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![Previous (earlier) Story](/images/sty-down.gif ""It Seems to Us . . ." BPL's 15 Minutes of Fame"){kind=small} Previous: "It Seems to Us . . ." BPL's 15 Minutes of Fame |  Next: ARRL In Action: What Have We Been Up To Lately? |
NEWINGTON, CT, Oct 1, 2003--Although the bell has sounded ending Round 1 of the comment period on the initial seven Morse code-related petitions for rulemaking, members of the Amateur Radio community continue to post their opinions. Some of the petitions called for altogether eliminating Element 1, the 5 WPM Morse test, from the Amateur Service rules (Part 97). At the conclusion of the official 30-day comment period, the FCC had recorded a total of nearly 2300 comments on the seven petitions. The number of commenters is likely much smaller, however, since many commented on each individual petition. While some were content to express a brief comment pro or con, a few put forth recommendations of their own that were nearly petitions in themselves. The tenor of the comments reflects the fact that Morse code remains an emotional issue for many Amateur Radio licensees
"The CW issue, as expected, is a very gut-wrenching issue for many hams," ARRL Great Lakes Director Jim Weaver, K8JE, observed recently in response to concerns expressed by some members in his division. "Sometimes we mortals let issues to which we have emotional ties get out of perspective."
Garnering the lion's share of comments--with more than 600 posted and counting--was the Petition for Rule Making filed by the National Conference of Volunteer Examiner Coordinators (NCVEC). Designated RM-10787, the detailed, nine-page filing, called on the FCC to delete Element 1 and give "Tech Plus" privileges to current Technician licensees. The NCVEC also asked the FCC to "take expedited action" to allow volunteer examiner coordinators (VECs) to discontinue administering Element 1 "as soon as possible."
The NCVEC has been keeping close track of the comments recorded on its petition. As of September 29, the balance was 56 percent in favor of dropping Element 1 and 43 percent opposed. Approximately 1 percent of the petitions either were undecipherable or took no position.
Con
Strongly worded--and identical--sets of comments from the Potomac Valley Radio Club (PVRC) and the US members of the First Class CW Operators' Club (FOC-US) argued in favor of retaining the Morse requirement "at least for the Amateur Extra class license." Their comments were posted on all seven petitions.
"CW testing at the currently modest proficiency level of but 5 WPM represents a minimal standard that anyone serious about using Amateur Radio HF bands should be more than willing to possess," the PVRC and FOC-US said. The two organizations, which claim a total of upward of 1000 members in the US, asserted that Morse is a "critical emergency communications skill" and that eliminating the Morse requirement would adversely affect national emergency preparedness.
Thomas Geis, K1ZQ, declared that the elimination of Element 1 would be ill advised. "The Amateur Service is not broken--do not 'fix' it." Geis said.
Richard Adamy, KA4GFY, strongly disagreed with the notion of granting Technician licensees "instant access" to the HF spectrum without further testing. "While Morse code may not be used by other services," he told the FCC, "the Amateur Radio Service is not like the other services." Adamy said ham radio is "not only frequency agile, but mode agile," and CW is "the second most popular mode on the HF bands." Adamy was among those who expressed the opinion that "people tend to place a higher value on something they have to work for," and he called for retaining the Morse code requirement.
Pro
On the other side of the issue, commenters such as William Stewart, W2BSA, recommended the FCC act favorably on the NCVEC's petition. "This petition is also the only petition which spells out exactly what must be changed in the Amateur Radio regulations to carry out the objectives of the petition," Stewart said.
Mirroring the sentiments of many favoring the deletion of Element 1 from the FCC's rules, Laszlo Morocz, KF4PV, called Morse "an anachronism" as a requirement for Amateur Radio licensing. "The lack of a telegraphy examination will not prevent those who want to use CW radiotelegraphy for communications from using it," Morocz said, "any more than the lack of a typing test prevents digital mode aficionados from using PSK31, PACTOR, etc."
Similarly, Trever Adams, AE6HR, described Morse as "just another mode." Adams said that while CW should not be discouraged and that CW subbands should remain in place, "the requirement for proficiency in order to use Amateur Radio frequencies below 30 MHz should be removed."
Alan Kaul, W6RCL, argued in favor of discontinuing the Element 1 requirement for General applicants but said it should be retained for Extra class applicants.
Hans Brakob, K0HB--a former ARRL Dakota Division Vice Director--said he could find "no persuasive argument" to continue Morse testing. He also proposed a new licensing regime, with a Class B entry-level ticket and a Class A top-level ticket.
The NCVEC is the umbrella group for the 14 VECs in the US. Because the ARRL only comments directly to the FCC and not through other organizations, the ARRL-VEC abstained from voting on the NCVEC's petition question when it came up during the NCVEC's July 25 meeting in Gettysburg, Pennsylvania.
Other Morse-related petitions were filed by Peter M. Beauregard, KI1I, Pete V. Coppola, KG4QDZ, and family, Tina Coppola, KG4YUM, and Pete A. Coppola, KG4QDY, Kiernan K. Holliday, WA6BJH, Dale Reich, K8AD, Eric Ward, N0HHS, and No-Code International.
What's Ahead?
The FCC has yet to put another five Morse code-related petitions for rulemaking on public notice and invite comments on them. The ARRL did not comment on any of the seven initial petitions for rule making and won't likely comment on any future petitions on this topic. ARRL Chief Executive Officer David Sumner, K1ZZ, explained that there's no particular urgency to the issue and ample reason for the League to devote its attention to issues having more immediacy such as BPL.
"There have been numerous proposals submitted to the FCC with regard to amateur licensing qualifications and privileges," Sumner said. "Some have been put on public notice; others are at various points in the FCC's administrative pipeline. No doubt there will be more. There is no need for the ARRL to react to each and every one."
Sumner predicted it would be "months, if not longer" before the FCC takes any action on any of the petitions. In the meantime, he said, "there is plenty of time for the ARRL to receive considered input from its members and either to formulate a reasoned proposal for change or a rationale for maintaining the status quo."
At its January 2001 meeting, the ARRL Board of Directors reaffirmed the League's position to retain the Morse code examination requirement for HF access. World Radiocommunication Conference 2003 (WRC-03) left it up to individual countries to decide whether or not they want a Morse requirement for HF privileges. In the wake of WRC-03, the ARRL Executive Committee has been working on its own comprehensive Amateur Radio licensing proposal, of which the Morse requirement would be a part. Once completed, the proposal will go to the ARRL Board of Directors for consideration and possible action at its January 2004 meeting.
"There is simply no urgency to address it any sooner than that," Sumner said.
Elsewhere in the World
Following WRC-03, the International Amateur Radio Union (IARU) Administrative Council called for the removal of Morse code as an examination requirement to operate on HF. The council reiterated its stance--first taken in 2001--that Morse code proficiency "as a qualifying criterion for an HF amateur license is no longer relevant to the healthy future of Amateur Radio."
"IARU policy is to support the removal of Morse code testing as a requirement for an amateur license to operate on frequencies below 30 MHz," the IARU governing body resolved. At the same time, the council's resolution recognized Morse code as "an effective and efficient mode of communication used by many thousands of radio amateurs."
The most recent countries to summarily drop
the Morse requirement were Ireland, Singapore and Luxembourg. Switzerland,
Belgium, the UK, Germany, Norway, the Netherlands, Austria, New Zealand and
Australia also have moved to drop their Morse requirements or are expected to
do so this year.
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