[[CW] W6BNB's comments to FCC]

[Brad Farrell]

What a difference 5 years makes.  =

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"David J. Ring, Jr." <n1ea@arrl.net> wrote:

> Earlier comments from W6BNB worth quoting...
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> Federal Communications Commission
> Wireless Telecommunications Bureau
> 1919 M Street, N.W.
> Washington, D.C. 20554
> =

> AUG 14 1998
> =

> Gentlemen:
> =

> Re: Amateur Service Review,
> =

> Your desire to simplify the amateur radio service is probably
> well founded but it can also be improved. First, instead of
> having 6 license grades, only 3 are needed. These are:
>    =

> The LOWEST license class, termed "Class c", would be for amateurs
> who are not interested in making long distance (DX) contacts and
> who have no desire to use what has historically been the basis of
> all amateur work, the Morse Code ("CW'). This license would allow
> such people to operate on all VHF and UHF amateur bands (above 30
> MHz), using any legal amateur mode including practicing CW or MCW
> with other amateurs. This license test should cover basic
> electricity, basic active devices, basic radio circuits, basic
> radio systems, VHF and UHF antennas, and radio laws pertaining to
> amateur operations on VHF and UHF bands.
>    =

> The MIDDLE License class, termed "Class B", would be for amateurs
> who want to operate in the HF range (1.8 MHz to 29.7 MHz, as well
> as on the VHF and UHF amateur bands, using either CW or any other
> legal mode. The lowest 25 kHz of all HF bands above 3.5 MHz,
> which are usually used world-wide for DX CW communicating, would
> be limited to CW for both class B and class A license holders.
> The second 25 kHz should be reserved for Class A (see next
> paragraph) licensed amateurs for higher speed CW work. The next
> 25 kHz would also be for CW. The next 50 kHz would be for all
> modes other than forms of radiotelephone. The remainder of all
> bands would be for CW and radiotelephone only. (CW must be
> allowed on all amateur frequencies because it requires the least
> sophisticated equipment for 2-way emergency radio communications)
> =

> This license test should go deeper into electricity, active
> devices, radio circuits, radio systems, HE, UHF and VHF antennas,
> radio laws pertaining to amateur operating on all bands, plus a
> CW sending and receiving test at 13 words-per-minute (wpm). * *
>   =

> The TOP License class, termed "Class A", would be for higher
> speed CW amateurs. It would only differ from the Class B license
> in requiring a CW sending and receiving test at 20 wpm. (The more
> advanced theory test given for the Class B license should include
> all of the theory required for any mode of HF amateur
> operations.)
>  =

> **The suggested 12 wpm test by ARRL is not quite high enough.
> (ARRL is mostly interested in increasing the number of amateur
> operators to sell more magazines and other items and attract more
> advertisers). This writer taught CW and radio licensing
> professionally, at Community College level, for 27 years besides
> working as a licensed CW operator aboard ships and in police
> radio. His 700+ page text, "Electronic Communication", published
> by McGraw-Hill, includes chapters on "Operating Fundamentals", on
> "Amateur Radio" and on "Radio Rules and Licenses". He has found
> that the human mind first tries to learn code reception by
> memorizing what dots and dashes are in letters being heard. This
> can be done fairly well up to perhaps 12 wpm. His first amateur
> test was at 10 wpm and he can remember still counting dots and
> dashes for some letters. Students take almost as much time to
> progress from 10 to 13 wpm as they take for 0 to 10 wpm. By the
> time they reach about 13 wpm they no longer hear separate dots
> and dashes but recognize the letter sounds as specific letters.
> They have finally learned the code! For anyone not familiar with
> Morse Code: The letter "S" is sent as dot-dot-dot. A person
> capable of receiving at 13 wpm hears it as "dididit" and
> recognizes this sound as the letter "S". Similarly, the letter
> "I?" is sent as dot-dot-dash-dot. The sound of "dididahdit" is
> instantly recognized as the letter "F". The same is true of all
> letters, numbers, punctuation and special operating signs
> used in Morse Code. Back in the 193O's, the FCC recognized that
> code is learned at 13 wpm so it increased amateur Morse Code
> speed tests from 10 to 13 wpm. (Just because many foreign
> countries give 12 wpm tests is no reason why the U.S.A. shouldn't
> do it properly.)
>    =

> There is only one way of giving worthwhile code tests - plain
> language words including some numbers are sent at 13 (or 20) wpm
> for 4 or 5 minutes. The test should be considered passed if there
> is one minute during this copy time at 13 (or 20) wpm with at
> least 65 (or 100) letters copied correctly in succession. The
> same is true of a 4 or 5 minute sending test - 65 (or 100)
> letters must be properly sent in succession in one minute. (Any 5
> letters plus a space is considered one word.)
>   =

> The present method of sending for a given time at a required
> speed and then giving a multiple-guess test on what was
> transmitted does not test code receiving ability. One amateur
> told me he went in to try for a Novice 5-wpm test but was talked
> into trying the 20-wpm Extra Class CW test. He was not sure if he
> really knew 5 wpm or not when he went in, but he passed the
> 20-wpm multiple-guess test! Of course no sending test was at 20
> wpm, which would have proved him unqualified. Sending tests have
> not been required for years! I am constantly working Extra Class
> licensed operators who can not send or receive at even 10 wpm.
> The method presently being used is a BAD method of testing code
> ability! It should be changed.
>   =

> A 5-wpm code test is of no use except to raise the number of
> amateurs. This is proven by the 5-wpm tests given Novices in the
> past, now recognized as being essentially useless. If it is
> desired that someone know the Morse Code let them be tested at a
> speed which will show that they are capable of proper operating -
> that they do know how to send and receive at that speed.
>    =

> There will have to be a "Grandfather" clause regarding present
> license holders if new license classes are adopted. "Extra" class
> would become "Class A" - "Advanced" and "General" classes would
> become "Class B" since these operators have all passed 13-wpm
> tests - Other class license holders who have not passed a 13-wpm
> test would become "Class C".
>  =

> It is hoped that this simplified plan for possible changes on our
> present Amateur Radio licensing method will be considered
> favorably.
> =

> Respectfully,
> =

> Robert Shrader
> 11911 Barnett Valley Road
> Sebastopol, CA 95472
> w6bnb@aol.corn
> =

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