[HCRA] The Long Awaited Restructuring
Peter
[email protected]
Thu, 25 Mar 2004 23:56:46 -0500
Hi Everybody,
I got the bulletin ARLB007 yesterday via email. This is the long =
awaited restructuring plan that the ARRL has submitted to the FCC and =
they have finally attached a docket number to it: RM-10867. There is an =
explanation below about how to file comments on this docket using the =
FCC electronic comment filing system (ECFS). I have included in this =
email a copy of the ARLB007 and the comment which I filed this morning =
with the FCC. When I filed my comment there were only 12 comments =
showing up on the FCC database. Currently there are 194 records filed =
on that docket including the petition for rule making filed on behalf of =
the ARRL.
Please file a comment using the ECFS even if it is only a one liner =
saying that you agree or disagree with the ARRL petition. There have =
been several petitions for rule making centered on restructuring. The =
ARRL petition, in my humble opinion, is the most far reaching, well =
rounded, all inclusive, and most comprehensive of all that are on file =
thus far. I would encourage you to file comments either in agreement or =
against the petition. Your hobby is about to change drastically and =
fundamentally. Wouldn't you like to contribute to the process by making =
your views known to the FCC; the people who make the decisions. My =
estimate would be that comments are running about 10 to 1 in favor of =
the petition. Don't delay, file your comments soon.
73 De KI1I,
Peter
SB QST @ ARL $ARLB007
ARLB007 FCC invites comments on Amateur Radio restructuring plans
ZCZC AG07
QST de W1AW =20
ARRL Bulletin 7 ARLB007
>From ARRL Headquarters =20
Newington CT March 24, 2004
To all radio amateurs=20
SB QST ARL ARLB007
ARLB007 FCC invites comments on Amateur Radio restructuring plans
The FCC is seeking comment on three plans, one from the ARRL, that
would reshape the Amateur Service licensing structure. Each Petition
for Rule Making responds to World Radiocommunication Conference 2003
actions last summer that made changes to Article 25 of the
international Radio Regulations. While differing substantially in
some other aspects, the three petitions call for modifications at
Amateur Radio's entry level and for a three-tiered license system.
One petition goes beyond licensing structure to recommend additional
changes to amateur testing and HF digital privileges. A fourth
petition focuses solely on the Morse requirement. Comments are due
by April 24 on all four petitions.
Designated RM-10867, ARRL's petition asks the FCC to create a new
entry-level license class--being called ''Novice'' for now. It would
offer limited HF CW/data and phone/image privileges on 80, 40, 15
and 10 meters plus certain VHF and UHF privileges. The League plan
also would consolidate Technician, Tech Plus (Technician with
Element 1 credit) and General licensees into a new General license
that no longer would require a Morse examination. Current
Technicians automatically would gain General privileges without
additional testing. Applicants for Amateur Extra would still have to
pass a 5 WPM Morse code examination, but the General and Extra
written exams would stay the same.
A news report ''ARRL to Propose New Entry-Level License, Code-Free HF
Access,'' www.arrl.org/news/stories/2004/01/19/1/, has further
details. Frequently asked questions (FAQs) are addressed on the ARRL
Web site, www.arrl.org/news/restructuring2/faq.html.
An ''unincorporated grassroots organization,'' the Radio Amateur
Foundation (RAF), has filed a petition designated as RM-10868. Its
wide-ranging filing asks the FCC to modify the Technician ticket to
allow restricted HF phone, data, image and CW privileges. The group
also proposes retaining the 5 WPM Morse requirement for General and
Amateur Extra applicants, upgrading Advanced class holders to Extra
and all Novices to Technician. The Radio Amateur Foundation said it
sees no need to change licensing requirements for General or Amateur
Extra applicants.
The RAF also wants to scrap existing Amateur Radio question pools
and start over from scratch, keeping the question pools out of the
public domain and requiring a 10-day waiting period before
retesting. In addition, it would permit only Generals and Amateur
Extras or Technicians licensed more than two years to request vanity
call signs.
The RAF has further asked the FCC to permit digital experimentation
from 29.0 to 29.3 MHz at bandwidths of up to 15 kHz.
In his two-page petition designated RM-10869, Ronald D. Lowrance,
K4SX, calls on the FCC to retain the 5 WPM Morse code requirement
for General class applicants and to raise the Morse requirement to
13 WPM for Amateur Extra class applicants. He called Morse code ''the
most reliable mode of communication'' in an emergency. Lowrance would
make no change in Technician licensing requirements.
The National Conference of Volunteer Examiner Coordinators (NCVEC)
wants the FCC to establish a new entry-level license called the
Communicator class. Its petition, designated RM-10870, reiterates
its call--first made last fall in RM-10787--to altogether eliminate
the Morse code testing requirement.
The NCVEC's petition would upgrade all current Novices to
Communicator class. The NCVEC would further upgrade all existing
Technician and Tech Plus (Technician with Element 1 credit)
licensees to General and all Advanced class licensees to Amateur
Extra without further testing. Once the Morse requirement goes away,
NCVEC said in its filing, ''there will be no effective difference
between the Technician and General class licenses.''
The new Communicator ticket would permit a power limit of 100 W on
bands below 24 MHz and 50 W on all frequencies above 24 MHz.
Communicator licensees would have to use commercially manufactured
equipment (or gear built from a commercial kit). They could operate
both voice and digital modes on 80, 40, 15 and 10 meters plus VHF
and UHF up to 70 cm.
All three license restructuring plans call for changes to the
present HF subbands.
Interested parties may view and comment on these petitions via the
FCC Electronic Comment Filing System, www.fcc.gov/e-file/ecfs.html.
When entering the RM number in the ECFS ''Proceeding'' field, RM must
be in capital letters and the hyphen must be included.
NNNN
/EX
My Comments (KI1I) follows:
=
3/25/04
=20
I agree with the ARRL petition filed under RM-10867. It goes further =
than my proposal under RM-10781 and appears to address all of the legal =
issues as to the exact chapter and sections. It satisfies a major =
concern that I had that an entry level license contain HF operating =
privileges so as to expose that class of licensee to international =
communications and at the same time allow said licensee to participate =
in volunteer emergency communications services (both RACES and ARES).
=20
With regards to the 5WPM code requirement I can see both sides of the =
issue. I wonder how the FCC and/or any other organization would deal =
with the tangle of issues that would surely come as a result of the =
elimination of the international requirement for testing of Morse code =
proficiency relative to those applicants for [US] license who have =
debilitating conditions preventing them from demonstrating Morse code =
proficiency and how in the light of the Americans with Disabilities Act =
(ADA), said applicants would be directed, by whom, and what procedure. =
I can also see the viewpoint that keeping the testing for Morse code =
proficiency serves to make the licensing structure progressively more =
challenging and that it is still a viable mode for amateur =
communications. I think that the FCC commissioners will have to weigh =
these two issues out and determine which is more important: easy access =
to all or progressive license structure. =20
=20
Will the issuance of licenses independent of Morse code testing =
debilitate the licensee in any aspect of communications allowed by said =
licensee's privileges? In order for the license holder of any license =
to participate in Morse code communications it will require proficiency =
in that mode regardless of any disability. So the question becomes why =
test for proficiency when [proficiency] is required to operate in that =
mode effectively. Some may posture that not requiring testing of =
proficiency in operating Morse code would open the bands to all sorts of =
poorly trained and thus difficult to communicate with operators. This =
already happens even with testing. I can remember my first attempts to =
communicate in this mode. I think I attempted about four times before =
having a barely successful QSO in Morse code. Without Morse code =
proficiency people will try and become somewhat proficient before =
attempting to communicate in the mode and will or will not be successful =
on the first attempt. This will happen regardless of whether or not =
there is testing for proficiency. Therefore I don't think it really =
matters if the FCC keeps the requirement or not. Throwing out the =
requirement will surely solve the tangle that I spoke of above regarding =
the ADA compliance. =20
=20
The power limits proposed for the Novice class license would make it =
easy for the licensees of this proposed class [of license] to comply =
with the safe emissions requirements currently in place. Testing for =
this requirement would become unnecessary for this class of license =
because the requirements would already be met due to the power =
limitations proposed.
=20
Please adopt this proposal with the possible exception of Morse code =
proficiency test requirement for Extra class applicants as soon as =
possible. It will serve the United States aims for the Amateur Radio =
Service well into the future.
=20
Respectfully Submitted,
Peter M. Beauregard
ARS KI1I
Lifetime ARRL Member
Active Ham Radio Operator
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