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Old December 28th 05, 04:44 PM posted to rec.radio.amateur.policy
Bill Sohl
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.


None of the above is defined by any FCC rules. At the
moment there are 3 licenses being issued, but even that
can be changed as the FCC is not locked into their
past decisions because of prior comment in any NPRM
and/or R&O.

How does any proposed system handle all these requirements?


It doesn't, nor does it have to. It becomes an issue of
making athe case for whatever is being proposed. Clearly
the ARRL still believes and appears to be still supportive
of an entry level (learner's permit) despite what the FCC
may have already said.

How do we convince FCC to accept the changes?


By making clear and rational arguments and reasons for
whatever the proposed system may be.

Those are the tough ones!

K0HB's proposed 2 class system addresses all these issues.
But FCC denied his ideas.


FCC originally didn't buy a nocode Tech at some time
in the past but eventually changed its mind. FCC also
left 13wpm and 20wpm as requirements for many years
with the lack of change/elimination of said 13/20 wpm
elements supposedly waiting for a "consensus" in the
amateur ranks. In spite of the lack of any consensus on
code the FCC did, in fact, end 13/20wpm test elements
in April 2000 based on arguments and the FCC's own
conclusions at that time.

Bottom line, every statement or opinion offered by the FCC
in any NPRM and/or R&O is not cast in stone and can
end up being revisited and changed at a later review.

So Jim, with that in mind, what is your specific proposal?

Cheers,
Bill K2UNK


  #2   Report Post  
Old December 28th 05, 07:37 PM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


Bill Sohl wrote:
wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.


None of the above is defined by any FCC rules. At the
moment there are 3 licenses being issued, but even that
can be changed as the FCC is not locked into their
past decisions because of prior comment in any NPRM
and/or R&O.

How does any proposed system handle all these requirements?


It doesn't, nor does it have to. It becomes an issue of
making athe case for whatever is being proposed. Clearly
the ARRL still believes and appears to be still supportive
of an entry level (learner's permit) despite what the FCC
may have already said.

How do we convince FCC to accept the changes?


By making clear and rational arguments and reasons for
whatever the proposed system may be.

Those are the tough ones!

K0HB's proposed 2 class system addresses all these issues.
But FCC denied his ideas.


FCC originally didn't buy a nocode Tech at some time
in the past but eventually changed its mind. FCC also
left 13wpm and 20wpm as requirements for many years
with the lack of change/elimination of said 13/20 wpm
elements supposedly waiting for a "consensus" in the
amateur ranks. In spite of the lack of any consensus on
code the FCC did, in fact, end 13/20wpm test elements
in April 2000 based on arguments and the FCC's own
conclusions at that time.

Bottom line, every statement or opinion offered by the FCC
in any NPRM and/or R&O is not cast in stone and can
end up being revisited and changed at a later review.

So Jim, with that in mind, what is your specific proposal?

Cheers,
Bill K2UNK


For Jim, there is no problem so large nor complex that it cannot be run
away from. We -must- be saddled with a system of licensing and
privileges which are remnants of numerous OBE rules changes, according
to Jim. Not only does he desire the code hurdle to remain, but he is
now claiming that the FCC is the main obstacle to modernization of the
service. Odd, but it is the FCC that is proposing rules changes. Jim
is all about difficulty, hurdles, and obfuscation.

Why not look at the basis and purpose, then design an amateur radio
service around that?

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Old December 28th 05, 11:50 PM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?

From: on Tues, Dec 27 2005 8:45 pm


wrote:
wrote:
rom: "Dee Flint" on Thurs, Dec 22 2005 3:30 pm
"K0HB" wrote in message
"Dee Flint" wrote



Why? With the ease with which the General license will be obtainable, why
would anyone want to start with scaled back privileges?


Exactly, Dee. After all, the current General requires only
two written exams of 35 questions each, and a Morse
Code test of 5 wpm.

So they can "properly" emulate the past and all the "greats"
of "the service." :-)


Gee, Len, you've never qualified for *any* amateur radio license...


Gee, Jim, how many times and how many different ways can you say that?


Brian, it's all Jimmie has left in his verbal arsenal. :-)

He still confuses "qualified" with AUTHORIZED insofar as
"operating."

The FCC is very much AUTHORIZED by Congress to regulate ALL U.S.
civil radio. The FCC AUTHORIZES ability to use the EM spectrum
by means of licensing.

However, neither Congress of the United States nor the Commission
itself requires ANY staffer or commissioner to be licensed in any
of the radio services it regulates. Ergo, under Jimmielogic, the
FCC is "not qualified" to regulate U.S. amateur radio. :-)

That may be why, on 10 December, Jimmie wrote:

"The FCC doesn't license radio amateurs."

The whole point of Jimmie's comment on me was to discourage my
posting. Jimmie's concept of discussion on "amateur radio policy"
is a CLOSED one, limited ONLY to those who have already obtained
an amateur radio license. This is rather wrong in a democratic-
principled society but it fits his insular exclusivity. It also
fits Davie Heil's similar concept about amateur radio, so the
two of them form a mutual-aid enclave in here. Since I don't
agree with the "traditional" ('morse-coded') ideals of old U.S.
amateur radio, Jimmie wants me OUT of the "discussion."

Under Jimmielogic there is NO hope of any unlicensed-in-amateur-
radio person "discussing" anything, regardless of previous
experience in any other radio service. [in Jimmieworld
"amateur radio" is very much different than any other radio
service, therefore ALL unlicensed-in-amateur-radio persons are
"unqualified" to discuss anything] Unlicensed=in-amateur-radio
persons may (in Jimmieconcepts) ask polite questions, but must
never ever disagree with Jimmie (or his mutual opinion aid
enclave) in so doing. At that point, Jimmieguru takes over and
copies off reams of league-speak phrases, elevating amateur
radio to planes of existance far beyond what it really is...just
a hobby. QED.



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Old December 29th 05, 12:33 AM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


wrote:
From:
on Tues, Dec 27 2005 8:45 pm


wrote:
wrote:
rom: "Dee Flint" on Thurs, Dec 22 2005 3:30 pm
"K0HB" wrote in message
"Dee Flint" wrote


Why? With the ease with which the General license will be obtainable, why
would anyone want to start with scaled back privileges?

Exactly, Dee. After all, the current General requires only
two written exams of 35 questions each, and a Morse
Code test of 5 wpm.

So they can "properly" emulate the past and all the "greats"
of "the service." :-)

Gee, Len, you've never qualified for *any* amateur radio license...


Gee, Jim, how many times and how many different ways can you say that?


Brian, it's all Jimmie has left in his verbal arsenal. :-)


If so then he is more hollow than the strawmen that he trots out.

He still confuses "qualified" with AUTHORIZED insofar as
"operating."


They are synonymous to him.

The FCC is very much AUTHORIZED by Congress to regulate ALL U.S.
civil radio. The FCC AUTHORIZES ability to use the EM spectrum
by means of licensing.

However, neither Congress of the United States nor the Commission
itself requires ANY staffer or commissioner to be licensed in any
of the radio services it regulates. Ergo, under Jimmielogic, the
FCC is "not qualified" to regulate U.S. amateur radio. :-)


Not Qualified?

That may be why, on 10 December, Jimmie wrote:

"The FCC doesn't license radio amateurs."


Wonder if Riley got a copy of that original "Jimmyism"?

The whole point of Jimmie's comment on me was to discourage my
posting. Jimmie's concept of discussion on "amateur radio policy"
is a CLOSED one, limited ONLY to those who have already obtained
an amateur radio license. This is rather wrong in a democratic-
principled society but it fits his insular exclusivity. It also
fits Davie Heil's similar concept about amateur radio, so the
two of them form a mutual-aid enclave in here. Since I don't
agree with the "traditional" ('morse-coded') ideals of old U.S.
amateur radio, Jimmie wants me OUT of the "discussion."


They do try to run people off who happen to disagree with them. I even
entertained thoughts of leaving the group at one time, but I won't let
them run me off. I plan to turn off the lights when this group is
done. Between Steve and Mark, that may be sooner than I thought.

Under Jimmielogic there is NO hope of any unlicensed-in-amateur-
radio person "discussing" anything, regardless of previous
experience in any other radio service. [in Jimmieworld
"amateur radio" is very much different than any other radio
service, therefore ALL unlicensed-in-amateur-radio persons are
"unqualified" to discuss anything] Unlicensed=in-amateur-radio
persons may (in Jimmieconcepts) ask polite questions, but must
never ever disagree with Jimmie (or his mutual opinion aid
enclave) in so doing. At that point, Jimmieguru takes over and
copies off reams of league-speak phrases, elevating amateur
radio to planes of existance far beyond what it really is...just
a hobby. QED.


The Holy Grail is just a hobby? Get ready for some off-topic british
humor.



bb

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Old December 29th 05, 12:48 AM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?

Bill Sohl wrote:
wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.


None of the above is defined by any FCC rules.


That's true, Bill.

But from FCC actions and reactions over the past 20 years
plus, it's pretty clear that FCC is acting in accordance with
those ideas.

At the
moment there are 3 licenses being issued, but even that
can be changed as the FCC is not locked into their
past decisions because of prior comment in any NPRM
and/or R&O.


Of course! But at the same time, FCC isn't likely to change
their mind in the near future on those issues unless somebody
comes up with a really killer argument for the change.

How does any proposed system handle all these requirements?


It doesn't, nor does it have to. It becomes an issue of
making athe case for whatever is being proposed.


And that has to be done in a way that will convince FCC.

Particularly, to convince FCC to overrule decisions it made
just recently.

Clearly
the ARRL still believes and appears to be still supportive
of an entry level (learner's permit) despite what the FCC
may have already said.

From reading the NPRM, it seems to me that FCC isn't against

an entry-level license at all. FCC simply sees the Technician
as the entry-level license for US ham radio, and also sees
no reason to change that - even though several proposals
have tried to change FCC's mind.

What you're seeing is the classic "Law of Unintended Consequences".
If FCC does what they propose, eliminating the code test will also
eliminate any way for Technicians to get any HF privileges except
by upgrade to General.

How do we convince FCC to accept the changes?


By making clear and rational arguments and reasons for
whatever the proposed system may be.


I'm sure that almost all the proposals and commenters thought they
were making "clear and rational arguments". But FCC said no to
all of them involving more privs for Techs, new license classes,
automatic upgrades, and much more.

Those are the tough ones!

K0HB's proposed 2 class system addresses all these issues.
But FCC denied his ideas.


FCC originally didn't buy a nocode Tech at some time
in the past but eventually changed its mind.


No, that's not how it happened, IIRC.

FCC first proposed a nocodetest ham license for the USA
in 1975, as part of their "two-ladder" restructuring. (If you think
"incentive licensing" made things complex and took away
privs from existing hams, you should see what FCC proposed
in 1975!)

That 1975 proposal was so uniformly opposed by hams, ARRL, and
other groups that it went nowhere. About the only part of it
that was enacted was the renewal of Conditionals as General,
and the Novice becoming full renewable like other licenses.

Then in 1983 FCC tried again to get a nocodetest ham license. And
again ARRL and others opposed it so strongly that the idea went
nowhere.

Finally in 1990, FCC tried again, and let it be known that this time
they wouldn't take no for an answer. This was when 220 was under
attack from land mobile, and ARRL decided to propose a new
license class that would be a sort of "VHF/UHF Novice". No code
test, simple written test, and the centerpiece of the privs would be
220 MHz privileges. The idea was that new hams would fill up 220
so much that it couldn't be reassigned. FCC saw through that idea,
plus didn't want another license class, so they just dropped the
code test for the Technician.

FCC also
left 13wpm and 20wpm as requirements for many years
with the lack of change/elimination of said 13/20 wpm
elements supposedly waiting for a "consensus" in the
amateur ranks.


Perhaps. Yet anyone who could come up with a doctor's
note could get a medical waiver. Such notes were never
hard to get.

In spite of the lack of any consensus on
code the FCC did, in fact, end 13/20wpm test elements
in April 2000 based on arguments and the FCC's own
conclusions at that time.


Yep. FCC also reduced the written tests at the same time
and closed off three license classes to new issues.

End result is less admin work for FCC. No more medical
waivers, only three written elements instead of five, and
eventual elimination of some rules.

Bottom line, every statement or opinion offered by the FCC
in any NPRM and/or R&O is not cast in stone and can
end up being revisited and changed at a later review.


Agreed - but at the same time, getting them to do so
is an uphill battle. Particularly when such an change will
result in more work for FCC.

So Jim, with that in mind, what is your specific proposal?


I've given it here several times. Perhaps I'll dig it out and
post it again.

My point is not that change is impossible, but that FCC isn't
likely to adopt changes that violate the above principles.

For example, more than one proposal wanted free upgrades.
FCC said no to all of them, and gave reasons why. (See
footnote 142...)

73 de Jim, N2EY

  #8   Report Post  
Old December 29th 05, 04:18 AM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


wrote:
Bill Sohl wrote:
wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.


None of the above is defined by any FCC rules.


That's true, Bill.

But from FCC actions and reactions over the past 20 years
plus, it's pretty clear that FCC is acting in accordance with
those ideas.


What is clear is that in '98 the FCC wanted to modernize the ARS. And
it was pretty clear that they wanted the ARRL to lead in that
modernization. And it was pretty clear that the ARRL had no plan
(gosh, no concensus). When the ARRL saw Carl, Bill, and NCI et al,
heading up the steps of the FCC building, the ARRL finally had the
courage to develop a plan. The FCC wasn't particularly impressed with
the ARRL plan.

Almost 8 years later we're still dealing with a lack of leadership in
the amateur community, even after several NPRMs.

Perhaps NCI needs to ramp up and become an advocate for a broader array
of issues than just the Morse Code Test issue.

  #9   Report Post  
Old December 29th 05, 04:10 PM posted to rec.radio.amateur.policy
Bill Sohl
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


wrote in message
oups.com...
Bill Sohl wrote:
wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.


None of the above is defined by any FCC rules.


That's true, Bill.

But from FCC actions and reactions over the past 20 years
plus, it's pretty clear that FCC is acting in accordance with
those ideas.


It may appear so to you, but I don't believe such is the
case in an absolute sense. We'll just have to disagree on that.
I believe the ARRL also would disagree with you (IMHO).

At the
moment there are 3 licenses being issued, but even that
can be changed as the FCC is not locked into their
past decisions because of prior comment in any NPRM
and/or R&O.


Of course! But at the same time, FCC isn't likely to change
their mind in the near future on those issues unless somebody
comes up with a really killer argument for the change.

How does any proposed system handle all these requirements?


It doesn't, nor does it have to. It becomes an issue of
making athe case for whatever is being proposed.


And that has to be done in a way that will convince FCC.
Particularly, to convince FCC to overrule decisions it made
just recently.


Of course.

Clearly
the ARRL still believes and appears to be still supportive
of an entry level (learner's permit) despite what the FCC
may have already said.

From reading the NPRM, it seems to me that FCC isn't against

an entry-level license at all. FCC simply sees the Technician
as the entry-level license for US ham radio, and also sees
no reason to change that - even though several proposals
have tried to change FCC's mind.


As proposed by the ARRL, the Learner's license
would (IMHO) involve a less intense
syllabus of material and access to some HF.
.. IF that is the case,
and ARRL accepts FCC mindset to leave Tech
as entry level, then what gets changed to
make the Tech an entry level per ARRL mindset.
....and, can I presume that you would be in opposition
to the Tech being changed in that or any other way?

What you're seeing is the classic "Law of Unintended Consequences".
If FCC does what they propose, eliminating the code test will also
eliminate any way for Technicians to get any HF privileges except
by upgrade to General.


Ageed...which is why I believe there will be some
changes made sometime down the road.

How do we convince FCC to accept the changes?


By making clear and rational arguments and reasons for
whatever the proposed system may be.


I'm sure that almost all the proposals and commenters thought they
were making "clear and rational arguments".


Of course they did.

But FCC said no to
all of them involving more privs for Techs, new license classes,
automatic upgrades, and much more.


Yet nothing in the FCC's rejection even comes close to stating
their decision is absolute/final and irrevocable based on the
princioples that you ascribe to the FCC.

Those are the tough ones!

K0HB's proposed 2 class system addresses all these issues.
But FCC denied his ideas.


(SNIP of history of nocode....because in the end, it came to pass
anywayregardless of who originated the idea. )

FCC also
left 13wpm and 20wpm as requirements for many years
with the lack of change/elimination of said 13/20 wpm
elements supposedly waiting for a "consensus" in the
amateur ranks.


Perhaps. Yet anyone who could come up with a doctor's
note could get a medical waiver. Such notes were never
hard to get.


But in the overall perspective waivers were used only by
a relatively small percentage of new hams. In the few VE
sessions I assisted in I don't recall ever seeing one being
used. Was the waiver process abused by some?
Probably, but it wasn't a wide practice at all.

In spite of the lack of any consensus on
code the FCC did, in fact, end 13/20wpm test elements
in April 2000 based on arguments and the FCC's own
conclusions at that time.


Yep. FCC also reduced the written tests at the same time
and closed off three license classes to new issues.


I presume you mean the FCC reduced the number
of written tests as opposed to the overall
difficulty of the test material since the syllabus for
the now three remaining test elements did not change.

(SNIP)

End result is less admin work for FCC. No more medical
waivers, only three written elements instead of five, and
eventual elimination of some rules.


That eventual elimination, unless
changes are made by the FCC, could
well be upwards of 50+ years assuming there are
some Advanced hams who are in their 20s.

Bottom line, every statement or opinion offered by the FCC
in any NPRM and/or R&O is not cast in stone and can
end up being revisited and changed at a later review.


Agreed - but at the same time, getting them to do so
is an uphill battle. Particularly when such an change will
result in more work for FCC.


On the issue of a learners license I see no additional
work for FCC if there are only one or two other
licenses as some (e.g. Hans) have proposed.

So Jim, with that in mind, what is your specific proposal?


I've given it here several times. Perhaps I'll dig it out and
post it again.


Does it reflect any of the options I listed above?

My point is not that change is impossible, but that FCC isn't
likely to adopt changes that violate the above principles.


In your opinion that is. In fact, several of the principals you
listed are only your interpretation based on FCC decisions
as opposed to the FCC ever articulating or stating them
as fact.

For example, more than one proposal wanted free upgrades.
FCC said no to all of them, and gave reasons why. (See
footnote 142...)


Neither of us may be around to collect on this bet, but I'll
bet you a dinner anywhere that sometime down the road
the FCC will "simplify" the rules and regs by renewing
Advanced as either Extra or General when the number
of Advanced drops to a small percentage of all
amateurs. I also believe that IF a learner's license does
come to pass, the FCC will make all current Novice
licenses renewable to that new license name AND will
make the rules for the existing Novice the same as whatever rules
and privileges are given to the new learner's class.

Cheers,
Bill K2UNK


  #10   Report Post  
Old December 31st 05, 12:21 AM posted to rec.radio.amateur.policy
 
Posts: n/a
Default How many licenses should there be, why and what privileges?


Bill Sohl wrote:
wrote in message
oups.com...
Bill Sohl wrote:
wrote in message
ups.com...
Bill Sohl wrote:
Scattered around several other threads there have been several
dialogs as to how many licenses the USA should have for
amateur radio.

The options suggested so far seem to be:

(a) 1 License
(b) 1 License plus a "lerner's license"
(c) 2 Licenses plus a "lerner's license"
(d) 3 Licenses
(e) 3 Licenses plus a "lerner's license"

What I wonder about these is how the individual
proponents of each would set the "difficulty
level" of each in comparison to current Tech/Gen/Extra
AND how they see privilege differences (in terms
of power levels and/or band segments and modes)
in multiple license options.

That's just the beginning, Bill.

The devil is in the details, limited by what FCC
has written in various NPRMs and R&Os:
- No existing licensee should lose privileges
- No existing licensee should gain privileges without taking
the required tests
- No free upgrades
- No significant extra admin work for FCC
- FCC sees the optimum level as 3 license classes, none of
which have a limited term and all of which are renewable.

None of the above is defined by any FCC rules.


That's true, Bill.

But from FCC actions and reactions over the past 20 years
plus, it's pretty clear that FCC is acting in accordance with
those ideas.


It may appear so to you, but I don't believe such is the
case in an absolute sense. We'll just have to disagree on that.
I believe the ARRL also would disagree with you (IMHO).


When has the FCC acted in such a way as to *not* be in accordance
with those rules?

At the
moment there are 3 licenses being issued, but even that
can be changed as the FCC is not locked into their
past decisions because of prior comment in any NPRM
and/or R&O.


Of course! But at the same time, FCC isn't likely to change
their mind in the near future on those issues unless somebody
comes up with a really killer argument for the change.

How does any proposed system handle all these requirements?

It doesn't, nor does it have to. It becomes an issue of
making athe case for whatever is being proposed.


And that has to be done in a way that will convince FCC.
Particularly, to convince FCC to overrule decisions it made
just recently.


Of course.


Not impossible, but an uphill go.

Clearly
the ARRL still believes and appears to be still supportive
of an entry level (learner's permit) despite what the FCC
may have already said.

From reading the NPRM, it seems to me that FCC isn't against

an entry-level license at all. FCC simply sees the Technician
as the entry-level license for US ham radio, and also sees
no reason to change that - even though several proposals
have tried to change FCC's mind.


As proposed by the ARRL, the Learner's license
would (IMHO) involve a less intense
syllabus of material and access to some HF.


My understanding is that they're just asking for some
more HF privileges for Techs.

. IF that is the case,
and ARRL accepts FCC mindset to leave Tech
as entry level, then what gets changed to
make the Tech an entry level per ARRL mindset.


Tech has been the defacto "entry level" since 2000.

...and, can I presume that you would be in opposition
to the Tech being changed in that or any other way?


No, you can't. I'd have to see the proposed change first
before deciding if I'm fer it or agin it.

What you're seeing is the classic "Law of Unintended Consequences".
If FCC does what they propose, eliminating the code test will also
eliminate any way for Technicians to get any HF privileges except
by upgrade to General.


Ageed...which is why I believe there will be some
changes made sometime down the road.

How do we convince FCC to accept the changes?

By making clear and rational arguments and reasons for
whatever the proposed system may be.


I'm sure that almost all the proposals and commenters thought they
were making "clear and rational arguments".


Of course they did.


But FCC said no.

But FCC said no to
all of them involving more privs for Techs, new license classes,
automatic upgrades, and much more.


Yet nothing in the FCC's rejection even comes close to stating
their decision is absolute/final and irrevocable based on the
princioples that you ascribe to the FCC.


Of course not! No regulatory agency is ever going to say that
any decision is final and/or irrevocable.

Those are the tough ones!

K0HB's proposed 2 class system addresses all these issues.
But FCC denied his ideas.

(SNIP of history of nocode....because in the end, it came to pass
anywayregardless of who originated the idea. )


Point is, the FCC was pushing it for a long time.

FCC also
left 13wpm and 20wpm as requirements for many years
with the lack of change/elimination of said 13/20 wpm
elements supposedly waiting for a "consensus" in the
amateur ranks.


Perhaps. Yet anyone who could come up with a doctor's
note could get a medical waiver. Such notes were never
hard to get.


But in the overall perspective waivers were used only by
a relatively small percentage of new hams.


I've heard figures as high as 10%.

In the few VE
sessions I assisted in I don't recall ever seeing one being
used. Was the waiver process abused by some?
Probably, but it wasn't a wide practice at all.


Who can say what constitutes "abuse" if the person got
a doctor's note?

In spite of the lack of any consensus on
code the FCC did, in fact, end 13/20wpm test elements
in April 2000 based on arguments and the FCC's own
conclusions at that time.


Yep. FCC also reduced the written tests at the same time
and closed off three license classes to new issues.


I presume you mean the FCC reduced the number
of written tests as opposed to the overall
difficulty of the test material since the syllabus for
the now three remaining test elements did not change.


What FCC did was to reduce both the number of tests and
the total number of questions for each class of license.

(SNIP)

End result is less admin work for FCC. No more medical
waivers, only three written elements instead of five, and
eventual elimination of some rules.


That eventual elimination, unless
changes are made by the FCC, could
well be upwards of 50+ years assuming there are
some Advanced hams who are in their 20s.


Only true if those hams continue to renew and never
ever upgrade.

Bottom line, every statement or opinion offered by the FCC
in any NPRM and/or R&O is not cast in stone and can
end up being revisited and changed at a later review.


Agreed - but at the same time, getting them to do so
is an uphill battle. Particularly when such an change will
result in more work for FCC.


On the issue of a learners license I see no additional
work for FCC if there are only one or two other
licenses as some (e.g. Hans) have proposed.


The big admin issue with new license classes is that the
database has to be re-done.

So Jim, with that in mind, what is your specific proposal?


I've given it here several times. Perhaps I'll dig it out and
post it again.


Does it reflect any of the options I listed above?


I'll post it and you can decide.

My point is not that change is impossible, but that FCC isn't
likely to adopt changes that violate the above principles.


In your opinion that is. In fact, several of the principals you
listed are only your interpretation based on FCC decisions
as opposed to the FCC ever articulating or stating them
as fact.


They're observations based on FCC's behavior for more than
20 years. Can you cite examples where FCC did not act
according to them?

For example, more than one proposal wanted free upgrades.
FCC said no to all of them, and gave reasons why. (See
footnote 142...)


Neither of us may be around to collect on this bet, but I'll
bet you a dinner anywhere that sometime down the road
the FCC will "simplify" the rules and regs by renewing
Advanced as either Extra or General when the number
of Advanced drops to a small percentage of all
amateurs.


You don't have to bet me, Bill, we'll do dinner one of these
days eventually. I'm just sorry I missed the chance to
meet Carl in person when he was down here some months
back.

I also believe that IF a learner's license does
come to pass, the FCC will make all current Novice
licenses renewable to that new license name AND will
make the rules for the existing Novice the same as whatever rules
and privileges are given to the new learner's class.


That's not unreasonable - particularly considering that
there are only about 29,000 Novices left and the number
keeps dropping every month.

73 de Jim, N2EY



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