[CW] W5YI groups suggestions on ham radio licensing

[David J. Ring, Jr.]

HERE IS N2EY'S RESPONSE TO THE ARTICLE I POSTED HERE A FEW DAYS AGO:

73
DR

 http://gacw.no-ip.org/n2eythree.html

"Amateur Radio in the 21st Century"
We are very glad to reproduce the N2EY remarks on the "Amateur Radio in the
21st Century" paper by the NCVEC group.



Part Three

This is a response to the paper "Amateur Radio in the 21st Century",
prepared by Jim Wiley, KL7CC, with assistance from other members of NCVEC
working on changes to the US Amateur rules. This response is intended to
evaluate and constructively comment on the merits of the various ideas and
changes presented in the paper, regardless of their source.
For purposes of clarity and brevity, the introductions and executive
summaries are not reproduced here.
"Part One" deals with the code test. "Part Two" and "Part Three" deal with
the proposed "Communicator" license.
Since the style of the paper is conversational, I inserted my comments into
the original paper in the same style, so that the paper reads like a
conversation between KL7CC and myself. My comments are preceded with "N2EY".
The main text of the original paper is preceded by "KL7CC".
Here is my response to "Amateur Radio In the 21st Century" (Part Three)



KL7CC: How about those who feel insulted that these new hams are gaining
"free" access to bands that "they had to work hard for".   Excuse me?  Do we
recognize that times have changed and move on, or not?
N2EY: Excuse me? What exactly does "that times have changed and move on"
mean in this context? Are you saying that those who disagree with you should
simply shut up?
KL7CC:  Following that argument to it's logical end, isn't it reasonable to
say that if the newcomers have to learn the old stuff before they can have a
license, then the existing licensees should have to give back their tickets
until they could show they had mastered all the newer techniques too?
Wouldn't that be fair?  I'm sure it seems reasonable to a newcomer.  Sauce
for the goose, and all that, right?
N2EY: Wrong. Licenses are granted for a specific term. They are renewed
based on the licensee having a clean record. It is part of the "conditions
of grant" that licensees will stay current with changes in rules and
regulations as they apply to their license.
KL7CC: A timetable:
As we all know, several petitions requesting that the FCC remove Morse code
testing have been filed. Depending on how soon a NPRM is issued, assuming it
is at all, then we have to wait while they slog their way through the rule
making process.   One of the things that will happen is that comments, both
pro and con, will begin to accumulate.  After a several weeks or at most a
few months, and assuming the majority of comments are in favor of
eliminating the code as a licensing requirement, then we plan to file for a
waiver asking for an immediate end to code testing.  Obviously, this can
only be done if there are enough favorable comments on file for the FCC to
justify granting such a waiver.   The actual change in the FCC rules will
still be in progress, but if we can show that there is enough interest, and
that such a waiver will be beneficial to Amateur Radio as a whole, then
there is a good chance it would be granted.
N2EY: It is also possible that FCC will go through the entire NPRM process
before dropping Element 1.
KL7CC: Very soon (a few days at most) after the Morse requirement
disappears, assuming it does, then we plan to file for the creation of the
"Communicator" license, as detailed elsewhere in this discussion.  We will
follow the same procedure as before, filing a petition for a NPRM, and
starting the clock on that issue.    Assuming the comments on that issue are
also favorable, after a reasonable time has elapsed, we will file a petition
to upgrade Techs to General, and Advanced to Extra, as explained earlier.
We will probably not be able to accelerate the creation of the
"Communicator" license, since it would involve a complete restructure of the
present system, but in case that option should become available, we would
likewise pursue that end.
Next, once the "Communicator" proposal started to look like it would become
reality, we would file another petition asking that the Novice HF
assignments be re-allocated, also as per the previous discussion.  We would
further ask that the re-allocation take place at the same time as the
implementation date of the new license, so that those who passed their tests
would have a place to operate.
N2EY: Why all the steps and delays? Look how long the last restructuring
took! And there are still petitions on the table for refarming the Novice
bands.
If the Communicator is a good idea, then it should be openly discussed and
developed in the entire amateur community now, and a comprehensive proposal
put together so that everything is handled in one NPRM cycle.
KL7CC: In all cases, because this is a multiple step process, useful
information will be gained as each part moves forward.   This is actually a
benefit, because we may very well find that some of the present ideas need
revision before being submitted.
All this will take some time, perhaps spanning several years.  Mixed in with
these proposals, but not part of them, will be the issue of how to best
implement other changes to the amateur regulations that came out of
WRC-2003, such as the 40 meter readjustment.  These issues have their own
timetable, of course, but those issues and the topics discussed in the
possible petitions mentioned here do interact to varying degrees.
In other words, nothing is going to happen next week, and everyone will have
ample time to offer his or her own suggestions as to how to proceed.   There
will be no "rush to judgment".   All the present actions have done, or can
do, is to get something out there for consideration.  There is absolutely no
guarantee that the FCC, or the ham community at large, will accept these
proposals.
N2EY: The thing to do is develop them out in the open, with input from all
interested parties. Otherwise, you are cutting yourself off from the
community whose support you need to make the proposal work.
KL7CC: You have heard a lot about what we are planning.  Now, how about some
of the things we are not addressing at this time:
We are not addressing the issue of reallocation of bands or sub-bands,
either by mode or license class, with the sole exception of using the former
Novice CW sub-bands on 80, 40, 15 and 10 meters to create working space for
new Communicator licensees.  By the way, don't forget that this adjustment
will create more phone space for General, Advanced, and Extra operators at
the same time.  And, in the case of 40 meters, when the WRC-2003
re-allocation adds another 100 KHz the band in regions 1 and 3  (that is to
say, adding 7100-7200 to the present 7000-7100 world wide Amateur
allocation), there will be a 100 KHz phone band overlap all ready to go!
N2EY: Communicators need more than those 4 bands on HF.
KL7CC: We are not suggesting that the CW sub-bands, or the exclusive CW
bands for Extra licensees, be eliminated or otherwise adjusted.  Again, with
the exception of Novice CW, we are not proposing any change whatsoever to
the present band plans or allocations.
N2EY: There are NO exclusive CW subbands in amateur HF or MF. All are shared
with data modes.
With all due respect, if someone doesn't know that simple fact, or cannot
bother to write "CW/data subbands", that person really shouldn't be
proposing policy changes. Just my opinion.
Using terms like "CW bands" and "exclusive CW subbands" has caused some hams
to believe that other modes are not allowed there.
KL7CC: We are not addressing the issue of the relative split between
General, Advanced, and Extra allocations at HF.
We feel that these issues are best dealt with only after some period of
experience with both the proposed new license and a completely code free
licensing structure give us more insight on the best way to proceed.  This
intermediate stage may take a while to properly evaluate.  These issues may
be best addressed at the time that reallocation of the 40 meter band  (per
decisions made at WRC 2003) takes place.  According to the present schedule,
that is not likely to happen sooner than 5 or 6 years from now.   By that
time, we will have accumulated enough data to tell us whether additional
adjustments are in order, or not.
OK, there you have it, the "master plan".    Will it actually turn out this
way?  Probably not.  Just as there are thousands of hams, there will be lots
of suggestions, pro and con, about which is the best way to go.  When (and
if) a petition is filed, and a Notice of Proposed Rule Making (NPRM) is
posted, offer your comments and suggestions.
N2EY: That last sentence sounds like you are saying that no one except NCVEC
should file a petition, or comment, until an NPRM is posted by FCC. I hope I
am mistaken in that interpretation.
KL7CC: The FCC will consider all sides before changing anything.  If a
majority of comments indicate that hams want thing to stay the way they are,
then that's what will happen.
N2EY: That is not what happened with the Restructuring NPRM (98-143). The
majority of comments wanted 2 or 3 code test speeds, but FCC went with just
1 code test speed. The minority opinion was accepted by FCC and the majority
opinion rejected. Perhaps it will be different next time. But there is a
precedent for FCC to reject majority opinion.
KL7CC: If hams want change, and their arguments make sense, then that's what
will happen.  In almost no other country in the world are the governed given
the chance to affect the rules that do the governing.  Use that power if you
wish.  But don't just sit there and complain if you don't act.
A few final words:
There are no black helicopters.
N2EY: I do not place any credibility in conspiracy theories.
KL7CC: This is not a plot by ARRL or Fred (W5YI) or anyone else to sell more
books, antennas, radios, or (fill in the blank).  Yes, ARRL will gain some
new members, the W5YI group will sell a few more books, and possibly some of
the manufacturers and vendors will peddle a few more sets.  Is this bad?
How?
N2EY: It's a bad thing if quality is sacrificed as part of an ill-fated
quest for quantity
Suppose the numbers do not increase dramatically - will NCVEC admit they
were wrong and petition to put back the old system?
KL7CC: It looks like growth of our beloved hobby from here.
N2EY: It looks like some good ideas and some bad ideas from here.
KL7CC: By the way, did you know Fred sold his company some time back?  He
does not particularly stand to gain anything from this effort, nor do any of
the other committee members. Do you suppose the committee members just want
to see our wonderful hobby prosper?   Wouldn't that be an odd reason for
doing what they are doing?
N2EY: I don't know any of the committee members personally, nor do I assume
anyhting about their motivations. The mere fact that someone wants the ARS
to prosper doesn't mean their ideas and proposals are good ones.
KL7CC: Just thought you'd like to know.  Thanks for taking the time to read
this somewhat long explanation, and in the truest sense, 73.
Respectfully submitted by Jim Wiley, KL7CC
With assistance from Fred Maia, W5YI, and Scott Neustadter, W4WW
N2EY: A few closing observations:
All of the above seems focused on the idea of "growth in the ARS" -
specifically, getting more new hams. The license tests in general and the
code test in particular are being cited as causes of low growth. The above
discussion seems to promise lots of new hams if the code test is dropped and
the entry level license requirements reduced. What if the proposed changes
are made and there is no significant long term change in growth? Will we
revert to the previous system?
Back in 2000, code testing was reduced from three speeds to one (5 wpm) and
the written test requirements reduced considerably. There was an initial
surge of new hams and upgrades, but in the 3-1/2 years since the changes
were made effective, the number of US hams has only grown by about 10,000.
The growth rate now is about the same as it was before the changes.
What is being overlooked in these discussions are other factors limiting the
growth of the ARS. These factors have far more impact than the license
tests, code or written. Two factors come immediately to mind: Lack of
publicity about the ARS in the mainstream media, and CC&Rs making the
installation of an effective amateur station too difficult for many
prospective amateurs.
Thank you for reading my comments
73 de Jim, N2EY - JAMES P MICCOLIS - WAYNE PA 19087 - USA