years. Which seemed
incredibly long at the time, but is now turning out to be short, if
anything.


IMHO, the FCC will not adopt the League's proposal as such.

Probably not. Nor will they adopt anyone's proposal as presented,
IMHO.



The FCC say
that they are looking for a consensus amongst us, and they are also
on record as saying that the code test useful doesn't serve any
useful purpose.

When did they say those things?


They said that they wouldn't restructure until a consensus emerged


Hehe, that could be a long long time.


Indeed


btw, the FCC's words were "serves no *REGULATORY* purpose" (emphasis
added) not "useful purpose". BIG difference!



Thanks for correcting the wording, but it really isn't much of a
difference



I respectfully disagree. That is a huge difference. If we were
tested
for our knowledge of Electron tube circuitry, it would not be serving a
useful purpose.



Testing electron tube knowledge or sending and receiving Morse by hand and
by ear serves no useful/regulatory purpose, but electron tube knowledge and
CW are useful.


And if FCC still thinks the code test serves no regulatory purpose,
why didn't they just dump Element 1 in late summer 2003, as proposed
by at least two groups?


I don't know, but you admit they said it serves no regulatory purpose


Despite the hand wringing, Element 1 is just another part of the
test.
A good case can be made that its inclusion or exclusion makes no
particular difference pro or con to the ARS.



In a sense it makes no particular difference to me or you, but we are not
the whole ARS. No-coders are hams too, and there are other people who are
not yet hams to consider as well.


I was a no-coder once. In fact, until around mid 2000, I was perfectly
happy to remain such. Then after my first exposure to Field Day, I was
hooked. I said "I want to do this" and asked what I needed to do. So I
did it. It wasn't as easy for me as for some. The writtens were easy for
me, but the Morse code wasn't.

The point is Big deal, I wanted it, I went out and got it.

So they probably didn't
feel the need to mess with it.


All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they
could have simply ordered that anyone who passed Element 2, 3 or 4
gets Element 1 credit.

But they didn't.


Maybe they didn't feel that they could do that when they had 19
petitions dumped on them?


I doubt that. Maybe the No coders can try to throttle the petition
process so that messy things like the law, due process and free speech
can be eliminated for expediency?



NCI did try to get the FCC to issue a Memorandum Report and Order, but as
you say, the FCC probably thought that would deny due process to all the
people who filed petitions, which is probably fair comment.


(major tongue in cheek mode here, I know you would never seriously
suggest that people should be able to speak their mind)



I'm all for free speech. Why do you think otherwise?


You've been making a lot of comments on all those petitions.


There
is no consensus, so I think they will choose from whatever has been
proposed those things that suit their own organisational objectives,
i.e. reducing administrative burden. IOW, fewer tests and fewer
licence classes suits the FCC.

Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and Tech
Pluses so that there would be four classes and no closed-out classes.
Others have proposed similar freebies. FCC has consistently said no,
and keeps the Tech Plus, Advanced and Novice alive in their rules and
database. At the current rate of decline, it may be 15 more years
before the last Advanced is gone.


A mistake IMO. I don't think closed classes are a good idea. It's
better to make a clean break and get everybody in the same system.



I predict the code test will not be a continuing feature in the NPRM,

whatever else is, since eliminating a test reduces administrative
burden and they are already on record as wanting to get rid of it.

Yet they have not done so. If they really think Element 1 should go,
why wasn't it dumped in 2003?



See above. They will have to consider all the petitions and then write
an NPRM that either does or doesn't restructure the licence classes.



Reducing the number of classes also appeals to the FCC, so maybe they
might even adopt most of the League's proposal but get rid of element
1 as well? I don't think so, though, as the line of least resistance
is to keep the current test elements as they are. This means
grandfathering Novice to Tech instead of Tech to General, so that is
what I predict they will do.

Why? Keeping the closed-out license classes costs them little or
nothing. Tech Plus will disappear in a little more than 5 years, as
the last Tech Plus is renewed as Tech. The other two closed-out
classes are slowly dropping, yet may last a lot longer because of
renewals.

Maybe I'll write a proposal...

73 de Jim, N2EY



It's just an unnecessary complication. Three classes are easier to
enforce than six.


Exactly what would be so difficult about it?


- Mike KB3EIA -




It's not particurly difficult, but I can see no need to continue the closed
classes. All those who would get a 'free upgrade' have held their licences
for some time, so I foresee no impact whatsoever from eliminating those
licences and upgrading them.



- mike KB3EIA -


robert casey March 2nd 05 10:19 PM



And if FCC still thinks the code test serves no regulatory purpose,
why didn't they just dump Element 1 in late summer 2003, as proposed
by at least two groups?

I don't know, but you admit they said it serves no regulatory purpose


When did FCC say it?



I can't recall, but you know they did. You've admitted it.


They said it when they did restructuring back in Dec '99



[email protected] March 3rd 05 12:10 AM


Michael Coslo wrote:
Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com


I see. Well, I guess the're not journalists.


I don't understand. Chronological order seems a good way to
post articles.


I agree!

And the code test was not abolished by ITU. All that changed was

that
the treaty no longer requires such a test. Signatory countries are

now
no longer *required by treaty* to have a code test, that's all.



Same thing.


Here is a question:

If a country were to require higher standards for their version of

the
ARS, are they hazing their applicants? If country A requ


something snipped there, I bet!

The FCC say
that they are looking for a consensus amongst us, and they are

also on
record as saying that the code test useful doesn't serve any

useful
purpose.

When did they say those things?



They said that they wouldn't restructure until a consensus emerged


Hehe, that could be a long long time.


FCC didn't need consensusone in 2000.


btw, the FCC's words were "serves no *REGULATORY* purpose"

(emphasis
added) not "useful purpose". BIG difference!



Thanks for correcting the wording, but it really isn't much of a

difference


I respectfully disagree. That is a huge difference. If we were tested


for our knowledge of Electron tube circuitry, it would not be serving

a
useful purpose.


Sure it would! How many hams run electron-tube linear amplifiers today?


And if FCC still thinks the code test serves no regulatory purpose,

why
didn't they just dump Element 1 in late summer 2003, as proposed by

at
least two groups?



I don't know, but you admit they said it serves no regulatory

purpose

Despite the hand wringing, Element 1 is just another part of the

test.
A good case can be made that its inclusion or exclusion makes no
particular difference pro or con to the ARS. So they probably didn't
feel the need to mess with it.


Or maybe they simply followed majority opinion.


All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules, they

could
have simply ordered that anyone who passed Element 2, 3 or 4 gets
Element 1 credit.

But they didn't.



Maybe they didn't feel that they could do that when they had 19

petitions
dumped on them?


I doubt that. Maybe the No coders can try to throttle the petition
process so that messy things like the law, due process and free

speech
can be eliminated for expediency?

(major tongue in cheek mode here, I know you would never seriously
suggest that people should be able to speak their mind)


bwaahaahaa

All kidding aside, I have *never* seen Alun write anything that could
possibly be interpreted to mean that all sides should not have their
say.

There's another frequent poster here who has told others to
"shut the hell up", but he bears no similarity to Alun except
for being against the code test.

It's just an unnecessary complication. Three classes are easier to

enforce
than six.


Exactly what would be so difficult about it?

It would be nice if there were no closed-off license classes - but not
at the cost of free upgrades. FCC isn't complaining about the admin
cost of Novices and Advanceds, either.

Look at it this way:

An Advanced is same as Extra except for small parts of 4 HF bands,
vanity call choices and some VE privs.

A Novice is a beginner license with certain limited privileges

A Tech Plus or "Tech-with-HF" is a license with the privs of a Tech and
a Novice.

73 de Jim, N2EY


[email protected] March 3rd 05 05:56 PM


Alun L. Palmer wrote:
wrote in news:1109760226.362991.253290
@o13g2000cwo.googlegroups.com:


Alun L. Palmer wrote:
wrote in news:1109706299.033324.211320
@l41g2000cwc.googlegroups.com:

Alun L. Palmer wrote:
"Vince Fiscus, KB7ADL" wrote in
nk.net:

wrote in news:1109689325.032940.133970
@o13g2000cwo.googlegroups.com:

Firstly, it's
very telling that they buried it down the page, just as they

did
with the announcement that the code test was abolished by the

ITU.


And the code test was not abolished by ITU. All that changed was
that the treaty no longer requires such a test. Signatory

countries
are now no longer *required by treaty* to have a code test,

that's
all.

Same thing.


No, completely different things. The change does not require member
countries to drop the code test.


Making a requirement optional is indistinguishable from abolishing

it. It's
just a different form of words used to keep some countries happy.


You wrote:

"the announcement that the code test was abolished by the ITU."

The *treaty requirement* was abolished, not the test itself. Very
different things.
The FCC say
that they are looking for a consensus amongst us, and they are

also
on record as saying that the code test useful doesn't serve any
useful purpose.

When did they say those things?

They said that they wouldn't restructure until a consensus emerged


*When* did FCC say that? They restructured in 2000 without a

consensus.

Maybe a google search would find the answer to that


My point is simply that something said by FCC years and years ago may
or may not still be their thinking today.

btw, the FCC's words were "serves no *REGULATORY* purpose"

(emphasis
added) not "useful purpose". BIG difference!


Thanks for correcting the wording, but it really isn't much of a
difference


Yes, it is. Since FCC's role is regulatory, their interest is in

what
should be regulated, not what's good and bad.


i.e. no regulatory purpose means no purpose useful to them as

regulators -
no contradiction there

Not useful to them doesn't mean not useful at all.

And if FCC still thinks the code test serves no regulatory

purpose,
why didn't they just dump Element 1 in late summer 2003, as

proposed
by at least two groups?

I don't know, but you admit they said it serves no regulatory

purpose

When did FCC say it?


I can't recall, but you know they did. You've admitted it.


Not the point - of course they said it. My point is simply that
something said by FCC years and years ago may or may not still be their
thinking today.

All it would take is a Memorandum Report and Order.
In fact, as a temporary measure pending rewriting the rules,

they
could have simply ordered that anyone who passed Element 2, 3 or

4
gets Element 1 credit.

But they didn't.

Maybe they didn't feel that they could do that when they had 19
petitions dumped on them?


Maybe. Or maybe their mind has changed on the subject.


I think they have beleived that since the '70s, but have hung onto

the code
test under pressure from some hams, including the League. The

question is
not whether their minds have changed (I beleive they haven't) but

whether
they beleive they can get rid of the pesky code test without

upsetting too
many hams. At this point in time I think they can, but it depends on

one's
definition of 'too many'.


What if their minds *have* changed? Perhaps they have looked at the
arguments
provided by pro-code-test folks, and at the results of the
reduction/elimination
of code testing in the USA and other countries, and have concluded that
Element 1 is no big deal. Maybe they've even concluded that it *does*
serve a useful,
regulatory purpose!

Of course, prior to 2003 they couldn't do it, but they had long since


abolished the sending test anyway, even though that was required by

the
ITU. Talk to Phil Kane and see what he thinks of that from a purely

legal
perspective. You can't construe a statute in such a way as to ignore

it's
plain language by arguing that meeting one of the requirements

indicates
that you _could_meet_ (NB: not _have_met_) the other requirement. I

am
talking about _sending_ and receiving Morse code by _hand_ and by

ear. Of
course, it was a treaty, not a statute, but that should make no

difference.

One alleged violation of the treaty (no sending test) does not justify
another.

There
is no consensus, so I think they will choose from whatever has

been
proposed those things that suit their own organisational
objectives, i.e. reducing administrative burden. IOW, fewer

tests
and fewer licence classes suits the FCC.

Maybe.

But back in 1998, ARRL proposed free upgrades for Novices and

Tech
Pluses so that there would be four classes and no closed-out
classes. Others have proposed similar freebies. FCC has

consistently
said no, and keeps the Tech Plus, Advanced and Novice alive in

their
rules and database. At the current rate of decline, it may be 15
more years before the last Advanced is gone.

A mistake IMO. I don't think closed classes are a good idea.


Why not?

It's better to
make a clean break and get everybody in the same system.


All US hams are in the same system. IMHO, and FCC's to date, free
upgrades are *not* a good idea.


Look at it from the other way around. It's not right to have a closed


Advanced licence with some of the theory and some of the privileges

of an
Extra and not admit new people to it.


Sure it is. In fact, there's a precedent for it. From Jan 1 1953 to
November 22 1967, you could not get a new Advanced but existing ones
could be renewed and modified.

That's not fair to the new Generals.


Sure it is. They get the current tests, not the old ones.

IF OTOH, you counter that by saying that there's little difference in

the
theory level, then why not grandfather the Advanceds to Extra?


Because there *is* a difference.

If everything were done your way you could only create licence

classes and
never abolish them.


Nope.

Eventually you would have Heinz 57 varieties of
licence, but only two or three that you could actually apply for, a

system
that only a civil servant could love. The only way to avoid that

would be
to change nothing, ever, which may be your hidden agenda.


Not at all.

The closed-off license classes are slowly but surely disappearing. As
hams holding those licenses upgrade or drop out, the numbers will
decline and eventually reach zero. At that point, the license class can
simply be written out of the rules.

FCC kept Advanced as a separate license class not available to new
issues from 1953 to 1967. During most of that time the "database" was
not computerized. Advanceds made up about 40,000 of the then-250,000 US
hams. Today with a computerized database it's a lot simpler.

I think keeping old license classes is better than free upgrades.
Apparently so does FCC.

Yet FCC *turned down* such proposals in the past. They prefer more
classes to free automatic upgrades. Enforcement is a nonissue; the

FCC
folks know where the subbands are. And it's the rare ham who

strays,
judging by enforcement actions.

73 de Jim, N2EY


I think they turned them down for lack of consensus on our part. If

we
agree, then they'll do it.


Perhaps. But we don't agree!

The fact is that comments to FCC show no consensus on a number of
issues. In fact, if you look at the number of *individuals* who comment
pro-or-con on code testing, you find majority support *for* the test.
Now since everyone is free to comment on FCC proposals, why shouldn't
the majority opinion decide?



73 de Jim, N2EY



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