[FLham] ARRL Reply to Restructure NPRM

[Radioguy]

Meaningful Entry-Level License Privileges are Top Priority, ARRL Says

NEWINGTON, CT, Nov 1, 2005--The ARRL again has urged the FCC to 
provide meaningful operating privileges to entry-level Amateur Radio 
licensees, including access to HF, even if it doesn't want to create 
a new license class. Commenting in response to the FCC's July 9 
Notice of Proposed Rule Making and Order (NPRM&O) in WT Docket 
05-235, the League also stood by its stance that the Commission 
retain the 5 WPM Morse code requirement for Amateur Extra applicants, 
but do away with it for General applicants.

"Retaining Morse telegraphy as a requirement for only the Amateur 
Extra class license, in ARRL's view, places Morse telegraphy in a 
proper, balanced perspective," the League told the Commission October 
31, the deadline to comment in the proceeding. Reply comments are due 
November 14.

The FCC's NPRM&O proposed eliminating the 5 WPM Morse code 
requirement for all Amateur Radio license classes but denied requests 
to create a new entry-level license class with limited HF privileges. 
The League said the FCC needs to finish the job of license 
restructuring it began in 1998 by reviewing operating privileges for 
all classes--especially at the first rung of the licensing ladder.

"The elimination of Morse telegraphy, absent a more thorough review 
of operating privileges in the Amateur Service, will not address the 
ascertained flaws in the only entry-level license class," the ARRL 
asserted, referring to the Technician license. "That license class is 
not attracting or keeping newcomers in its present configuration, and 
it needs fixing right now."

The ARRL argued that if the FCC will not create a new Novice class 
license as the League had suggested in its earlier Petition for Rule 
Making (RM-10867) in the proceeding, it should modify Technician 
operating privileges instead. The present licensing regime limits 
Technicians to VHF bands and above, "leaving newcomers to the Amateur 
Service isolated from their peers holding higher class licenses," the 
ARRL said. "The Technician class is, for too many, a 'dead end' to 
what might otherwise be an active, progressive interest in Amateur 
Radio, technical self-training and incentive-based educational 
progress in the many facets of the avocation."

The ARRL reminded the FCC that its restructuring plan enjoyed the 
support the two Amateur Radio licensees in Congress--Rep Greg Walden, 
W7EQI (R-OR) and Rep Mike Ross, WD5DVR (D-AR).

Eliminating the Morse requirement for General class applicants 
"creates an anomaly with respect to the Technician class license," 
the ARRL noted. "If the telegraphy requirement for the General class 
license is eliminated, the distinction between the Technician class 
licensee and the Technician Plus class licensee will have disappeared 
completely." Therefore, the League contends, there is a logical basis 
for affording Technician licensees entry-level HF privileges.

Those privileges would be very basic under the League's plan, which 
takes into account the FCC's proposal to adopt the ARRL's so-called 
"Novice refarming" plan in WT Docket 04-140. The ARRL had earlier 
proposed the same privileges for a reconstituted Novice license.

Under the ARRL plan, Technicians would have telegraphy and data 
privileges on 3.55-3.7 MHz, 7.05-7.125 MHz and 21.05-21.20 MHz at 100 
W output and on 28.05-28.3 MHz at 50 W output. The League wants the 
FCC to provide HF phone and image privileges to Technicians on 
3.9-4.0 MHz, 7.2-7.3 MHz and 21.35-21.45 MHz at 100 W output, and on 
28.3-28.5 MHz at 50 W.

The time is right to take a look at the operating privileges of 
Amateur Radio license classes, the ARRL said in its filing, "because 
the entry-level license class is demonstrably neither attractive to 
newcomers nor encouraging in terms of retaining the interest of 
license holders."

To back up its assertions, the League pointed to surveys it conducted 
in 1992 and 2003. Nearly half of the licensees responding in the 
latter poll indicated that they were not currently active in Amateur 
Radio--up 30 percent from the earlier survey. "The number of inactive 
Technician class licensees is 46 percent," the ARRL noted, adding 
that more than a quarter of Technicians responding in 2003 said 
they'd never even been on the air.

The League pointed out that the FCC's proposed across-the-board 
elimination of the Morse requirement eliminates a simple mechanism 
for current Technician licensees to obtain HF operating 
privileges--passing the 5 WPM code exam.

If the FCC does nothing other than eliminate the Morse requirement 
for the General license, the ARRL commented, it would make no sense 
to continue to deprive Technician licensees the HF operating 
privileges that Tech Plus licensees now enjoy.

"To do otherwise is to draw a distinction that is entirely 
arbitrary," the League concluded.