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ARRL General Bulletin ARLB102 (1998)

ARLB102 League files "restructuring" comments with FCC

QST de W1AW  
ARRL Bulletin 102  ARLB102
From ARRL Headquarters  
Newington CT  December 3, 1998
To all radio amateurs 

ARLB102 League files ''restructuring'' comments with FCC

The ARRL has filed formal comments in response to the FCC's proposed
streamlining of the Amateur Radio rules.  The League delivered its
comments to the FCC December 1, the final day for comments in the
FCC's Notice of Proposed Rulemaking in WT Docket 98-143.

The League's filing promotes the ARRL Board of Directors'
restructuring positions, adopted last July and fine-tuned at a
special meeting in October.  It also takes the FCC to task on a few
points.  The ARRL said the FCC's NPRM failed to contain ''a
comprehensive license restructuring proposal or even an overall
review of license restructuring'' and generally ''missed the mark.''

The League called on the FCC to adopt the ARRL Board's restructuring
plans as the centerpiece of its streamlining efforts.  Among other
things, the League plan calls for eliminating the Novice and Tech
Plus licenses to reduce the number of license classes from six to
four.  The ARRL plan automatically upgrades current Novice and Tech
Plus licensees to General.  The General license would become the
entry-level ticket to HF.  Existing Novice and Tech Plus HF CW bands
would be ''refarmed'' to provide additional phone spectrum for
General, Advanced, and Extra class licensees.

The FCC also proposed a four-tier license structure, eliminating the
Novice ticket and melding existing Technician and Tech Plus
licensees into a common database while allowing current Novices and
Tech Pluses to retain their current operating privileges.  The ARRL
said the FCC was on ''the right track'' in proposing to eliminate the
Novice ticket.  But the League said its ''instant upgrade'' plan for
Novice and Tech Plus operators is a better approach because it
permits ''refarming'' the underutilized Novice HF subbands.  The
League called refarming ''critical to any comprehensive license
restructuring proposal.''

The FCC's NPRM sought comments on the issue of Morse code testing
and requirements but offered no specific proposals.  The ARRL called
for a reduction in the number of Morse code examination tiers from
three to two--5 and 12 WPM--and changes in the written examinations
to make them more relevant and with greater emphasis on current
operating practices and newer digital technologies.  The League also
recommended that the number of written exam questions ''increase
incrementally'' for all license classes above Technician.

The League said that Morse code should not be overemphasized in the
licensing process, but should be continued as a licensing
requirement above the entry level.  It has proposed that General
class applicants pass a 5 WPM code test, while Advanced and Extra
applicants pass the 12 WPM code test.  Subsequent to release of its
original restructuring plan, the ARRL Board also decided to ask the
FCC to permit Technician operators to use Morse code on the General
class HF CW segments without passing a specific code examination.

The ARRL said acknowledged abuses of the CW disability exemption
process were an enforcement, not a testing, issue.  For those
claiming a disability waiver for the higher-speed CW test, the
League urged testing accommodations as a preferable alternative.
The League also urged an end to multiple-choice CW exams and rules
specifying that a passing grade for a Morse examination be either 70
percent correct answers to 10 fill-in questions or one minute out of
five of solid copy.

The League also praised the ''new dawn'' in amateur enforcement
undertaken within the Compliance and Information Bureau by Riley
Hollingsworth, K4ZDH.  The ARRL suggested that it would be
''reasonable to withhold any further action on amateur enforcement''
for now and let the CIB continue its work.

The ARRL's comments stressed the value of increasing participation
in the hobby and making it available to more people.  ''By increased
participation, Amateur Radio can provide even more service to the
United States than it does currently, with a simpler licensing
structure,'' the League asserted.

A complete copy of the ARRL's comments in WT Docket 98-143 is
available on ARRLWeb at (see
''ARRL's Comments to the FCC on WT Docket 98-143'').  Reply comments
on the FCC's rulemaking proposals are due January 15, 1999.  The FCC
is not expected to take action on restructuring at least until
sometime next spring.


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