This is a response to the paper "Amateur Radio in the 21st Century", prepared
by Jim Wiley, KL7CC, with assistance from other members of NCVEC working on
changes to the US Amateur rules. This response is intended to evaluate and
constructively comment on the merits of the various ideas and changes presented
in the paper, regardless of their source.

For purposes of clarity and brevity, the introductions and executive summaries
are not reproduced here.

"Part One" dealt with the code test. "Part Two" and "Part Three" deal with the
proposed "Communicator" license.

Since the style of the paper is conversational, I inserted my comments into the
original paper in the same style, so that the paper reads like a conversation
between KL7CC and myself. My comments are preceded with "N2EY". The main text
of the original paper is preceded by "KL7CC".

Here is my response to "Amateur Radio In the 21st Century"

Part Three

KL7CC: How about those who feel insulted that these new hams are gaining "free"
access to bands that "they had to work hard for". Excuse me? Do we recognize
that times have changed and move on, or not?

N2EY: Excuse me? What exactly does "that times have changed and move on" mean
in this context? Are you saying that those who disagree with you should simply
shut up?

KL7CC: Following that argument to it's logical end, isn't it reasonable to say
that if the newcomers have to learn the old stuff before they can have a
license, then the existing licensees should have to give back their tickets
until they could show they had mastered all the newer techniques too? Wouldn't
that be fair? I'm sure it seems reasonable to a newcomer. Sauce for the
goose, and all that, right?

N2EY: Wrong. Licenses are granted for a specific term. They are renewed based
on the licensee having a clean record. It is part of the "conditions of grant"
that licensees will stay current with changes in rules and regulations as they
apply to their license.

KL7CC: A timetable:

As we all know, several petitions requesting that the FCC remove Morse code
testing have been filed. Depending on how soon a NPRM is issued, assuming it is
at all, then we have to wait while they slog their way through the rule making
process. One of the things that will happen is that comments, both pro and
con, will begin to accumulate. After a several weeks or at most a few months,
and assuming the majority of comments are in favor of eliminating the code as a
licensing requirement, then we plan to file for a waiver asking for an
immediate end to code testing. Obviously, this can only be done if there are
enough favorable comments on file for the FCC to justify granting such a
waiver. The actual change in the FCC rules will still be in progress, but if
we can show that there is enough interest, and that such a waiver will be
beneficial to Amateur Radio as a whole, then there is a good chance it would be
granted.

N2EY: It is also possible that FCC will go through the entire NPRM process
before dropping Element 1.

KL7CC: Very soon (a few days at most) after the Morse requirement disappears,
assuming it does, then we plan to file for the creation of the "Communicator"
license, as detailed elsewhere in this discussion. We will follow the same
procedure as before, filing a petition for a NPRM, and starting the clock on
that issue. Assuming the comments on that issue are also favorable, after a
reasonable time has elapsed, we will file a petition to upgrade Techs to
General, and Advanced to Extra, as explained earlier.

We will probably not be able to accelerate the creation of the "Communicator"
license, since it would involve a complete restructure of the present system,
but in case that option should become available, we would likewise pursue that
end.

Next, once the "Communicator" proposal started to look like it would become
reality, we would file another petition asking that the Novice HF assignments
be re-allocated, also as per the previous discussion. We would further ask
that the re-allocation take place at the same time as the implementation date
of the new license, so that those who passed their tests would have a place to
operate.

N2EY: Why all the steps and delays? Look how long the last restructuring took!
And there are still petitions on the table for refarming the Novice bands.

If the Communicator is a good idea, then it should be openly discussed and
developed in the entire amateur community now, and a comprehensive proposal put
together so that everything is handled in one NPRM cycle.

KL7CC: In all cases, because this is a multiple step process, useful
information will be gained as each part moves forward. This is actually a
benefit, because we may very well find that some of the present ideas need
revision before being submitted.

All this will take some time, perhaps spanning several years. Mixed in with
these proposals, but not part of them, will be the issue of how to best
implement other changes to the amateur regulations that came out of WRC-2003,
such as the 40 meter readjustment. These issues have their own timetable, of
course, but those issues and the topics discussed in the possible petitions
mentioned here do interact to varying degrees.

In other words, nothing is going to happen next week, and everyone will have
ample time to offer his or her own suggestions as to how to proceed. There
will be no "rush to judgment". All the present actions have done, or can do,
is to get something out there for consideration. There is absolutely no
guarantee that the FCC, or the ham community at large, will accept these
proposals.

N2EY: The thing to do is develop them out in the open, with input from all
interested parties. Otherwise, you are cutting yourself off from the community
whose support you need to make the proposal work.

KL7CC: You have heard a lot about what we are planning. Now, how about some of
the things we are not addressing at this time:

We are not addressing the issue of reallocation of bands or sub-bands, either
by mode or license class, with the sole exception of using the former Novice CW
sub-bands on 80, 40, 15 and 10 meters to create working space for new
Communicator licensees. By the way, don't forget that this adjustment will
create more phone space for General, Advanced, and Extra operators at the same
time. And, in the case of 40 meters, when the WRC-2003 re-allocation adds
another 100 KHz the band in regions 1 and 3 (that is to say, adding 7100-7200
to the present 7000-7100 world wide Amateur allocation), there will be a 100
KHz phone band overlap all ready to go!

N2EY: Communicators need more than those 4 bands on HF.

KL7CC: We are not suggesting that the CW sub-bands, or the exclusive CW bands
for Extra licensees, be eliminated or otherwise adjusted. Again, with the
exception of Novice CW, we are not proposing any change whatsoever to the
present band plans or allocations.

N2EY: There are NO exclusive CW subbands in amateur HF or MF. All are shared
with data modes.

With all due respect, if someone doesn't know that simple fact, or cannot
bother to write "CW/data subbands", that person really shouldn't be proposing
policy changes. Just my opinion.

Using terms like "CW bands" and "exclusive CW subbands" has caused some hams to
believe that other modes are not allowed there.

KL7CC: We are not addressing the issue of the relative split between General,
Advanced, and Extra allocations at HF.

We feel that these issues are best dealt with only after some period of
experience with both the proposed new license and a completely code free
licensing structure give us more insight on the best way to proceed. This
intermediate stage may take a while to properly evaluate. These issues may be
best addressed at the time that reallocation of the 40 meter band (per
decisions made at WRC 2003) takes place. According to the present schedule,
that is not likely to happen sooner than 5 or 6 years from now. By that time,
we will have accumulated enough data to tell us whether additional adjustments
are in order, or not.

OK, there you have it, the "master plan". Will it actually turn out this
way? Probably not. Just as there are thousands of hams, there will be lots of
suggestions, pro and con, about which is the best way to go. When (and if) a
petition is filed, and a Notice of Proposed Rule Making (NPRM) is posted, offer
your comments and suggestions.

N2EY: That last sentence sounds like you are saying that no one except NCVEC
should file a petition, or comment, until an NPRM is posted by FCC. I hope I am
mistaken in that interpretation.

KL7CC: The FCC will consider all sides before changing anything. If a majority
of comments indicate that hams want thing to stay the way they are, then that's
what will happen.

N2EY: That is not what happened with the Restructuring NPRM (98-143). The
majority of comments wanted 2 or 3 code test speeds, but FCC went with just 1
code test speed. The minority opinion was accepted by FCC and the majority
opinion rejected. Perhaps it will be different next time. But there is a
precedent for FCC to reject majority opinion.

KL7CC: If hams want change, and their arguments make sense, then that's what
will happen. In almost no other country in the world are the governed given
the chance to affect the rules that do the governing. Use that power if you
wish. But don't just sit there and complain if you don't act.

A few final words:

There are no black helicopters.

N2EY: I do not place any credibility in conspiracy theories.

KL7CC: This is not a plot by ARRL or Fred (W5YI) or anyone else to sell more
books, antennas, radios, or (fill in the blank). Yes, ARRL will gain some new
members, the W5YI group will sell a few more books, and possibly some of the
manufacturers and vendors will peddle a few more sets. Is this bad? How?


N2EY: It's a bad thing if quality is sacrificed as part of an ill-fated quest
for quantity.

Suppose the numbers do not increase dramatically - will NCVEC admit they were
wrong and petition to put back the old system?

KL7CC: It looks like growth of our beloved hobby from here.

N2EY: It looks like some good ideas and some bad ideas from here.

KL7CC: By the way, did you know Fred sold his company some time back? He does
not particularly stand to gain anything from this effort, nor do any of the
other committee members. Do you suppose the committee members just want to see
our wonderful hobby prosper? Wouldn't that be an odd reason for doing what
they are doing?

N2EY: I don't know any of the committee members personally, nor do I assume
anyhting about their motivations. The mere fact that someone wants the ARS to
prosper doesn't mean their ideas and proposals are good ones.

KL7CC: Just thought you'd like to know. Thanks for taking the time to read
this somewhat long explanation, and in the truest sense, 73.

Thanks you for reading my rebuttal

73 de Jim, N2EY

Respectfully submitted by Jim Wiley, KL7CC

With assistance from Fred Maia, W5YI, and Scott Neustadter, W4WW
++++++++++++++++++++++

N2EY: A few closing observations:

All of the above seems focused on the idea of "growth in the ARS" -
specifically, getting more new hams. The license tests in general and the code
test in particular are being cited as causes of low growth. The above
discussion seems to promise lots of new hams if the code test is dropped and
the entry level license requirements reduced. What if the proposed changes are
made and there is no significant long term change in growth?
Will we revert to the previous system?

Back in 2000, code testing was reduced from three speeds to one (5 wpm) and the
written test requirements reduced considerably. There was an initial surge of
new hams and upgrades, but in the 3-1/2 years since the changes were made
effective, the number of US hams has only grown by about 10,000. The growth
rate now is about the same as it was before the changes.

What is being overlooked in these discussions are other factors limiting the
growth of the ARS. These factors have far more impact than the license tests,
code or written. Two factors come immediately to mind: Lack of publicity about
the ARS in the mainstream media, and CC&Rs making the installation of an
effective amateur station too difficult for many prospective amateurs.

Thank you for reading my comments.

73 de Jim, N2EY