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