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yet another nail in the coffin for morse code

Discussion in 'Communication (CB | GPS | HAM)' started by rebelk5frk, Aug 1, 2003.

  1. rebelk5frk

    rebelk5frk 1/2 ton status

    Joined:
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    Location:
    Houston, TX
    Before the
    FEDERAL COMMUNICATIONS COMMISSION
    Washington, D.C. 20554


    In the Matter of )
    )
    Amendment of Part 97 of the Commission's ) RM-
    Amateur Service Rules to Eliminate )
    Morse code testing )
    )

    To: The Commission


    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.

    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.

    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.

    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.

    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.

    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.



    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.

    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.

    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.

    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.

    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.

    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.

    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.

    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).

    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.

    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


    By:___
    Frederick O. Maia, W5YI, Chairman,
    NCVEC Rules Committee

    July 29, 2003

    ------------------------------------------------------------------------------------------



    -----------
    APPENDIX
    PROPOSED RULES

    Proposed changes to Part 97 of Chapter I of Title 47 of the Code of
    Federal Regulations to delete references to the Morse code exam
    element. Part 97, is amended as follows:

    PART 97 -- AMATEUR RADIO SERVICE

    1. Section 97.301 is amended by revising paragraph (e) to read as
    follows. The frequency tables in Section 97.301(a), (b), ©, (d) and
    (e) remain unchanged.

    97.301 Authorized frequency bands.

    The following transmitting frequency bands are available to an amateur
    station located within 50 km of the Earth's surface, within the
    specified ITU Region, and outside any area where the amateur service is
    regulated by any authority other than the FCC.
    (d) ******
    (e) For a station having a control operator who has been granted an
    operator license of Novice Class, Technician Class or Technician Plus
    Class:


    Wavelength ITU Region 1 ITU Region 2 ITU Region 3 Sharing
    requirements,
    see  97.303


    HF MHz MHz MHz paragraph:

    80 m 3.675-3.725 3.675-3.725 3.675-3.725 (a)
    40 m 7.050-7.075 7.10-7.15 7.050-7.075 (a)
    15 m 21.10-21.20 21.10-21.20 21.10-21.20
    10 m 28.1-28.5 28.1-28.5 28.1-28.5

    VHF MHz MHz MHz
    1.25 m - - 222-225 - - (a)

    UHF MHz MHz MHz
    23 cm 1270-1295 1270-1295 1270-1295 (h)(i)


    2. Section 97.307 is amended by deleting paragraph (f)(9) and revising
    paragraph (f)(10) to read as follows. Previous  97.307(f)(10) is
    renumbered to (f)(9). Paragraphs (f)(11) to (f)(13) are renumbered to
    (f)(10) to (f)(12).

     97.307 Emission standards.

    (f) The following standards and limitations apply to transmissions on
    the frequencies specified in 97.305© of this part. (10) A
    station having a control operator holding a Novice Class, Technician
    Class or Technician Plus operator license may only transmit a CW
    emission using the international Morse code or phone emissions J3E and
    R3E.



    3. Section 97.313 is amended by revising paragraph ©(2) to read as follows:

    97.313 Transmitter power standards.

    (b) ******
    © No station may transmit with a transmitter power exceeding 200 W PEP on:
    (1) ******
    (2) The 28.1-28.5 MHz segment when the control operator is a Novice Class operator, a
    Technician Class operator or a Technician Plus Class; or
    (3) ******


    4. Section 97.501 is amended by revising paragraph (a) and (b) to read as follows.

    97.501 Qualifying for an amateur operator license.

    Each applicant must pass an examination for a new amateur operator license grant and for each change in
    operator class. Each applicant for the class of operator license grant specified below must pass, or
    otherwise receive examination credit for, the following examination elements:
    (a) Amateur Extra Class operator: Elements 2, 3, and 4;
    (b) General Class operator: Elements 2, and 3;
    © ******


    5. Section 97.503 is amended by deleting paragraph (a).

    97.503 Element standards.

    (b) ******


    6. Section 97.505 is amended by revising paragraph (a)(1), (a)(2), and (a)(3) to read as follows.
    Paragraphs (a)(5), (a)(7), and (a)(9) are deleted.

    97.505 Element credit.

    (a) The administering VEs must give credit as specified below to an examinee holding any of the
    following license grants or license documents:
    (1) An unexpired (or expired but within the grace period for renewal) FCC-granted
    Advanced Class operator license grant: Elements 2 and 3.
    (2) An unexpired (or expired but within the grace period for renewal) FCC-granted General
    Class operator license grant: Elements 2 and 3.
    (3) An unexpired (or expired but within the grace period for renewal) FCC-granted
    Technician Plus Class operator license grant: Element 2
    (4) ******
    (6) ******
    (8) ******
    (b) ******



    7. Section 97.507 is amended by revising paragraph (a), (a)(2), and © to read as follows. Paragraph (d)
    is deleted.

    97.507 Preparing an examination.

    (a) Each written question set administered to an examinee must be prepared by a VE holding an
    Amateur Extra Class operator license. A written question set may also be prepared for the following
    elements by a VE holding an operator license of the class indicated:
    (1) ******
    (2) Element 2: Advanced, General, or Technician (including Technician Plus) Class
    operators.
    (b) *******
    © Each written question set administered to an examinee for an amateur operator license must be
    prepared, or obtained from a supplier, by the administering VEs according to instructions from the
    coordinating VEC.


    8. Section 97.509 is amended by revising paragraph (f) to read as follows. Paragraph (g) is deleted.

    97.509 Administering VE requirements.

    (e) ******
    (f) No examination that has been compromised shall be administered to any examinee. The same
    question set may not be re-administered to the same examinee.
    (h) ******

    -------------------------------------------
    (1)
    The following organizations have entered into an agreement with the FCC
    to coordinate Amateur Radio examinations: Anchorage Amateur Radio Club,
    Anchorage, AK; American Radio Relay League (ARRL), Newington, CT;
    CAVEC, Inc., Huntsville, AL; Golden Empire Amateur Radio Society,
    Chico, CA; Greater L.A. Amateur Radio Group, North Hills, CA; Jefferson
    Amateur Radio Club, New Orleans, LA; Laurel Amateur Radio Club, Inc.;
    Laurel, MD; The Milwaukee Radio Amateurs' Club, Inc., Milwaukee, WI;
    MO-KAN VEC Coordinator, Richmond, KS; Sandarc-VEC, La Mesa, CA;
    Sunnyvale VEC Amateur Radio Club, Inc., Sunnyvale, CA; W4VEC, High
    Point, NC; W5YI-VEC, Dallas, TX; Western Carolina Amateur Radio Society
    VEC, Inc., Knoxville, TN.

    The United Kingdom's Regulatory Authority
    published a "Gazette Notice" on July 25, 2003, discontinuing all Morse
    code testing in their Amateur Service effective July 26, 2003. The
    effect was that all "Class B" (no code) radio amateurs in Great Britain
    who previously were restricted to operation above 30 MHz obtained
    "Class A" access to all Amateur bands. This can be confirmed at the
    Radio Society of Great Britain's website at:
    and/or the UK "Regulatory Authority" (their telecom regulator) website
    at: . In addition, effective July 15, 2003,
    radio amateurs in Switzerland were given immediate "provisional"
    authority to operate on the HF amateur bands by the Swiss Federal
    Office of Communications (OFCOM) while they await formal rulemaking.
    Citing the recent WRC-03 decision, OFCOM said the temporary permission
    to use the HF bands would suffice until the regulation could be
    changed. Many other countries are rumored to be in the process of
    discontinuing Morse code testing.
    See 47 C.F.R.  503(a.)
     

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