[HCRA] NCVEC Files No-Code (No Morse Code) Petition with FCC
Rick Lindquist, N1RL
[email protected]
Thu, 31 Jul 2003 23:29:12 -0400
Please note that while the NCVEC petition (below) has been filed with
the FCC, it must first be put on "public notice" and given a rule making
(RM) number before the FCC will accept your comments on it.
Do not waste your own time or the FCC's by attempting to comment on this
petition or any of the others (there will be more than one) before the
FCC puts them on public notice. ARRL will announce when that happens and
inform you how to post comments--most easily done via the Electronic
Comment Filing System (ECFS) <http://www.fcc.gov/cgb/ecfs/>.
We're still a long way from writing the obituary for CW, and, besides,
there's no *real* reason why CW should disappear from the ham bands even
if the requirement to pass a very minimal 5 WPM examination element goes
away. Just ask any CW contesters if they're planning to switch modes in
the absence of a Morse requirement. They'll probably just laugh at you.
Thanks!
73, Rick N1RL
-----Original Message-----
From: [email protected] [mailto:[email protected]] On
Behalf Of Daniel Sullivan
Sent: Thursday, July 31, 2003 7:33 AM
To: [email protected]
Cc: [email protected]; [email protected]
Subject: Re: [HCRA] NCVEC Files No-Code (No Morse Code) Petition with
FCC
______________________________________________
-------Hampden County Radio Association-------
-----------e-mail list (reflector)-------------
______________________________________________
Obituaries:
Morse Code 18?? - 2003.
Morse or as his friends called him CW was a good friend for many years.
His
father Samuel and mother Continental were well known to telegraphers the
nation over. From his young days on 200m CW was always one of the most
unique conversationalists around. His finest hour in his young life came
on
a cold day in April where he, and he alone, passed word of the sinking
of
the great liner Titanic. Although others would try and take credit, it
was
only through CW's ability to communicate effectively under all
conditions
that the world learned the fate of the doomed liner.
Through two world wars his service saved thousands of lives and passed
messages that effected the fate of the world. He would become the basis
for
his best friend Rtty and, although they later fell out, the older
generaltion of the Digital Revolution Gang. As his age grew he was found
to
be less and less useful and more controversial in his stand against such
questionable criticas as the modulation sisters Amplitude and Frequency,
the
Digital Revolution gang, and that great Greek himself Telly Vision. Once
it
became clear that his days were numbered regardless of what he had done,
CW
was put out to pasture and set on his way.Memorial Services will be held
from 0500z to 1100z and again between 1430z to 2300z daily on:
1818
3530
7030
14030
21030
28030
50030
Donations may be sent to the IARU so they can buy the rest of 40m for
us.
.- .- .---- - . -..-. -.-. .-- --.- .-. - --... ...-- -- --- .-. ... .
...-.-
----Original Message Follows----
From: Steve Rodowicz <[email protected]>
To: HCRA <[email protected]>
Subject: [HCRA] NCVEC Files No-Code (No Morse Code) Petition with FCC
Date: Thu, 31 Jul 2003 06:24:42 -0400
______________________________________________
-------Hampden County Radio Association-------
-----------e-mail list (reflector)-------------
______________________________________________
>The following is forwarded without comment by the sender.
>
>///////////////////////////////////////////////////////////////////////
///////
>///////////////////////////////////////////////////////////////////////
///////
>/////////////////////////////////////////
>
>From: <A
>HREF="http://www.qrz.com/index.html">http://www.qrz.com/index.html</A>
>
>The attached Petition for Rulemaking (dated July 29.2003) has been
filed by
>the National Conference of VECs with the Secretary, FCC, Washington DC.
It
>requests an immediate end of Morse code testing.
>
>73/Fred/W5YI, Chairman
>NCVEC Rules Committee
>
>
>Before the
>FEDERAL COMMUNICATIONS COMMISSION
>Washington, DC 20554
>
>RM.-
>In the Matter of Amendment of Part 97 of the Commission's Amateur
Service
>Rules to Eliminate Morse code testing
>
>To: The Commission
>
>
>PETITION FOR RULE MAKING
>
>The National Conference of Volunteer Examiner Coordinators (NCVEC) is
the
>umbrella organization comprised of the fourteen organizations charged
since
>1984,
>under Section 97.519(a) of the rules of the Federal Communications
>Commission, 47 CFR 97.519(a) to develop and administer all Amateur
Radio
>operator
>license testing and to electronically file all successful license
>applications with
>the FCC. In total, the VECs and their more than 30,000 VEL teams have
>collectively administered nearly two million examinations during the
past
>twenty
>years and have notified the FCC to issue approximately a million new
and
>upgraded
>Amateur Radio licenses.
>
>Once a year, the various Volunteer Examiner Coordinator organizations
meet
>at
>their annual conference to discuss the various issues that impact
Amateur
>Radio operator testing. At their July 25, 2003, meeting held with the
FCC
>in
>Gettysburg, PA, the VECs overwhelmingly agreed that Morse code testing
>should be
>immediately ended since it was now possible to do so. It was also
noted
>that
>countries have already begun discontinuing Morse examinations. As a
result
>the VECs voted to file this Petition asking that the FCC take expedited
>action
>to allow them to discontinue administering Element 1, the 5
>words-per-minute
>telegraphy examination as soon as possible.
>
>Pursuant to Section 1.405 of the Commission's procedural rules (47
C.F.R.
>1.405), the NCVEC hereby respectfully requests that the Commission
issue a
>Notice of Proposed Rule Making at an early date looking toward
amendment of
>the
>rules governing the Amateur Radio Service, 47 C.F.R. 97.1 et seq., as
set
>forth
>herein and in the attached Appendix.
>
>The rule changes requested herein would terminate the telegraphy
>examination
>requirement and permit existing Technician Class operators to access HF
>spectrum as provided in 47 C.F.R. 97.301(e) without the necessity of
>passing a
>Morse code examination. This request to eliminate the Morse code
(Element
>1)
>examination does not necessarily have the support of the ARRL Board
since
>they
>have yet to develop a position on the matter. In support of its
petition,
>NCVEC
>states as follows:
>
>I. Introduction and Background
>
>Since the turn of the century, the Morse code, invented by American
Samuel
>Morse and first used in 1844, has been the foundation of early distress
and
>safety communications. Although Morse code (or CW, as it is commonly
>called) was
>the primary mode of communications from the late 19th Century through
the
>early 20th Century, it has all but become obsolete in practically all
other
>contemporary communication systems. Due to the emergence of satellite
and
>digital
>communications, manual telegraphy is no longer used or required in any
>radio
>service other than in the Amateur Service.
>
>Radiotelegraphy in the maritime service has been phased out in favor of
>modern technology. The last vestige of manual telegraphy began being
>phased out in
>the maritime service in 1988 when the International Maritime
Organization
>adopted the Global Maritime Distress and Safety System (GMDSS).
>
>In the 1990's, countries around the world began closing down their
distress
>500 kHz calling frequency watch which had been in use since 1912. The
>final
>500 kHz message sent by the US Coast Guard took place from station NMN
>(Chesapeake Virginia) on April 1, 1995, and they no longer monitor the
>frequency.
>
>Even though the commercial world eliminated Morse code as a
communications
>medium many years ago, it has continued on the Amateur bands because
manual
>Morse proficiency was an international Amateur Service requirement when
>operating
>on spectrum under 30 MHz.
>
>
>
>II. Telegraphy requirement in the Amateur Service
>
>There are many communications modes and emissions available to the
radio
>amateur and manual CW is just another one that certainly deserves no
>special
>priority. The amateur radio operator examination process does not
require
>a
>practical demonstration in the ability to use any other mode - even
though
>more than
>a thousand modes and emissions are available to the Amateur Service.
>
>The international law previously required unspecified proficiency in
the
>International Morse code when the operation takes place in the medium
or
>high
>frequency bands. Because of technological advances, this regulation
has
>become
>inconsistent with the goals of the Amateur Service since it provides a
>barrier
>to otherwise qualified individuals who wish to experiment and
communicate
>below
>30 MHz. There can be no doubt that the Morse code proficiency
requirements
>have constituted an unnecessary and artificial impediment to fuller use
of
>the
>Amateur Radio Service for many potential and existing amateurs.
>
>It appears that the reason that many (no-code) Technician amateurs are
not
>upgrading to license classes that require telegraphy suggests that the
>Morse
>code requirement may be a significant barrier.
>
>III. Morse code testing is a burden to the applicant
>
>It should be noted that while today's personal computers can easily
send
>and
>receive telegraphy, the international Morse code "sent by hand and
received
>by
>ear" requirement continued as a worldwide fundamental requirement for
an
>amateur operator license until the recent actions by the International
>Telecommunications Union.
>
>The taking of the telegraphy examination is an unnecessary burden upon
the
>applicant. Experience has shown that it is more often than not a very
>stressful
>experience for the examine With the elimination of the international
>requirement for skill in manual telegraphy, there is no longer any
>reasonable
>justification for requiring an applicant to demonstrate this antiquated
>skill.
>
>It is one that must be acquired through rote memorization of the
character
>meanings of some 43 combinations of audible dots and dashes: 26
letters of
>the
>alphabet, numerals 0 through 9, four punctuation marks and three
characters
>unique to CW. This must be followed by numerous practice sessions
until
>the
>necessary skill is achieved. Most applicants, once they pass the code
>exam,
>never use the mode on the amateur airwaves. And many, perhaps most,
could
>not
>pass it again if required to do so.
>
>While it continues to serve some amateur operators well, as it did in
the
>early days of radio, it is now but one of many modes available to
amateur
>operators. The lack of interest in CW has turned many prospective
amateur
>operators
>away from the Amateur Service.
>
>IV. Morse proficiency is not an indication of a quality operator
>
>Some amateurs believe that the effort and sacrifice needed to learn
Morse
>code indicates a more dedicated and, therefore, a better candidate for
>Amateur
>Radio. No evidence exists, however, that supports a relationship
between
>manual
>telegraphy proficiency and the quality, desirability or motivation of
the
>operator.
>
>What the Morse code licensing requirement does do, however, is to
greatly
>reduce the number of applicants operating in the medium and high
>frequencies.
> Many people question why an individual with vast knowledge in the
>electronics
>field should be excluded from operating on HF spectrum due to a
personal
>disinterest in the Morse code.
>
>Continuing the use of Morse code proficiency as a means with which to
gauge
>"quality" or to limit the number of amateur radio operators accessing
>public
>spectrum is certainly at odds with the FCC's mandate to promote the
wider
>use of
>radio and its commitment to the use of emerging technologies.
>
>V. Morse proficiency should not be required to operate in the voice
mode
>
>It appears that most amateurs want to communicate in the voice mode.
It
>makes no sense from a regulatory perspective to require radio amateurs
to
>be Morse
>proficient when the greater majority of radio amateurs do not desire to
use
>that mode and there is no regulatory reason for them to do so.
>
>The future of Amateur Radio encompasses many modes undreamed of just a
few
>years ago. Although manual telegraphy is a noble part of the Amateur
>Radio's
>past, it is no longer the prime emission mode.
>
>In short, the Commission should ensure that the amateur examination
>elements
>are appropriate for the types of operation that will be performed by
the
>licensee.
>
>VI. An unnecessary burden upon the VEC system
>
>The administration of a CW examination imposes an unnecessary burden
upon
>the
>VE teams who must prepare and administer the CW examinations. It
requires
>extensive preparation and special equipment to prepare and administer
>properly.
> It is often disruptive and unsettling to those other examinees who
are
>taking
>one of the written examinations within the same room.
>
>Under 97.507(d), the VEs must prepare and record a series of messages
>sufficient to preclude any one message from becoming known to the
>examinees. Each
>message must contain every one of the 43 telegraphy characters at least
>once
>during period of at least 5 minutes. At the prescribed speed of 5
words
>per
>minute, and at the prescribed 5 characters per word, the message is
little
>more
>than 25 words in length. In practice, it is a difficult task to
compose a
>realistic
>message under these limitations. It is also an unnecessary burden upon
the
>coordinating VECs since most of them also prepare telegraphy
examinations
>for
>their VE teams.
>
>VII. An unnecessary burden upon the amateur service community
>
>The amateur service community suffers from the loss to its ranks of a
large
>number of potentially excellent operators who are turned away because
of
>the CW
>requirement. Either because of lack of the requisite aptitude for
sending
>and receiving CW or because of an unwillingness to spend the time
acquiring
>a
>skill for which they find of no value to them, they forego becoming
amateur
>operators.
>
>VIII. An unnecessary burden upon the FCC
>
>Now that the international (treaty) Morse code requirement is optional,
the
>FCC can expect to receive numerous requests for waivers of the Morse
code
>examination due to applicant hearing and other medical conditions in
order
>to be
>compliant with the Americans with Disabilities Act (ADA).
>
>When there were multiple code tests, the FCC cited the international
>(treaty)
>requirement, as the reason that the five word-per-minute code test
could
>not
>be waived. This case no longer applies and the FCC will have to
develop
>procedures to guide both themselves and the VECs/VEs in handling
requests
>for code
>exam waivers that are certain to come.
>
>Dealing with requests for a waiver of the code exam could create an
>unnecessary burden on the FCC and VECs/VEs and consume an excessive
amount
>of time and
>resources. It seems illogical to require all amateur examinees to pass
a
>requirement that could be waived by the actions of a physician.
History
>has shown
>that physician-initiated waiver requests have been very controversial
in
>the
>Amateur Service.
>
>IX. World Administrative Radio Conference 2003
>
>The only changes made to the international Amateur Service regulations
over
>the last 75 years concern the frequency above which amateurs may
operate
>without Morse testing. At their Washington, DC conference in 1927, the
ITU
>(then
>called the International Telegraph Union) allocated frequency bands to
the
>various radio services and established operating guidelines and
operator
>qualifications. It was deemed important that Amateurs prove an ability
to
>transmit and
>receive communications in Morse signals since, at the time,
radiotelegraphy
>was the primary means of long range communication.
>
>Since then, the administrations comprising International
Telecommunication
>Union have reviewed and voted to relax the Amateur Service's mandatory
>Morse
>proficiency requirement at every international conference capable of
doing
>so.
>
>In 1947 (Atlantic City), the ITU agreed that Morse proficiency should
only
>be
>required when the operation took place on frequencies below 1000 MHz (1
>GHz).
> At WARC-59, the 1959 World Administrative Radio Conference, this
level
>dropped to 144 MHz. A further reduction was made at WARC-79 to 30 MHz.
>Consequently, up until recently, Article S25.5 3 read: 25.5 3. 1)
Any
>person
>seeking a license to operate the apparatus of an amateur station shall
>prove
>that he is able to send correctly by hand and to receive correctly by
ear,
>texts
>in Morse code signals. The administrations concerned may, however,
waive
>this requirement in the case of stations making use exclusively of
>frequencies above 30 MHz.
>
>At WRC-2003, the international Radio Regulation Article S25.5 3 was
revised
>to make the Morse code testing requirement a matter for each licensing
>administration to decide for itself. Effective July 5, 2003, Article
S25.5
>3
>reads: 25.5 3. 1) Administrations shall determine whether or not
a
>person
>seeking a license to operate an amateur station shall demonstrate the
>ability
>to send and receive texts in Morse code signals.
>
>X. Summary of NCVEC proposal to end Morse testing
>
>The attached appendix contains a list of the rules that must be amended
if
>Morse code examinations are to be discontinued. These amendments
propose
>merely
>to end the manual telegraphy examination and to permit Technician Class
>operators the same frequency privileges as those enjoyed by Technician
>Class
>operators who have passed a code exam.
>
>Therefore, the foregoing considered, NCVEC, the National Conference of
>Volunteer Examiner Coordinators, respectfully requests that the
Commission
>issue a
>Notice of Proposed Rule Making at any early date, proposing the rule
>changes
>set forth herein, and in the appendix attached hereto.
>
>Respectfully submitted,
>
>NCVEC, National Conference of VECs
>P.O. Box 565101, Dallas, Texas 75356
>
>
>By:___
>Frederick O. Maia, W5YI, Chairman,
>NCVEC Rules Committee
>
>July 29, 2003
>
>-----------------------------------------------------------------------
-------
>------------
>
>
>
>-----------
>APPENDIX
>PROPOSED RULES
>
>Proposed changes to Part 97 of Chapter I of Title 47 of the Code of
Federal
>Regulations to delete references to the Morse code exam element. Part
97,
>is
>amended as follows:
>
>PART 97 -- AMATEUR RADIO SERVICE
>
>1. Section 97.301 is amended by revising paragraph (e) to read as
follows.
> The frequency tables in Section 97.301(a), (b), C, (d) and (e) remain
>unchanged.
>
>97.301 Authorized frequency bands.
>
>The following transmitting frequency bands are available to an amateur
>station located within 50 km of the Earth's surface, within the
specified
>ITU
>Region, and outside any area where the amateur service is regulated by
any
>authority
>other than the FCC.
>(d) ******
>(e) For a station having a control operator who has been granted an
>operator
>license of Novice Class, Technician Class or Technician Plus Class:
>
>
>Wavelength ITU Region 1 ITU Region 2 ITU Region
3
> Sharing requirements, see 97.303
>
>
>HF MHz MHz
MHz
> paragraph:
>
>80 m 3.675-3.725 3.675-3.725
>3.675-3.725 (a)
>40 m 7.050-7.075 7.10-7.15
>7.050-7.075 (a)
>15 m 21.10-21.20 21.10-21.20
>21.10-21.20
>10 m 28.1-28.5 28.1-28.5
>28.1-28.5
>
>VHF MHz MHz MHz
>1.25 m - - 222-225 -
-
> (a)
>
>UHF MHz MHz MHz
>23 cm 1270-1295 1270-1295 1270-1295
> (h)(i)
>
>
>2. Section 97.307 is amended by deleting paragraph (f)(9) and revising
>paragraph (f)(10) to read as follows. Previous 97.307(f)(10) is
renumbered
>to
>(f)(9). Paragraphs (f)(11) to (f)(13) are renumbered to (f)(10) to
>(f)(12).
>
>97.307 Emission standards.
>
>(f) The following standards and limitations apply to transmissions on
the
>frequencies specified in 97.305C of this part.
>(10) A station having a control operator holding a Novice Class,
>Technician Class or Technician Plus operator license may only transmit
a CW
>emission
>using the international Morse code or phone emissions J3E and R3E.
>
>
>
>3. Section 97.313 is amended by revising paragraph C(2) to read as
>follows:
>
>97.313 Transmitter power standards.
>
>(b) ******
>C No station may transmit with a transmitter power exceeding 200 W PEP
on:
>(1) ******
>(2) The 28.1-28.5 MHz segment when the control operator is a Novice
Class
>operator, a Technician Class operator or a Technician Plus Class; or
>(3) ******
>
>
>4. Section 97.501 is amended by revising paragraph (a) and (b) to read
as
>follows.
>
>97.501 Qualifying for an amateur operator license.
>
>Each applicant must pass an examination for a new amateur operator
license
>grant and for each change in operator class. Each applicant for the
class
>of
>operator license grant specified below must pass, or otherwise receive
>examination credit for, the following examination elements:
>(a) Amateur Extra Class operator: Elements 2, 3, and 4;
>(b) General Class operator: Elements 2, and 3;
>C ******
>
>
>5. Section 97.503 is amended by deleting paragraph (a).
>
>97.503 Element standards.
>
>(b) ******
>
>
>6. Section 97.505 is amended by revising paragraph (a)(1), (a)(2), and
>(a)(3) to read as follows.
>Paragraphs (a)(5), (a)(7), and (a)(9) are deleted.
>
>97.505 Element credit.
>
>(a) The administering VEs must give credit as specified below to an
>examinee
>holding any of the following license grants or license documents:
>(1) An unexpired (or expired but within the grace period for renewal)
>FCC-granted Advanced Class operator license grant: Elements 2 and 3.
>(2) An unexpired (or expired but within the grace period for renewal)
>FCC-granted General Class operator license grant: Elements 2 and 3.
>(3) An unexpired (or expired but within the grace period for renewal)
>FCC-granted Technician Plus Class operator license grant: Element 2
>(4) ******
>(6) ******
>(8) ******
>(b) ******
>
>
>
>7. Section 97.507 is amended by revising paragraph (a), (a)(2), and C
to
>read as follows. Paragraph (d) is deleted.
>
>97.507 Preparing an examination.
>
>(a) Each written question set administered to an examinee must be
prepared
>by
>a VE holding an Amateur Extra Class operator license. A written
question
>set
>may also be prepared for the following elements by a VE holding an
operator
>license of the class indicated:
>(1) ******
>(2) Element 2: Advanced, General, or Technician (including Technician
Plus)
>Class operators.
>(b) *******
>C Each written question set administered to an examinee for an amateur
>operator license must be prepared, or obtained from a supplier, by the
>administering
>VEs according to instructions from the coordinating VEC.
>
>
>8. Section 97.509 is amended by revising paragraph (f) to read as
follows.
> Paragraph (g) is deleted.
>
>97.509 Administering VE requirements.
>
>(e) ******
>(f) No examination that has been compromised shall be administered to
any
>examinee. The same question set may not be re-administered to the same
>examinee.
>(h) ******
>
>-------------------------------------------
>(1)
>The following organizations have entered into an agreement with the FCC
to
>coordinate Amateur Radio examinations: Anchorage Amateur Radio Club,
>Anchorage, AK; American Radio Relay League (ARRL), Newington, CT;
CAVEC,
>Inc., Huntsville, AL; Golden Empire Amateur Radio Society, Chico, CA;
>Greater L.A.
>Amateur Radio Group, North Hills, CA; Jefferson Amateur Radio Club, New
>Orleans, LA; Laurel Amateur Radio Club, Inc.; Laurel, MD; The Milwaukee
>Radio
>Amateurs' Club, Inc., Milwaukee, WI; MO-KAN VEC Coordinator, Richmond,
KS;
>Sandarc-VEC, La Mesa, CA; Sunnyvale VEC Amateur Radio Club, Inc.,
>Sunnyvale, CA;
>W4VEC, High Point, NC; W5YI-VEC, Dallas, TX; Western Carolina Amateur
Radio
>Society
>VEC, Inc., Knoxville, TN.
>
>The United Kingdom's Regulatory Authority published a "Gazette Notice"
on
>July 25, 2003, discontinuing all Morse code testing in their Amateur
>Service
>effective July 26, 2003. The effect was that all "Class B" (no code)
radio
>amateurs in Great Britain who previously were restricted to operation
above
>30 MHz
>obtained "Class A" access to all Amateur bands. This can be confirmed
at
>the
>Radio Society of Great Britain's website and/or the UK "Regulatory
>Authority"
>(their telecom regulator) website. In addition, effective July 15,
2003,
>radio
>amateurs in Switzerland were given immediate "provisional" authority to
>operate on the HF amateur bands by the Swiss Federal Office of
>Communications
>(OFCOM) while they await formal rulemaking. Citing the recent WRC-03
>decision,
>OFCOM said the temporary permission to use the HF bands would suffice
until
>the
>regulation could be changed. Many other countries are rumored to be in
the
>process of discontinuing Morse code testing.
>See 47 C.F.R. 503(a.)
>
>-----------------------------------------------------------------------
----
>Fred Lloyd, AA7BQ Founder, QRZ.COM
>
>///////////////////////////////////////////////////////////////////////
///////
>///////////////////////////////////////////////////////////////////////
//
> The preceding is forwarded without comment by the sender.
>
>Bill Lennox
>US Air Force (Retired)
>Full Time College Student (Emergency Management)
>KD7EFP
>Assistant Emergency Coordinator - Plans (ARES), Washington County,
Oregon
>Assistant Radio Officer - Plans (RACES), Washington County, Oregon
>
>
>
>
>
>
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