[LeArc] FCC Invites Comments on Additional Morse Code-Related Petitions

[Duane Whittingham]

FCC Invites Comments on Additional Morse Code-Related Petitions
ARRL

http://www.arrl.org/news/stories/2003/10/08/1/?nc=1


NEWINGTON, CT, Oct 8, 2003--The FCC has sounded the bell to begin Round 2 of the Morse code issue by inviting public comment on another group of seven Morse-related petitions for rulemaking. The FCC put the petitions on public notice today. Comments will be due by November 7. As they did with the initial seven Morse-related petitions, members of the amateur community may make their opinions known on any or all of these filings using the FCC's Electronic Comment Filing System (ECFS).

The Petitions

Charles L. Young Jr, AG4YO, has asked the FCC to delete the 5 WPM Morse code test (Element 1) for Technician-plus-Element 1 privileges--formerly called "Tech Plus." Young's petition, designated RM-10805, would retain Element 1 as an examination requirement for General and Amateur Extra applicants. His proposal would give Technicians access to the top 50 kHz of the General-class HF bands on SSB at 100 W ERP, but no privileges on 60, 30 or 17 meters. In his petition, Young said he felt his approach "addresses the need for a no-code license class and offers the best compromises to preserve the traditions and needs of all amateurs."

In a three-page document that's more commentary than petition, Frank W. Napurano, K2OKA, describes CW as "the purest, most accurate, efficient, reliable and economical form of radio communications ever devised." The FCC designated Napurano's filing as RM-10806. Calling Morse code "an art form and a language," Napurano requests that the FCC retain the current 5 WPM Morse code licensing requirement "in the interest of public safety, the preservation of a radio art and as a tribute of support for a prized and respected avocation."

A 19-page petition filed by Robert G. Rightsell, AE4FA and Harry A.M. Kholer, N0PU, outlines a more complex plan. Designated RM-10807, it would continue Morse testing but give applicants up to 24 points of exam credit according to their success on Element 1. The final exam score would be the sum of earned Element 1 points and the written test score for a possible total of 100 points.

"Petitioners see a need for continued International Morse code testing but do not believe code testing should be the main determining factor," Rightsell and Kholer say in their filing. "Similarly, petitioners see a need for more comprehensive written examinations." They believe current question pools do not assess required knowledge of technical and regulatory issues "as thoroughly as in the past." RM-10807 also calls on the FCC to consolidate the Novice and Technician and the Advanced and Amateur Extra licenses, boost the number and range of written test questions and give new Technicians CW and data privileges on 80, 40, 15 and 10, with 100 kHz additional Tech spectrum on 80 and 10.

Joseph Speroni, AH0A, seeks to have the FCC delete Element 1 for applicants who want to operate phone on HF but retain Element 1 at 5 WPM for applicants who want to operate CW. "If we are to test for use of phone privileges, it seems reasonable to test CW skills if an applicant intends to operate that mode," Speroni said. His petition, designated RM-10808, would restructure the Amateur Radio testing regime to require specific knowledge of "RTTY, data, image, spread spectrum, pulse/test, RACES/ARES and space communications only for those wishing to operate these modes." Under Speroni's plan, applicants would be under no obligation to pass mode-specific examination elements for mode privileges they don't wish to operate.

Speroni also asks the FCC to open the gate to new Volunteer Examiner Coordinators (VECs) if the nation's current VECs cannot "handle the burden of examinations for mode privileges (one of which would be CW)."

"This petition is submitted as an alternate approach to that proposed by a recently filed NCVEC petition," Speroni said, in reference to the recent National Conference of Volunteer Examiner Coordinators' petition, RM-10787, which attracted more than 600 comments in Round 1. Among other things, the NCVEC had asked the FCC to delete Element 1 and give "Tech Plus" privileges to current Technician licensees (see "Hundreds Comment on Morse Petitions").

In its eight-page petition, the Puerto Rico Amateur Radio League (PRARL) asks the FCC to delete Element 1 for Technician and General classes but to also increase the rigor of the written elements for those two license classes. The PRARL would keep the 5 WPM Morse exam for Extra applicants.

"The knowledge of Morse code is needed in order to maintain a reliable emergency communications service during natural disasters and national emergencies," the PRARL said in its petition.

The PRARL also would require adequate monitoring and auditing of volunteer examiners (VEs), including periodic session audits by the VEC. It also wants the FCC to eliminate same-session retesting and require 30 days between retakes. The PRARL further calls on the FCC to require VECs to not accredit any volunteer examiner who has "ever been removed from service for any reason by any qualified VEC."

In a single-page filing, James Roux, W4YA, proposes that the FCC whittle down the number of license classes to two--General and Amateur Extra--and the number of written examination elements to one--at the General level. Roux's petition would eliminate the 5 WPM Morse code exam for General but require Extra applicants to pass a 15 WPM test.

Roux also would have the FCC eliminate all Advanced and Extra-class phone subbands and give Generals all currently available amateur privileges except the Extra-class CW subbands on 80, 40, 20 and 15 meters. He says his plan would mean less paperwork for the FCC and for VECS and would simplify the license structure. "The number of amateur licensees should grow, especially with the elimination of the Morse code requirement that has historically deterred many from obtaining a license," he concluded.

A 14-page petition filed on behalf of FISTS CW Club by Nancy A. Kott, WZ8C, the executive director of FISTS' North American chapter would delete the requirement to pass Element 1 to obtain Technician plus Element 1 (ie, "Tech Plus") HF privileges. Designated RM-10811, it would merge Tech and Tech Plus into a single class, emphasize technical content, including digital modes, on written examinations and extend digital mode privileges within Novice/Tech Plus subbands. It would not provide additional HF phone privileges for Technicians, however.

The FISTS petition would retain a 5 WPM Morse exam for General applicants and raise the Morse exam to 12 WPM for Amateur Extra applicants while increasing the technical level on written examinations for both classes.

"Morse code is relevant to Amateur Radio because it contributes not only to our frequency agility but also to our unique mode agility, a special ability our served agencies and the public fully appreciate," FISTS said in its filing. It said the surge in upgrades following the FCC's April 2000 restructuring indicates that 5 WPM is neither a hindrance to applicants nor an unreasonable burden on prospective licensees.

FISTS also wants the FCC to retain the Novice CW subbands for narrowband digital modes only--not voice/image modes--and end instant retesting on exams. Its petition further urges the FCC to reinstate its regulatory standards and syllabus of topics for each license class. RM-10811 already has gathered more than 50 comments.



How to Comment

Interested parties may file comments on any or all of these petitions using the FCC's Electronic Comment Filing System (ECFS), which also permits users to view all comments on file. There is a 30-day comment window.

To file a comment, click on "Submit a Filing" under "ECFS Main Links." In the "Proceeding" field, type the full RM number, including the hyphen, and complete the required fields. "RM" must be in capital letters, and you must include the hyphen between "RM" and the five-digit number. You may type your remarks into a form or attach a file. ECFS also accepts comments in active proceedings via e-mail, per instructions on the ECFS page.

To view any comments already submitted for each petition, click on "Search for Filed Comments" under "ECFS Main Links" and type in the complete RM number, including the hyphen, in the "Proceeding" field. "RM" must be in capital letters, and you must include the hyphen between "RM" and the five-digit number.

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