"Phil Kane" wrote in message
.net...

Don't get me wrong, Cecil - you read my input to the Restructuring
Docket and you know that I was in favor of eliminating the code test.

begin quote

COMMENTS SUBMITTED BY PHILIP M. KANE

MANUAL MORSE CODE TESTING

13. From the inception of both commercial (marine) and amateur radio
in the early years of this century, Manual Morse Code was the first and
"simplest" method of communication, requiring operators trained and
experienced in the use of this mode at all points in the circuit. At the
time, equipment used by all services was rather crude, and in some cases
the amateur service shared large amounts of spectrum with the governmental
and private commercial services. It was essential that the amateur
operator be qualified in Manual Morse Code in order to recognize signals
from other stations with higher priority informing the amateur operator of
technical interference and in some cases exercising authority to order the
amateur operator to stop communicating.

14. At the present stage in the development of communications, those
early-year requirements no longer are valid and Manual Morse Code is
considered an obsolete method of communication. Amateur operators are no
longer advised of problems "on the air" by governmental and commercial
operators, and indeed the amateur radio service is the only such service
still using Manual Morse Code for communications.

15. The United States is a signatory on the International Radio
Regulations ("IRR") of the International Telecommunications Union ("ITU")
which still specifies that each Administration require proof of proficiency
in receiving by ear and sending by hand of Manual Morse Code for amateur
operators using portions of the spectrum below 30 MHz. The IRR does not
specify any particular speed for such certification, and indeed, one major
Administration (Japan) has been issuing amateur radio licenses in
derogation of this regulation (by the "exception" process).

16. It is expected that a proposal will be made to eliminate this
requirement at an ITU World Radiocommunications Conference to be held
within the next few years. This commenter urges the Commission to take a
leadership position among the ITU member Administrations to eliminate this
requirement as no longer necessary.

17. Additionally, this commenter urges the Commission to eliminate
all such code testing requirements at the earliest opportunity, by the
"exception" method if feasible, and if not feasible, in the interim to
require testing in Manual Morse Code to be at a speed of no greater than
five (5) words per minute.

end quote

The FCC must have agreed, they changed all code test to 5 wpm.


Just not for the reasons that you are proffering.

If your reason is because it is "unnecessary",
I agree, it is unnecessary [arbitrary, not in conformity with
5 USC 706(2)(A)].

Ok, we agree on the decision, now who gets writes the majority opinion?

I do like that "exception" thing. Dam, did I take a lot of flake
for proposing that to the NCI board.

La.rry....