[Fists] Hundreds have already filed comments via FCC Electronic Comment Filing System

[David J. Ring, Jr.]

*************** The ARRL Letter Vol. 24, No. 30 August 5, 2005
***************

IN THIS EDITION:

* +Amateurs commenting heavily on FCC's Morse proposal
===========================================================

==HUNDREDS FILE COMMENTS ON FCC MORSE PROPOSAL

Hundreds already have filed comments via the FCC's Electronic Comment Filing 
System (ECFS) on the Commission's recent proposal to eliminate the Morse 
code requirement for all license classes. Dozens more--most brief, some 
detailed--are showing up daily. A formal 60-day comment period starts once 
the FCC's Notice of Proposed Rule Making and Order (NPRM&O) in WT Docket
05-235 appears in the Federal Register, but the FCC will accept comments 
filed now. Issued in response to 18 petitions for rule making--including one 
from the ARRL--the FCC's July 19 NPRM&O dealt only with the Morse 
requirement and turned away all other proposed rule changes. A random 
sampling of the more than 360 comments filed as of August 2 suggested the 
tide is running firmly in favor of the FCC's stance. Some even praised the 
Commission.

"The FCC has finally come through," commented Doug Durrett, KC7DJI, a 
Technician class licensee. "Hats off and thumbs up to the 05-235 proposal. 
Get it done ASAP."

Others, such as Jesse T. Franklin, K9GO, were just as adamant that Morse 
code should remain a licensing requirement for those desiring HF access. 
"Morse code has been the foundation of the Amateur Radio Service since the 
very beginning," he asserted. "I feel doing away with the Morse code testing 
would only weaken the service."

Many pro-Morse postings raised the specter of impending chaos on the ham 
bands if the requirement goes away, with some suggesting that eliminating 
Morse testing would be "the beginning of the end for Amateur Radio." As one 
commenter put it, dropping Element 1 would mean "continuing down the 
slippery slope of 'dumbing down' the Amateur Radio Service." Another 
contended that passing a Morse code examination contributes to better 
on-the-air discipline. Still others called Morse an "important tradition," a 
"universal language," a "vital tool" useful in emergencies and--in the words 
of Jan Smoller, KC2CT-- "the one sacred bastion left to preserve the history 
and continuance of the Amateur Radio Service." William R. Ogden, W2WO, 
suggested that Morse code creates a sense of community among radio amateurs.

A relative handful of commenters appear to favor keeping the 5 WPM Morse 
examination for Amateur Extra applicants only. Others asked the FCC to 
revisit the notion of creating a new entry-level license class--something 
else the ARRL and others sought--as well as the recommendation to stop 
making question pools public.

Several licensees who'd gone through the old three-tiered system of Morse 
examination elements indicated they'd like to see the requirement disappear. 
"I support the removal of the Morse code requirement, even though I had to 
pass the 5, 13 and 20 WPM," wrote Brent Crier, N9BC, whose comments were 
fairly typical of that group. "CW is not going to go away like some think. 
If new operators want to use that mode they will learn it."

Robert A. Johnson, K3MQ, was among those characterizing Morse code as 
obsolete, even though he says he operates CW. "Requiring amateurs to learn a 
system which is antiquated meets no public service need," he remarked. "I 
personally use and enjoy Morse code but feel it should be an option for 
those interested--not a requirement." Advanced class operator Marvin B. 
Smith, WA5PSA, said it's "time for Morse code to stand or fall of its own 
accord as a mode."

Many, like Thomas J. Miller, W2HVK, said eliminating the Morse requirement 
would breathe new life into the Amateur Service. "The US could certainly use 
more trained radio operators considering the post 9/11 world we live in," he 
said. "Additional roadblocks (like CW) to upgrading to HF make no sense 
today."

Based on a random sample of 135 comments filed by August 2, approximately 60 
percent favored the elimination of the Morse code requirement for all 
license classes, while approximately 30 percent asked the FCC to retain the 
requirement. Another 10 percent endorsed keeping the Morse code as a 
requirement to obtain an Amateur Extra class license. The ARRL random 
sampling was not scientific. By week's end, the number of comments filed had 
nearly doubled, with comments supporting removal of the Morse requirement 
continuing to predominate.

The comment period extends for many more weeks; an official comment deadline 
has not yet been established. The FCC then will consider all comments in 
developing a Report and Order (R&O) that spells out whatever new rules the 
FCC finally adopts and set an effective date. That's not expected to happen 
before year's end at the earliest.

A copy of the NPRM&O is on the FCC Web site 
<http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi? 
native_or_pdf=pdf&id_docume nt=6518023930 To file on-line comments in this 
proceeding, WT Docket
05-235, or to view others' comments, visit the FCC Electronic Comment Filing 
System (ECFS) site <http://www.fcc.gov/cgb/ecfs/ and click on "Submit a 
Filing" or "Search for Filed Comments."

In either case, type "05-235" in the "Proceeding" field. Be sure to include 
the hyphen--but not the quotation marks. Directions for filing comments, 
which can be in the form of an attached document, are on the ECFS site. 
Click on "Getting Started" to learn more.