[HCRA] NCVEC Files No-Code (No Morse Code) Petition with FCC
Steve Rodowicz
[email protected]
Thu, 31 Jul 2003 06:24:42 -0400
>The following is forwarded without comment by the sender.
>
>///////////////////////////////////////////////////////////////////////////=
///
>///////////////////////////////////////////////////////////////////////////=
///
>/////////////////////////////////////////
>
>From: <A=20
>HREF=3D"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=20
>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=20
>operator
>license testing and to electronically file all successful license=20
>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=
=20
>twenty
>years and have notified the FCC to issue approximately a million new and=20
>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=20
>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=20
>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=20
>of the
>rules governing the Amateur Radio Service, 47 C.F.R. 97.1 et seq., as set=
=20
>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=20
>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=
=20
>they
>have yet to develop a position on the matter. In support of its petition,=
=20
>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=20
>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=
=20
>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=20
>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=20
>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=20
>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=
=20
>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=20
>become
>inconsistent with the goals of the Amateur Service since it provides a=20
>barrier
>to otherwise qualified individuals who wish to experiment and communicate=
=20
>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=
=20
>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=20
>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=20
>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=20
>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=
=20
>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=
=20
>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=20
>Amateur
>Radio. No evidence exists, however, that supports a relationship between=
=20
>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=20
> 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=
=20
>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=
=20
>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=20
>properly.
> It is often disruptive and unsettling to those other examinees who are=20
> 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=20
>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=
=20
>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=20
>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=
=20
>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=
=20
>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=
=20
>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=20
>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=20
>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=
=20
>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)=20
>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,=
=20
>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=
=20
>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=
=20
>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=
=20
>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), =A9, (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=
=20
>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=20
>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 97.305=A9 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=20
>CW emission
>using the international Morse code or phone emissions J3E and R3E.
>
>
>
>3. Section 97.313 is amended by revising paragraph =A9(2) to read as=
follows:
>
>97.313 Transmitter power standards.
>
>(b) ******
>=A9 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;
>=A9 ******
>
>
>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 =A9 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) *******
>=A9 Each written question set administered to an examinee for an amateur
>operator license must be prepared, or obtained from a supplier, by the=20
>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=20
>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;=20
>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.,=20
>Sunnyvale, CA;
>W4VEC, High Point, NC; W5YI-VEC, Dallas, TX; Western Carolina Amateur=20
>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=20
>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,=
=20
>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=20
>decision,
>OFCOM said the temporary permission to use the HF bands would suffice=20
>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
>
>
>
>
>
>
>--- StripMime Report -- processed MIME parts ---
>multipart/alternative
> text/plain (text body -- kept)
> text/html
>The reason this message is shown is because the post was in HTML
>or had an attachment. Attachments are not allowed. To learn how
>to post in Plain-Text go to: http://www.expita.com/nomime.html ---
>Now, more than ever, QSL.NET is in urgent need of your financial support.
>
>Please help QSL.NET by sending a donation now.
>_______________________________________________
>ARES-RACES mailing list
>[email protected]
>http://mailman.qth.net/mailman/listinfo/ares-races