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ARRL General Bulletin ARLB057 (1998)

ARLB057 FCC proposes to streamline amateur rules

ARRL Bulletin 57  ARLB057
From ARRL Headquarters
Newington CT  August 11, 1998
To all radio amateurs

ARLB057 FCC proposes to streamline amateur rules

The FCC has proposed to phase out the Novice and Technician Plus
class licenses, leaving just four amateur license classes in
place--Technician, General, Advanced, and Extra.  The Commission
also has asked the amateur community to express its opinions on
Morse code requirements for licensing and testing, but offered no
specific changes.  And the FCC proposed to permit Advanced class
licensees to administer amateur exams up through General class.  The
proposals were among several suggested rules changes and invitations
to comment contained in an FCC Notice of Proposed Rulemaking, WT
Docket 98-143, made public August 10.

In proposing to phase out the Novice and Tech Plus tickets, the FCC
said ''there appears to be an unnecessary overlap between the Novice,
Technician, and Technician Plus license classes.''  The FCC also said
that Technician and Tech Plus operators ''predominantly'' use FM and
packet on VHF and UHF.  In addition, the FCC said Novice applicants
last year numbered fewer than 1000, while there were nearly 21,500
Technician applications.

Under the FCC plan, Novice and Tech Plus licensees would retain
current operating privileges, but no new Novice or Tech Plus
licenses would be granted.  For examination purposes, current
examination elements 2 and 3A would be combined into a new element
3A.  For administrative purposes, the FCC would combine the current
Technician and Tech Plus databases into a single Technician
database.  The proposal would eliminate the 5 WPM code test, Element
1A, as a required element for any class of license.

The elimination of the Novice and Tech Plus license classes would
effectively raise the bar for future applicants desiring to gain HF
operating privileges, unless the FCC ultimately reduces Morse code
testing requirements.  Since the General class license would become
the entry-level HF ticket under the FCC's proposed rules, applicants
would have to pass at least the 13 WPM code test.

The FCC did not propose to change any operating frequencies or
license privileges for amateurs.  However, the FCC does seeks
comment on the disposition of the current Novice HF bands, which
carry a 200-W output power limit for all licensees.  The FCC invited
comment on whether it would be ''appropriate'' to delete the Novice
bands and the power restrictions on higher-class licensees and
permit Novices to operate CW anywhere on 80, 40, 15, and 10 meters
at 200 W output.

The FCC opened the door to comments on all aspects of Morse code
testing from the amateur community.  In particular, the Commission
said it wants to know if hams prefer the current three-level system
or would like to see it reduced to a one or two-tier system--and, if
so, at what required speeds.  The FCC asked whether hams would be
willing to trade a reduction in Morse code requirements for
additional written elements on newer digital technologies ''which, in
part, are replacing the Morse code.''  And, the Commission asked
whether it should consider specifying Morse code examination
methods, such as fill-in-the-blank or one minute of solid copy,
instead of allowing VEs to determine the testing method.

In a related issue, the FCC also seeks comments on how to deal with
potential abuses of the current disability waiver for higher-speed
Morse code tests.  In RM-9196, the ARRL had asked the FCC to require
anyone applying for an exemption pursuant to a doctor's
certification to first attempt the higher-speed test before
examination credit could be given.  The League also asked that VECs
have access to relevant medical information from the certifying
physician.  The FCC said the ARRL's proposal would place ''an unfair
burden on examinees'' and raised serious privacy and confidentiality

The FCC went along with an ARRL petition and proposed allowing
Advanced class hams to be eligible to prepare and administer license
examinations up through General class under the VE program.  The
Commission said the change would permit greater testing
opportunities for hams.  The FCC also invited comments on whether it
should change written examination requirements ''to provide VEs and
VECs additional flexibility in determining the specific contents of
written examinations.''

Referring to yet another ARRL petition, RM-9150, the FCC invited
comments on how it can improve its Amateur Radio enforcement
processes.  The FCC applauded the ARRL ''for its creative thinking''
in that petition, but said the specific proposal was ''inconsistent''
with the current statutory role of administrative law judges.  The
FCC raised the possibility of encouraging complainants to include a
draft order ''to show cause to initiate a revocation or cease and
desist hearing proceeding.''  The FCC said it also wants to hear how
it can better use the services of the Amateur Auxiliary in beefing
up enforcement.

The FCC proposed to phase out Radio Amateur Civil Emergency Service,
or RACES, stations by not renewing their licenses.  No new RACES
licenses have been issued since 1980, and only 249 valid licenses
remain.  The FCC said RACES stations no longer are needed because
any amateur station that has been properly registered with a civil
defense organization has the same privileges as a RACES station.

The FCC also took the occasion to clarify the definition of ''power''
as used in the RF exposure table in Section 97.13(c)(1).  The FCC
said it refers to peak envelope power (PEP) input to the antenna.
It also made clear that no one holding an FCC-issued ham ticket may
apply for a reciprocal permit for alien amateur license.

The FCC set a longer-than-normal comment period.  The deadline for
comments is December 1, 1998.  The deadline for reply comments is
January 15, 1999.  The FCC will accept electronic comments via the
Internet at

A copy of the complete NPRM has been posted on the ARRLWeb page, The FCC NPRM can also be downloaded from the
FCC Web site in Word Perfect 5.1 and Text versions as:


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