[CW] URGENT re FCC Petitions Open for Comment

[Marshall Emm]

The following text is from the ARRL Letter Vol 22 No 34 dated 8/29/03. It 
details 6 (count 'em) petitions for rulemaking to eliminate or change the Morse 
requirement.  PLEASE follow the instructions and file a comment on each and 
every one.  Also please consider petitioning the FCC to make a rule regarding 
the filing of multiple, substantially similar petitions.  In the case of the 
NCVEC petition, if you are an ARRL member you might mention that the ARRL VEC 
abstained from voting on the issue and your (my? our?) opinion that the NCVEC 
has no business petitioning without unanimous support, especially when the 
abstainer is the biggest VEC.  I would question whether the NCVEC has the legal 
standing to file a petition in any case-- it's the "National Conference" of 
VECs or an organization that  "represents" other organizations that "represent" 
their members who are VE's who were never polled on THEIR opinions!.  

Again, please do your part to man the barricades!
73 DE Marshall, N1FN
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[ARRL Letter Vol 22 No 34 dated 8/24/03.]
 ==>FCC INVITES COMMENTS ON SIX MORSE CODE-RELATED PETITIONS

The FCC has invited public comments on six separate Morse code-related
petitions for rule making, some of which would altogether eliminate
Element 1, the 5 WPM Morse test, from the Amateur Service rules (Part 97).
World Radiocommunication Conference 2003 (WRC-03) made optional the
requirement to prove the ability to send and receive Morse signals to
operate below 30 MHz.

A petition from Peter M. Beauregard, KI1I, designated RM-10781, would give
all Technician licensees current Novice/Tech Plus CW privileges on 80, 40,
15 and 10 meters and limited phone and image privileges on 80, 40 and 10
meters. Beauregard said the CW privileges would "encourage Technician
class licensees to upgrade to General" by giving them a "practice area."
He has proposed new Tech phone/image privileges on 3850-3900 kHz and
7225-7300 kHz. His petition would not eliminate Element 1, however.

Pete V. Coppola, KG4QDZ, and family--Tina Coppola, KG4YUM, and Pete A.
Coppola, KG4QDY--have asked the FCC to eliminate Element 1 from the rules.
The Coppolas' petition, designated RM-10782, would grant Tech Plus HF
privileges to current Technician licensees. It also would retain the
current CW-only subbands. The Coppolas asked the FCC to make the change
effective immediately on a provisional basis.

Kiernan K. Holliday, WA6BJH, has asked the FCC simply to "remove all
requirements for knowledge of Morse code" from the Amateur Service rules.
Holliday said there is less reason to require Morse code in the Amateur
Service today. In his petition, designated RM-10783, Holliday also said
the code requirement limits the ability of handicapped individuals to get
ham tickets. "The Commission's policy should be to encourage the use of
Amateur Radio," he said.

Dale Reich, K8AD, petitioned the FCC to delete Element 1 for General class
applicants but keep it in place for Extra class applicants. Under Reich's
scheme, "no-code" Techs wanting HF privileges would have to upgrade to
General first. Reich's petition is designated RM-10784.

Eric Ward, N0HHS, seeks immediate elimination of "proficiency in
telegraphy using Morse code." The "immediate removal of the telegraphy
requirement from Amateur Radio licensing is appropriate and clearly in the
public interest," Ward contended in his petition, designated RM-10785.

In a detailed, nine-page petition, the National Conference of Volunteer
Examiner Coordinators (NCVEC) is calling on the FCC to delete Element 1
and give "Tech Plus" privileges to current Technician licensees. The NCVEC
also asked the FCC to "take expedited action" to allow volunteer examiner
coordinators (VECs) to discontinue administering Element 1 "as soon as
possible."

"The Amateur Service community suffers from the loss to its ranks of a
large number of potentially excellent operators who are turned away
because of the CW requirement," the NCVEC petition said.

The organization, the umbrella group for the 14 VECs in the US, said
there's "no longer any reasonable justification for requiring an applicant
to demonstrate this antiquated skill," and that most applicants never use
Morse after they pass the test. The NCVEC petition is designated RM-10787.

The ARRL-VEC abstained from voting on the NCVEC's petition question when
it came up during the NCVEC's July 25 meeting in Pennsylvania. At its own
July meeting in Connecticut, the ARRL Board of Directors affirmed its
interest in reviewing members' input on the Morse issue as well as on
other possible revisions to Part 97 arising from WRC-03. The Board's
current position is to retain the Morse requirement for HF access.

Two more recently filed petitions--one from No Code International and
another from two amateur licensees--are expected to be put on public
notice in the near future.

Interested parties may file comments on any or all of these petitions
using the FCC's Electronic Comment Filing System (ECFS)
<http://www.fcc.gov/cgb/ecfs/>, which also permits users to view the
petitions and all comments on file. There is a 30-day comment window.

To file a comment, click on "Submit a Filing" under "ECFS Main Links." In
the "Proceeding" field, type the full RM number, including the hyphen, and
complete the required fields. "RM" must be in capital letters, and you
must include the hyphen between "RM" and the five-digit number. You may
type your remarks into a form or attach a file. ECFS also accepts comments
in active proceedings via e-mail, per instructions on the ECFS page.

While a Morse code exam element remains on the books in the US, Canada and
elsewhere, a handful of countries--including Switzerland, Belgium, the UK,
Germany, Norway and the Netherlands--already have moved to drop their
Morse requirements. Austria and New Zealand are expected to do so soon.
 dated73
Marshall Emm
N1FN/VK5FN
n1fn@MorseX.com
Morse Express and Oak Hills Research
"Everything for the Morse Enthusiast"
http://www.MorseX.com
http://www.ohr.com
(303)752-3382
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