Andre Kesteloot andre.kesteloot at
Sat Nov 5 06:27:40 CST 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 the
Commission 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

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 of
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. 

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.

These recommended privileges take 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.

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.

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