[Ares-races] NCVEC Files No-Code (No Morse Code) Petition with FCC
[email protected]
[email protected]
Wed, 30 Jul 2003 23:49:11 EDT
The following is forwarded without comment by the sender.
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From: <A HREF=3D"http://www.qrz.com/index.html">http://www.qrz.com/index.ht=
ml</A>
The attached Petition for Rulemaking (dated July 29.2003) has been filed by=20
the National Conference of VECs with the Secretary, FCC, Washington DC. =A0I=
t=20
requests an immediate end of Morse code testing.
73/Fred/W5YI, Chairman
NCVEC Rules Committee=20
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
=20
RM.-
In the Matter of Amendment of Part 97 of the Commission's Amateur Service=20
Rules to Eliminate Morse code testing =20
=20
To: =A0The Commission=20
PETITION FOR RULE MAKING
The National Conference of Volunteer Examiner Coordinators (NCVEC) is the=20
umbrella organization comprised of the fourteen organizations charged since=20=
1984,=20
under Section 97.519(a) of the rules of the Federal Communications=20
Commission, 47 CFR =1597.519(a) to develop and administer all Amateur Radio=20=
operator=20
license testing and to electronically file all successful license applicatio=
ns with=20
the FCC. =A0In total, the VECs and their more than 30,000 VEL teams have=20
collectively administered nearly two million examinations during the past tw=
enty=20
years and have notified the FCC to issue approximately a million new and upg=
raded=20
Amateur Radio licenses.
Once a year, the various Volunteer Examiner Coordinator organizations meet a=
t=20
their annual conference to discuss the various issues that impact Amateur=20
Radio operator testing. =A0At their July 25, 2003, meeting held with the FCC=
in=20
Gettysburg, PA, the VECs overwhelmingly agreed that Morse code testing shoul=
d be=20
immediately ended since it was now possible to do so. =A0It was also noted t=
hat=20
countries have already begun discontinuing Morse examinations. =A0As a resul=
t=20
the VECs voted to file this Petition asking that the FCC take expedited acti=
on=20
to allow them to discontinue administering Element 1, the 5 words-per-minute
telegraphy examination as soon as possible.
Pursuant to Section 1.405 of the Commission's procedural rules (47 C.F.R.=20
=151.405), the NCVEC hereby respectfully requests that the Commission issue=20=
a=20
Notice of Proposed Rule Making at an early date looking toward amendment of=20=
the=20
rules governing the Amateur Radio Service, 47 C.F.R. =1597.1 et seq., as set=
forth=20
herein and in the attached Appendix.
The rule changes requested herein would terminate the telegraphy examination=
=20
requirement and permit existing Technician Class operators to access HF=20
spectrum as provided in 47 C.F.R. =15 97.301(e) without the necessity of pas=
sing a=20
Morse code examination. =A0This request to eliminate the Morse code (Element=
1)=20
examination does not necessarily have the support of the ARRL Board since th=
ey=20
have yet to develop a position on the matter. =A0In support of its petition,=
NCVEC=20
states as follows:
I. =A0Introduction and Background
Since the turn of the century, the Morse code, invented by American Samuel=20
Morse and first used in 1844, has been the foundation of early distress and=20
safety communications. =A0Although Morse code (or CW, as it is commonly call=
ed) =A0was=20
the primary mode of communications from the late 19th Century through the=20
early 20th Century, it has all but become obsolete in practically all other=20
contemporary communication systems. Due to the emergence of satellite and d=
igital=20
communications, manual telegraphy is no longer used or required in any radio=
=20
service other than in the Amateur Service.
Radiotelegraphy in the maritime service has been phased out in favor of=20
modern technology. =A0The last vestige of manual telegraphy began being phas=
ed out in=20
the maritime service in 1988 when the International Maritime Organization=20
adopted the Global Maritime Distress and Safety System (GMDSS).
In the 1990's, countries around the world began closing down their distress=20
500 kHz calling frequency watch which had been in use since 1912. =A0The fin=
al=20
500 kHz message sent by the US =A0Coast Guard took place from station NMN=20
(Chesapeake Virginia) on April 1, 1995, and they no longer monitor the frequ=
ency.
Even though the commercial world eliminated Morse code as a communications=20
medium many years ago, it has continued on the Amateur bands because manual=20
Morse proficiency was an international Amateur Service requirement when oper=
ating=20
on spectrum under 30 MHz.
II. =A0Telegraphy requirement in the Amateur Service
There are many communications modes and emissions available to the radio=20
amateur and manual CW is just another one that certainly deserves no special=
=20
priority. =A0The amateur radio operator examination process does not require=
a=20
practical demonstration in the ability to use any other mode - even though m=
ore than=20
a thousand modes and emissions are available to the Amateur Service.
The international law previously required unspecified proficiency in the=20
International Morse code when the operation takes place in the medium or hig=
h=20
frequency bands. =A0Because of technological advances, this regulation has b=
ecome=20
inconsistent with the goals of the Amateur Service since it provides a barri=
er=20
to otherwise qualified individuals who wish to experiment and communicate be=
low=20
30 MHz. =A0There can be no doubt that the Morse code proficiency requirement=
s=20
have constituted an unnecessary and artificial impediment to fuller use of t=
he=20
Amateur Radio Service for many potential and existing amateurs.
It appears that the reason that many (no-code) Technician amateurs are not=20
upgrading to license classes that require telegraphy suggests that the Morse=
=20
code requirement may be a significant barrier.
III. =A0Morse code testing is a burden to the applicant
It should be noted that while today's personal computers can easily send and=
=20
receive telegraphy, the international Morse code "sent by hand and received=20=
by=20
ear" requirement continued as a worldwide fundamental requirement for an=20
amateur operator license until the recent actions by the International=20
Telecommunications Union.
The taking of the telegraphy examination is an unnecessary burden upon the=20
applicant. =A0Experience has shown that it is more often than not a very str=
essful=20
experience for the examine =A0With the elimination of the international=20
requirement for skill in manual telegraphy, there is no longer any reasonabl=
e=20
justification for requiring an applicant to demonstrate this antiquated skil=
l.
It is one that must be acquired through rote memorization of the character=20
meanings of some 43 combinations of audible dots and dashes: 26 letters of=20=
the=20
alphabet, numerals 0 through 9, four punctuation marks and three characters=20
unique to CW. =A0 This must be followed by numerous practice sessions until=20=
the=20
necessary skill is achieved. =A0Most applicants, once they pass the code exa=
m,=20
never use the mode on the amateur airwaves. =A0And many, perhaps most, could=
not=20
pass it again if required to do so.
While it continues to serve some amateur operators well, as it did in the=20
early days of radio, it is now but one of many modes available to amateur=20
operators. =A0The lack of interest in CW has turned many prospective amateur=
operators=20
away from the Amateur Service. =A0
IV. Morse proficiency is not an indication of a quality operator
Some amateurs believe that the effort and sacrifice needed to learn Morse=20
code indicates a more dedicated and, therefore, a better candidate for Amate=
ur=20
Radio. =A0No evidence exists, however, that supports a relationship between=20=
manual=20
telegraphy proficiency and the quality, desirability or motivation of the=20
operator.
What the Morse code licensing requirement does do, however, is to greatly=20
reduce the number of applicants operating in the medium and high frequencies=
.=20
=A0Many people question why an individual with vast knowledge in the electro=
nics=20
field should be excluded from operating on HF spectrum due to a personal=20
disinterest in the Morse code.
Continuing the use of Morse code proficiency as a means with which to gauge=20
"quality" or to limit the number of amateur radio operators accessing public=
=20
spectrum is certainly at odds with the FCC's mandate to promote the wider us=
e of=20
radio and its commitment to the use of emerging technologies.
V. =A0Morse proficiency should not be required to operate in the voice mode
It appears that most amateurs want to communicate in the voice mode. It=20
makes no sense from a regulatory perspective to require radio amateurs to be=
Morse=20
proficient when the greater majority of radio amateurs do not desire to use=20
that mode and there is no regulatory reason for them to do so.
The future of Amateur Radio encompasses many modes undreamed of just a few=20
years ago. =A0Although manual telegraphy is a noble part of the Amateur Radi=
o's=20
past, it is no longer the prime emission mode.
In short, the Commission should ensure that the amateur examination elements=
=20
are appropriate for the types of operation that will be performed by the=20
licensee.
VI. =A0An unnecessary burden upon the VEC system
The administration of a CW examination imposes an unnecessary burden upon th=
e=20
VE teams who must prepare and administer the CW examinations. It requires=20
extensive preparation and special equipment to prepare and administer proper=
ly.=20
=A0It is often disruptive and unsettling to those other examinees who are ta=
king=20
one of the written examinations within the same room.
Under =15 97.507(d), the VEs must prepare and record a series of messages=20
sufficient to preclude any one message from becoming known to the examinees.=
=A0 Each=20
message must contain every one of the 43 telegraphy characters at least once=
=20
during period of at least 5 minutes. =A0At the prescribed speed of 5 words p=
er=20
minute, and at the prescribed 5 characters per word, the message is little m=
ore=20
than 25 words in length. =A0In practice, it is a difficult task to compose a=
=20
realistic
message under these limitations. =A0It is also an unnecessary burden upon th=
e=20
coordinating VECs since most of them also prepare telegraphy examinations fo=
r=20
their VE teams.
VII. =A0An unnecessary burden upon the amateur service community
The amateur service community suffers from the loss to its ranks of a large=20
number of potentially excellent operators who are turned away because of the=
CW=20
requirement. =A0Either because of lack of the requisite aptitude for sending=
=20
and receiving CW or because of an unwillingness to spend the time acquiring=20=
a=20
skill for which they find of no value to them, they forego becoming amateur=20
operators.
VIII. =A0An unnecessary burden upon the FCC
Now that the international (treaty) Morse code requirement is optional, the=20
FCC can expect to receive numerous requests for waivers of the Morse code=20
examination due to applicant hearing and other medical conditions in order t=
o be=20
compliant with the Americans with Disabilities Act (ADA).
When there were multiple code tests, the FCC cited the international (treaty=
)=20
requirement, as the reason that the five word-per-minute code test could not=
=20
be waived. =A0This case no longer applies and the FCC will have to develop=20
procedures to guide both themselves and the VECs/VEs in handling requests fo=
r code=20
exam waivers that are certain to come.
Dealing with requests for a waiver of the code exam could create an=20
unnecessary burden on the FCC and VECs/VEs and consume an excessive amount o=
f time and=20
resources. =A0It seems illogical to require all amateur examinees to pass a=20
requirement that could be waived by the actions of a physician. =A0History h=
as shown=20
that physician-initiated waiver requests have been very controversial in the=
=20
Amateur Service.
IX. =A0World Administrative Radio Conference 2003
The only changes made to the international Amateur Service regulations over=20
the last 75 years concern the frequency above which amateurs may operate=20
without Morse testing. =A0At their Washington, DC conference in 1927, the IT=
U (then=20
called the International Telegraph Union) allocated frequency bands to the=20
various radio services and established operating guidelines and operator=20
qualifications. =A0It was deemed important that Amateurs prove an ability to=
transmit and=20
receive communications in Morse signals since, at the time, radiotelegraphy=20
was the primary means of long range communication.
Since then, the administrations comprising International Telecommunication=20
Union have reviewed and voted to relax the Amateur Service's mandatory Morse=
=20
proficiency requirement at every international conference capable of doing s=
o.
In 1947 (Atlantic City), the ITU agreed that Morse proficiency should only b=
e=20
required when the operation took place on frequencies below 1000 MHz (1 GHz)=
.=20
=A0At WARC-59, the 1959 World Administrative Radio Conference, this level=20
dropped to 144 MHz. =A0A further reduction was made at WARC-79 to 30 MHz. =20
Consequently, up until recently, Article S25.5 =153 read: =A025.5 =A0 =15 3.=
=A0 =A01) Any person=20
seeking a license to operate the apparatus of an amateur station shall prove=
=20
that he is able to send correctly by hand and to receive correctly by ear, t=
exts=20
in Morse code signals. The administrations concerned may, however, waive
this requirement in the case of stations making use exclusively of=20
frequencies above 30 MHz.
At WRC-2003, the international Radio Regulation Article S25.5 =15 3 was revi=
sed=20
to make the Morse code testing requirement a matter for each licensing=20
administration to decide for itself. =A0Effective July 5, 2003, Article S25.=
5 =153=20
reads: =A025.5 =A0 =A0=15 3. =A0 =A01) Administrations shall determine wheth=
er or not a person=20
seeking a license to operate an amateur station shall demonstrate the abilit=
y=20
to send and receive texts in Morse code signals.
X. =A0Summary of NCVEC proposal to end Morse testing
The attached appendix contains a list of the rules that must be amended if=20
Morse code examinations are to be discontinued. =A0These amendments propose=20=
merely=20
to end the manual telegraphy examination and to permit Technician Class=20
operators the same frequency privileges as those enjoyed by Technician Class=
=20
operators who have passed a code exam.
Therefore, the foregoing considered, NCVEC, the National Conference of=20
Volunteer Examiner Coordinators, respectfully requests that the Commission i=
ssue a=20
Notice of Proposed Rule Making at any early date, proposing the rule changes=
=20
set forth herein, and in the appendix attached hereto.
Respectfully submitted,=20
NCVEC, National Conference of VECs
P.O. Box 565101, Dallas, Texas 75356
By:___
Frederick O. Maia, W5YI, Chairman,
NCVEC Rules Committee
July 29, 2003=20
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APPENDIX=20
PROPOSED RULES
Proposed changes to Part 97 of Chapter I of Title 47 of the Code of Federal=20
Regulations to delete references to the Morse code exam element. =A0Part 97,=
is=20
amended as follows:
PART 97 -- AMATEUR RADIO SERVICE=20
1. =A0Section 97.301 is amended by revising paragraph (e) to read as follows=
.=20
=A0The frequency tables in Section 97.301(a), (b), =A9, (d) and (e) remain=20
unchanged.
97.301 Authorized frequency bands.
The following transmitting frequency bands are available to an amateur=20
station located within 50 km of the Earth's surface, within the specified IT=
U=20
Region, and outside any area where the amateur service is regulated by any a=
uthority=20
other than the FCC. =A0
(d) ******
(e) For a station having a control operator who has been granted an operator=
=20
license of Novice Class, Technician Class or Technician Plus Class:
Wavelength =A0ITU Region 1 =A0 ITU Region 2 =A0 ITU Region=
3 =A0=20
=A0Sharing requirements, see 97.303
=A0 =A0
HF =A0 =A0 =A0 =A0 MHz =A0 =A0 =A0 =A0 =A0 MHz =A0 =A0=20=
=A0 =A0 =A0 MHz =A0=20
=A0 =A0 =A0 =A0 =A0 =A0 paragraph: =A0
80 m =A0 =A0 =A0 3.675-3.725 =A0 3.675-3.725 =A0 =20=
=20
3.675-3.725 =A0 =A0 (a)=20
40 m =A0 =A0 =A0 7.050-7.075 =A0 7.10-7.15 =A0 =A0 =20=
=20
7.050-7.075 =A0 =A0 (a)
15 m =A0 =A0 =A0 21.10-21.20 =A0 21.10-21.20 =A0 =20=
=20
21.10-21.20=20
10 m =A0 =A0 =A0 28.1-28.5 =A0 =A0 28.1-28.5 =A0 =A0 =20=
28.1-28.5
VHF =A0 =A0 =A0 MHz =A0 =A0 =A0 =A0 =A0 MHz =A0 =A0 =A0=20=
=A0 =A0 MHz=20
1.25 m =A0 =A0 - - =A0 =A0 =A0 =A0 =A0 222-225 =A0 =A0=20=
=A0 - - =A0 =A0=20
=A0 =A0 =A0 =A0 (a)
UHF =A0 =A0 =A0 MHz =A0 =A0 =A0 =A0 =A0 MHz =A0 =A0 =A0=20=
=A0 =A0 MHz=20
23 cm =A0 =A0 1270-1295 =A0 =A0 1270-1295 =A0 =A0 1270=
-1295 =20
(h)(i)
2. =A0Section 97.307 is amended by deleting paragraph (f)(9) and revising=20
paragraph (f)(10) to read as follows. =A0Previous =15 97.307(f)(10) is renum=
bered to=20
(f)(9). =A0 Paragraphs (f)(11) to (f)(13) are renumbered to (f)(10) to (f)(1=
2).
=15 97.307 Emission standards.
(f) The following standards and limitations apply to transmissions on the=20
frequencies specified in =1597.305=A9 of this part. =A0
(10) =A0 =A0A station having a control operator holding a Novice Class,=20
Technician Class or Technician Plus operator license may only transmit a CW=20=
emission=20
using the international Morse code or phone emissions J3E and R3E.
3. =A0Section 97.313 is amended by revising paragraph =A9(2) to read as foll=
ows:
=1597.313 Transmitter power standards.
(b) ******
=A9 No station may transmit with a transmitter power exceeding 200 W PEP on:
(1) ******
(2) The 28.1-28.5 MHz segment when the control operator is a Novice Class=20
operator, a Technician Class operator or a Technician Plus Class; or
(3) ******
=20
4. =A0Section 97.501 is amended by revising paragraph (a) and (b) to read as=
=20
follows.
=1597.501 Qualifying for an amateur operator license.
Each applicant must pass an examination for a new amateur operator license=20
grant and for each change in operator class. =A0Each applicant for the class=
of=20
operator license grant specified below must pass, or otherwise receive=20
examination credit for, the following examination elements:
(a) Amateur Extra Class operator: Elements 2, 3, and 4;
(b) General Class operator: Elements 2, and 3;
=A9 ******
5. =A0Section 97.503 is amended by deleting paragraph (a).
=1597.503 Element standards.
(b) ******
6. =A0Section 97.505 is amended by revising paragraph (a)(1), (a)(2), and=20
(a)(3) to read as follows. =A0
Paragraphs (a)(5), (a)(7), and (a)(9) are deleted.
=1597.505 Element credit.
(a) The administering VEs must give credit as specified below to an examinee=
=20
holding any of the following license grants or license documents:
(1) An unexpired (or expired but within the grace period for renewal)=20
FCC-granted Advanced Class operator license grant: Elements 2 and 3.
(2) An unexpired (or expired but within the grace period for renewal)=20
FCC-granted General Class operator license grant: Elements 2 and 3.
(3) An unexpired (or expired but within the grace period for renewal)=20
FCC-granted Technician Plus Class operator license grant: Element 2
(4) ******
(6) ******
(8) ******
(b) ******
7. =A0Section 97.507 is amended by revising paragraph (a), (a)(2), and =A9 t=
o=20
read as follows. =A0Paragraph (d) is deleted.
=1597.507 Preparing an examination.
(a) Each written question set administered to an examinee must be prepared b=
y=20
a VE holding an Amateur Extra Class operator license. =A0A written question=20=
set=20
may also be prepared for the following elements by a VE holding an operator=20
license of the class indicated:
(1) ******
(2) Element 2: Advanced, General, or Technician (including Technician Plus)=20
Class operators.
(b) *******
=A9 Each written question set administered to an examinee for an amateur=20
operator license must be prepared, or obtained from a supplier, by the admin=
istering=20
VEs according to instructions from the coordinating VEC.
8. =A0Section 97.509 is amended by revising paragraph (f) to read as follows=
.=20
=A0Paragraph (g) is deleted.
=1597.509 Administering VE requirements.
(e) ******
(f) No examination that has been compromised shall be administered to any=20
examinee. =A0The same question set may not be re-administered to the same ex=
aminee.
(h) ******
-------------------------------------------
(1)
The following organizations have entered into an agreement with the FCC to=20
coordinate Amateur Radio examinations: Anchorage Amateur Radio Club,
Anchorage, AK; American Radio Relay League (ARRL), Newington, CT; CAVEC,=20
Inc., Huntsville, AL; Golden Empire Amateur Radio Society, Chico, CA; Greate=
r L.A.=20
Amateur Radio Group, North Hills, CA; Jefferson Amateur Radio Club, New=20
Orleans, LA; Laurel Amateur Radio Club, Inc.; Laurel, MD; The Milwaukee Radi=
o=20
Amateurs' Club, Inc., Milwaukee, WI; MO-KAN VEC Coordinator, Richmond, KS;=20
Sandarc-VEC, La Mesa, CA; Sunnyvale VEC Amateur Radio Club, Inc., Sunnyvale,=
CA;=20
W4VEC, High Point, NC; W5YI-VEC, Dallas, TX; Western Carolina Amateur Radio=20=
Society=20
VEC, Inc., Knoxville, TN. =A0=20
The United Kingdom's Regulatory Authority published a "Gazette Notice" on=20
July 25, 2003, discontinuing all Morse code testing in their Amateur Service=
=20
effective July 26, 2003. =A0The effect was that all "Class B" (no code) radi=
o=20
amateurs in Great Britain who previously were restricted to operation above=20=
30 MHz=20
obtained "Class A" access to all Amateur bands. =A0This can be confirmed at=20=
the=20
Radio Society of Great Britain's website and/or the UK "Regulatory Authority=
"=20
(their telecom regulator) website. =A0In addition, effective July 15, 2003,=20=
radio=20
amateurs in Switzerland were given immediate "provisional" authority to=20
operate on the HF amateur bands by the Swiss Federal Office of Communication=
s=20
(OFCOM) while they await formal rulemaking. Citing the recent WRC-03 decisi=
on,=20
OFCOM said the temporary permission to use the HF bands would suffice until=20=
the=20
regulation could be changed. =A0Many other countries are rumored to be in th=
e=20
process of discontinuing Morse code testing.
See 47 C.F.R. =15 503(a.) =20
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Fred Lloyd, AA7BQ =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 =A0 Fo=
under, QRZ.COM
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The preceding is forwarded without comment by the sender.
Bill Lennox
US Air Force (Retired)
Full Time College Student (Emergency Management)
KD7EFP
Assistant Emergency Coordinator - Plans (ARES), Washington County, Oregon
Assistant Radio Officer - Plans (RACES), Washington County, Oregon
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