[Elecraft] Dropping the Code Test

[Stephen W. Kercel]

   At 09:09 AM 9/2/2005 -0400, N2EY at aol.com wrote:

     In  a  message  dated  9/1/05  4:30:13  PM  Eastern  Daylight Time,
     kercel1 at suscom-maine.net writes:

     There  are  a  great  many  of  us who would at least like to see a
     CW
         requirement  maintained  for  the  Extra  Class  exam. There is
     a very
         small   (but   real)  chance  that  the  FCC  would  do that if
     they are
         provided   with   novel   and   compelling  reasons. (Note: The
     traditional
         arguments,  such  as  "Without  the  code  test, ham radio will
     become
         another    Citizen's   Band,"   are   known  to  the  FCC,  and
     they  are
        unconvinced  by  them.  We  need to get the FCC to say, "Gee, we
     never
         thought   of  that.")  If you'd like to see some semblance of a
     code test
        preserved, this is the time to think outside the box.

     Some ideas:
     1)  Don't  compromise on what you really want. FCC has a history of
     going  a step farther, so a comment for Extra only code tests looks
     to  them  like  a  comment  for none at all. If you think Element 1
     should stay, say so!
     2)  Point  out  the  wide  use  of  Morse  Code  on HF by hams, and
     particularly   its  use  by  hams  who  are  technically  inclined,
     homebrewers, etc.
     3)  Despite  the  popularity of the mode, hams using Morse Code are
     rarely the subject of FCC enforcement actions.
     4)  Take  the  time  to  read  the  NPRM  a  couple  of  times, and
     specifically  comment on FCC statements that you disagree with. For
     example,  FCC  called  the  FISTS  recommendations  of written-test
     changes  "vague",  yet they specifically spelled out exact steps to
     be taken to improve the written tests.
     5) The reductions and eliminations in Morse Code testing since 1990
     have  not  resulted in longterm changes in the growth of US amateur
     radio.   Nor  have  they  resulted  in  an  increase  in  technical
     development, etc.
     6)  Suggest  that  FCC  could  do something similar to Canada (they
     still  have  code  testing, but the grade is considered part of the
     overall testing, not a go/nogo standalone element).
     7)  Suggest  that if the code test is eliminated, the bottom 15% of
     each HF band should be set aside for Morse Code only.
     8)  Write  your  comments  in  the  standards  form  used  by  many
     commenters.  (search  ECFS  for my comments to previous proposals -
     last name "Miccolis")
     9)  Include  a  brief  description of your amateur and professional
     experience, education, etc. Whil it may feel like bragging, the FCC
     does look at who is commenting as well as what they say.
     10) Take your time, spellcheck, proofread, etc. It really matters.
     Just IMHO
     73 de Jim, N2EY

   Jim:
   Your HO includes quite a bit of wisdom.
   A few specific reactions:
   1)  Although  many on the list will not agree with me, the reason that
   my  filing is an argument keeping an "Extra only" code test is because
   I  actually  believe it. Speaking only for myself, I have no objection
   opening  the HF bands to people only interested in digital; so long as
   they keep out of the CW-only segments.
   2)  I  personally  agree  with  the  "wide  use of CW by home brewers"
   argument;  it  does  illustrate the fundamental principle of advancing
   the  radio  art.  However,  I  offer  as  how the argument needs to be
   included  in  a  context of other arguments; the FCC is unpersuaded by
   this argument alone.
   3)  This  one  is wonderful! I do not recall its having been mentioned
   before.   Do   you   have  statistics?  Are  they  readily  available?
   Bureaucrats  like  numbers.  If one could show that 99.9% (or whatever
   large  fraction) of enforcement actions are against non-CW operations,
   it would be a telling point.
   4) This is a must. It is clear to me from many of the comments already
   filed  that  the commentor has not read the Notice. Such comments will
   be  dismissed  out  of  hand.  As your FISTS example demonstrates, one
   needs  to  find  the  factual errors in the Notice (easy to do because
   there are so many) and refute them in a polite but compelling manner.
   5) Another true point.
   6) Intriguing.
   7)  Keeping  "CW  only"  segments  is  critical.  Unfortunately,  mode
   allocation   is  outside  the  scope  of  05-235.  I  would  encourage
   commentors on 05-235 to focus on the code test. However, there will be
   future threats to the CW segments, and whenever the FCC floats a trial
   balloon on that idea we need to strangle it in the cradle.
   8)  This  is  very  important.  Preparing the comments in the standard
   format adds enormous credibility.
   9)  Yes,  including the commentor's relevant credentials is a critical
   element  of  the  filing;  it  is  not bragging. These invitations for
   public  comment  are  not  a  popularity  survey; they are intended to
   uncover  considerations that have previously escaped the FCC's notice.
   Arguments  that  can  be  credibly presented as "expert opinion" weigh
   more heavily than those that appear (whether rightly or wrongly) to be
   sentiment or speculation.
   10)  Yes,  especially proofreading by human eyes. It is important that
   the   filing  look  professional  and  carefully  prepared.  A  sloppy
   presentation  predisposes  the reader to presume that the reasoning is
   sloppy as well.
   73,
   Steve
   AA4AK