(N2EY) wrote in message ...
In article , "Bill Sohl"
writes:

"N2EY" wrote in message
...
PETITION FOR RULE MAKING

The National Conference of Volunteer Examiner Coordinators (NCVEC) is
the umbrella organization comprised of the fourteen organizations
charged 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 operator license testing and to electronically file
all successful license applications with the FCC. In total, the VECs
and their more than 30,000 VE teams have collectively administered
nearly two million examinations during the past twenty years and have
notified the FCC to issue approximately a million new and upgraded
Amateur Radio licenses.

The NCVEC is not, however, an organization where the VECs are elected, or
where
individual VE opinions were gathered or solicited.

So? Your point? Is that something that should call into question
the NCVEC as being invalid, illegal, or fattening?

The point is that the petition is NOT necessarily the opinion of the majority
of VEs or VECs. It was cooked up by a few of the top guys, who were not
elected.

Oh Geez. Not the same unelected, non-FCC guys that unilaterally
decided to jettison the 5wpm Morse Exam for the 13-15wpm Farnsworth
Exam, and deny HF access to otherwise qualified people who just can't
beep fast?

Come to think of it, I'm trying to remember the last time I voted for
the top few guys at the ARRL.

bb

"N2EY" wrote in message
...
In article , "Bill Sohl"
writes:

"N2EY" wrote in message
...
PETITION FOR RULE MAKING

The National Conference of Volunteer Examiner Coordinators (NCVEC) is
the umbrella organization comprised of the fourteen organizations
charged 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 operator license testing and to electronically file
all successful license applications with the FCC. In total, the VECs
and their more than 30,000 VE teams have collectively administered
nearly two million examinations during the past twenty years and have
notified the FCC to issue approximately a million new and upgraded
Amateur Radio licenses.

The NCVEC is not, however, an organization where the VECs are elected,
or
where
individual VE opinions were gathered or solicited.

So? Your point? Is that something that should call into question
the NCVEC as being invalid, illegal, or fattening?

The point is that the petition is NOT necessarily the opinion of the
majority
of VEs or VECs. It was cooked up by a few of the top guys, who were not
elected.

"cooked up" sure smacks of a negative spin. Regardless,
I don't recall the petition claiming to represent a majority opinion
based on any elections, survey, etc. More to the issue, those
that do gather at the annual NCVEC session DO represent
a significant participation and commitment to amateur radio...
of which, I suspect, the FCC is fully aware of.

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 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 action to allow them
to discontinue administering Element 1, the 5 words-per-minute
telegraphy examination as soon as possible.

No surprise there.

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 of the rules governing the Amateur Radio
Service, 47 C.F.R. 97.1 et seq., as set forth herein and in the
attached Appendix.

No imagination, either.

When does imagination or, for that matter, creativity have to be part
of the filling/process?

When someone truly has the interests of the ARS in mind, they will look at
the
complete picture rather than take a narrow view. This is particularly
important
in dealing with FCC because we have seen how long it takes them to do an
amateur service NPRM cycle.

The NCVEC filing seems to be right on target with regard to dropping
morse testing now that the treaty has ended any mandatory need for same.
Great Britain, Belgium, Germany, Switzerland have already taken the same
route.

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 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 they have yet to develop a
position on the matter. In support of its petition, 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 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 digital communications, manual
telegraphy is no longer used or required in any radio service other
than in the Amateur Service.

Amateur radio operators, however, use it extensively. On the HF/MF
amateur
bands, it is the second most popular mode of communications, only
slightly
behind SSB in popularity.

So?

So it makes sense that the things that should be tested for an amateur
radio
license should be derived from what hams actually do, rather than what
other
services do. Would you support questions on multiplex stereo FM on the ham
test? That mode is widely used in the broadcast service.

I support "questions" about morse on the tests. That is not, however,
the same as supporting a mandated "skill" test for character recognition
ability.

Hams also use differnent languages (Engish, Spanish, Chineese, etc.)
yet no one is mandated to use or be tested in any language other than
that of their "home" country.

How many US hams regularly use a language other than English on the ham
bands?
Betcha it's far, far below the number using Morse/CW.

The point is that morse is a character set, and the test is a skill
test based on speed of ability, not simple knowledge on a par
with written test questions.

The Amateur Radio Service is unlike other radio services in its needs
and
resources.

So are you sying amateur radio "needs" morse code testing? If so,
the burden of proof hasn't been met as per FCC R&O for 98-143.

All I'm saying is that comparisons with other services are meaningless
because the ARS is completely different.

Yet comparing it to the other service's need for a pool of
trained morse users was appropriate when it served the
purpose of arguing for morse testing. How convenient :-)

Radiotelegraphy in the maritime service has been phased out in favor
of
modern technology. The last vestige of manual telegraphy began being
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 U.S. Coast Guard took
place from station NMN (Chesapeake Virginia) on April 1, 1995, and
they
no longer monitor the frequency.

Most radio amateurs are not on ships.

So the validity of having a trained morse pool even 20 years ago
wasn't or shouldn't have been because other services used morse.

The validity of the "trained pool" argument depends on what you mean by
"trained". There's a lot more to it than a 5 wpm code test.

As above, how convenient :-) :-)

Interesting, did you make that comment when no-code was first proposed?

When was that? 1975?

I don't recall. I defer to your historic knowledge on that :-)

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 operating on spectrum under 30 MHz.

There is no requirement that any radio amateur actually use Morse code.
Radio amateurs use it by choice.

The statement isn't one of USE, it is based on a prior
international requirement...now gone, dead, caput, finito, over.

The NCVEC statement does indeed say that the USE of Morse has continued
because
of the TEST. It gives no other reason.

Here's the statement again:

"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
operating on spectrum under 30 MHz."

The word "it" refers to "Morse code as a communications medium" in the
above
sentence. NCVEC is saying that hams continue to USE Morse because of the
TEST.

That's just plain not true.

Fair enough..but I doubt the NCVEC intended to rule out ALL other reasons
that morse continues to be used by hams other than the test.

Other services are constrained by considerations of cost, particularly
labor cost. They consider elimination of the need for a skilled radio
operator to be progress. Amateurs do not.

You speak for "all" amateurs?

Yes. Do you think hams want to be eliminated?

I didn't see that as your point.

Perhaps you should have said "some"
amateurs.

Perhaps there are a few who want to be eliminated, but not many.

The point is that for other services radio is a means to an end. To hams
it's an end in itself.

Yet hams will be free to USE morse even if there's no test.

In any case, learning morse does have a cost to each
and every amateur that does so. I see no reason to "mandate"
that cost upfront for access to amateur radio.

Your opinion, very reasonably stated and noted.

Thanks.

To most other radio services, radio is but a means to an end, not an
end
in itself. Amateur radio, by contrast, is radio for its own sake.

So?

So amateur radio should not be judged nor structured the way other
services are.

Fair enough, although doing so doesn't (IMHO) add or detract
from the need for code testing.

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 more than a thousand modes and emissions are
available to the Amateur Service.

Except for single sideband radiotelphony, none of those other modes
approaches
Morse code in popularity on the amateur bands below 30 MHz.

The point still comes back to the fact that NO other mode
requires any skill test. It is that simple.

No other mode requires the acquisition of skills the average person is not
likely to have in order to use it.

So? In a nocode license world, those that want to use
morse will learn it. Are you worried about new hams operating
at 2 or 3 wpm on the air? Or would you encourage those
to get on the air and learn morse?

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 become inconsistent with the goals of the Amateur
Service since it provides a barrier to otherwise qualified
individuals
who wish to experiment and communicate 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 the Amateur
Radio Service for many potential and existing amateurs.

The removal of the code test requirement for amateur licenses above 30
MHz
has not resulted in a technological revolution in amateur radio on
those
frequencies. There is no reason to expect one below 30 MHz.

I never bought any great significance to that argument either.

Yet it has been made repeatedly in the past, and is made several times in
the
NCVEC petition. What does it matter if someone is a Ph.D in EE, has a
bunch of
patents, etc., etc., if all they're going to do as a ham is work SSB DX
with a
manufactured transceiver and antenna?

I repeat: I never bought that argument.

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 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 stressful experience for the examinee. 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 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 not pass it again if
required to do so.

Written tests are a burden to the applicants, too.

Are YOU proposing an end to written tests?

Nope. Just the opposite.

Good, wouldn't want some people to get the wrong idea.

Most radio amateurs do not construct or repair their own equipment, yet
they
are required to know something about how it works.

Because they "can" if they wanted to.

BINGO!

So since a ham can operate Morse if he/she wants to,
why is it unreasonable to have a basic Morse test?

Because it isn't needed for regulatory purposes.

There are probably far more US hams using Morse today
(by choice) than there are US hams today using
homebrew stations (by choice).

Because not having a test won't lead to any problems
if hams start out "learnin' on the air" using morse at
speeds we/you miht think of as painfully slow.
Even the ITU never spec'd a minimum speed.

Of course there are some like me who
use Morse with a homebrew station...

Personal choice, works for me.

If a non-coded ham gets
on the air to learn using morse with another ham...what's the probably
harm to others and or anyone compared to constructing or repairing
equipment themselves?

Depends on the situation. I can tell you, however, that the knoweldge
required
to pass all of the writtens is only a small subset of that needed to
homebrew
even a simple amateur station.

Agreed.

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 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 Amateur Radio. No evidence exists, however, that
supports a relationship between manual telegraphy proficiency and the
quality, desirability or motivation of the operator.

However, it should be noted that most of the Commission's enforcement
actions
for poor and illegal operating practices such as jamming,
obscenity/profanity,
failure to identify, operation outside of license privileges and
failure
to
heed bandplans are against amateurs using voice modes, not Morse code
or
digital modes.

More because saying "FU" via code isn't likly to be listened to by
any non-coded ham or non-ham.

In 35+ years of mostly-CW amateur radio operation I have NEVER heard
anything
like that. Have you?

Nope...and that's my point. Morse as a mode doesn't
lend itself naturally to verbal abuse...whereas phone does
allow for easy oral abuse recognized by anyone listening...both
ham and non-ham.

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 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 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 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.

Since most amateurs do not desire to build their own equipment.....

Are you proposing not allowing hams to build their own?

No - just the opposite.

But note that NCVEC doesn't see a problem in requiring theory in the
writtens
because *some* hams *might choose* to homebrew....

Nor do you and I from what we have been saying.

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.

Following this logic, the written exams should be stripped of anything
a
licensee does not have an interest in.

ZIP - false, since any one subject CAN be ingnored and the test
applicant can still pass. Not so with the separate morse
test element.

That depends on what you mean by a "subject". If you define a "subject"
narrowly, that's true. But not if you define it as, say, "theory".

True.

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 properly. It is often disruptive and unsettling to those
other examinees who are 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
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 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 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.

Yet the growth in amateur radio from 1990 to 2000, when there were both
medical
waivers and a nocodetest license, was almost identical to that from
1980
to
1990, when all amateur licenses required code tests and there were no
waivers..

Again, I don't care about or argue the growth side of it.

If we drop the code test and don't get lots more new hams, then Element 1
wasn't really a barrier or burden. QED

Agree...but I have never made that argument anyway.

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 to be compliant with the Americans with
Disabilities Act (ADA).

Yet it was not compliance with the ADA that resulted in medical waivers
for the
13 and 20 wpm code tests.

If it hadn't happened otherwise, the ADA would have entered the
picture by now.

I disagree. But we can't dig up a dead King and ask him.

Do you seriously doubt that if the J1 king hadn't helped push
for the waivers of 13/20 that someone wouldn't have invoked
the ADA to gain the same result? We'll never know, but it
seems likly to me as the argument has been raised even
against the 5 wpm test.

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 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 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 has shown that physician-initiated
waiver requests have been very controversial in the Amateur Service.

By this logic, the written tests will also be a target of waiver
actions.
For
example, profoundly deaf people are currently required to study for
exams
which
include numerous questions on SSB and other voice modes even though
there
is
little chance they will ever use those modes.

Pure speculation and, IMHO, not likly to ever happen.

But it logically proceeds from the argument that people shouldn't have to
learn
stuff they won't use.

I don't see the same relationship between the logic
of a "skill" test vs a knowledge test.

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 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 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) 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, 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 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 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 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

This proposal simply drops Element 1 without making any other changes.
Oddly
enough, if it were adopted, Technicians would gain a bit of 10 meter
SSB.
Most
of the privileges Technicians would gain would be slices of 80, 40, 15
and
10
meter CW.

Start simple...then, if it makes sense, look at the overall licensing
levels, etc. Makes sense to me.

At that rate and the typical FCC NPRM cycle, a couple decades should do
it.

Maybe so :-( :-)

Cheers,
Bill K2UNK

"Dick Carroll;" wrote in message ...
Brian wrote:

Oh Geez. Not the same unelected, non-FCC guys that unilaterally
decided to jettison the 5wpm Morse Exam for the 13-15wpm Farnsworth
Exam, and deny HF access to otherwise qualified people who just can't
beep fast?

Come to think of it, I'm trying to remember the last time I voted for
the top few guys at the ARRL.

B-rian, you may not beep fast but you sure do chirp like hell!

I guess I need a little more bias.

"Dick Carroll;" wrote in message ...
Bill Sohl wrote:


The point is that morse is a character set, and the test is a skill
test based on speed of ability, not simple knowledge on a par
with written test questions.

Yes, thast *is* the point, indeed. As you well know being able to recognize Morse
characters written on paper has nothing whatever to do with copying in off a radio. It
exhibits so little knowledge as to be of no value.
No one can copy by ear or any other way with no more than that.

Which shows yojust how flawed and clueless the entire No Code Agenda has always been.

DICK, rewrite that in Engrish 100 times. On the blackboard. With chalk.