Before the Federal Communications Commission Washington, DC Comments Submitted in the Matter of ) ) Simplification of the Rules Governing ) WT Docket No. 98-143 The Amateur Radio Service ) ) Comments submitted November 20, 1998 by Robert J. Crockett, an Amateur Radio Operator licensed as N9KUT. I may be contacted at 1923 South Sheridan Drive, Quincy, Illinois 62301-8978. Email: bcrocket@midwest.net To the Commissioners: INTRODUCTION 1. I have been an Amateur Radio Operator since 1991. I am active in the hobby and belong to The Western Illinois Amateur Radio Club, where I am a member of the repeater board and have held the position of Treasurer for the past 2 years. I also belong to the Quincy Area Repeater Group where I serve as a director and actively help to maintain their repeater.. I would like to offer these comments and recommendations in the matter of Docket 98-143. SUMMARY 2. In my opinion , the present license structure and system of examination serves the Amateur Radio community quite adequately. None the less, I recognize the need for FCC to reduce complexity and to streamline the rules governing the Amateur Radio Service. As a result and in response to Docket 98-143, I would like to offer comments and alternatively propose that the Amateur Radio Service rules be modified as follows; Reduce the number of classes of Amateur Radio license from 6 to 4 by eliminating the Technician Plus and Advanced License classes. Retain the Novice Class License in its present form and with its present privileges. Reduce the number of written question pools from 5 to 4 by combining Elements 4(A) and 4(B) into a single Element 4. Modify the FCC enforcement program to include greater participation of trained volunteers who are certified in an FCC enforcement program through an approved training course and are protected by statute from personal liability. Reduce the present three-tiered telegraphy proficiency examination system to a single 5 word per minute exam. DISCUSSION A. Number of License Classes 3. I am in favor of efforts by the FCC to reduce its workload and improve its efficiency in handling amateur radio matters. However, any change to the rules governing the Service must be done not only with efficiency and reduction of paperwork in mind, but must also be balanced against the resulting effects on the health and future growth of the Service. 4. Since the introduction of the Novice Class License in the early 1950's this license represented the easiest and most popular entry path into the Service. This remained true until the introduction of the code-free Technician class license nearly a decade ago. The Novice license allows entry into the hobby to anyone willing to demonstrate a fundamental knowledge of the rules and regulations, operating practices, and radio theory. The code examination is very basic at 5 WPM and nearly anyone willing to spend a few evenings of practice can pass this examination with little difficulty. 5. With the introduction of the code-free Technician License many candidates now choose this path in preference to the Novice License due to the lack of a code proficiency requirement and despite the more difficult written examination requirements. The figures quoted in the NPRM bear out this shift in popularity. However, among early and pre-teen candidates the Novice Class license is still the most viable entry path. I state this based upon my experiences gained through the annual introductory classes the Western Illinois Amateur Radio Club conducts each year. Typically there are several pre-teen candidates in these classes and they invariably struggle with the terms and concepts addressed in Element 3A. Additionally, local Volunteer Examiner teams during the process of administering examination sessions have observed a significantly lower success rate among pre-teens taking Element 3A as compared to older candidates who take the same element. I believe that the lower success rate of this age group is primarily due to the inability to comprehend the terminology and concepts presented in the materials which form the basis of examination for Element 3A. Without the Novice Class License, younger candidates who cannot comprehend the materials covered in the elements beyond Element 2 would, in effect, be denied entry into the Service. 6. Considering the proceeding factors, the elimination of the Novice and Technician Plus Licenses would have several very negative effects upon the future of Amateur Radio in the United States. First, without the Novice Class License, younger candidates who cannot comprehend the materials covered in the elements beyond Element 2 would, in effect, be denied entry into the Service. Without the Novice License and Technician Plus Licenses the minimum level of telegraphy examination speed needed to gain HF privileges would be that of the General License. Presently this is the 13 WPM Element 1B. In my opinion this would be a barrier to the future growth of HF activity. It is relatively easy to gain telegraphy skills sufficient to pass the 5-WPM (Element 1A) examination through classroom instruction and by listening to pre-recorded code practice materials. Attaining the necessary skill level in order to pass the next level of examination at 13 WPM (Element 1B) is much more difficult. Historically these skills are most easily gained only through on-air experience and actual use of the telegraphy mode. Attaining a skill level consistent with passing Element 1B is an much more difficult task if attempted through passive activities such as listening to code practice materials and through classroom instruction. I believe that a great many of those who have recently entered the Amateur Radio Service through the Technician License and eventually upgraded to General License and beyond did so by first upgrading to the Technician Plus License. The HF privileges thus gained are the key tool then used by the licensee to ease the process of upgrading from the Technician Plus License to the General License. 7. Thus, a license structure with the entry level telegraphy examination at the current 13 WPM General License level would in my opinion prevent a majority of entry level candidates from ever attaining HF privileges. I believe this would remain the case even if the General Class Telegraphy examination (Elements 1B) was administered at slower speed, even as slow as 10 WPM. 8. The Advanced License is achieved when a current General Class licensee successfully completes written Element 4(A). This License class is an interim step between the existing General and Extra Class licenses and becomes a stopping point for many Amateurs due to the 20 WPM requirements of Element 1(C). The need for this intermediate license class, especially when combined with a lesser focus on telegraphy, and coupled with an effort to streamline the licensing process is greatly reduced. 9. After considering all of the preceding factors, I would like to offer the following alternative. In an attempt to retain the ease of entry to the hobby now embodied in both the Novice and Technician Licenses, I propose that the Technician Plus License and the Advanced License be eliminated. B. Providing greater opportunities to volunteer examiners to participate in the examination process. 10. I strongly agree with the proposals set forth in Docket 98-143. C. Elimination of the Radio Amateur Civil Emergency Service. 11. I agree with the Commission that under emergency conditions, all necessary communications can be carried out by other FCC license holders, primary, club and military. Further I believe that there is little understanding among the present Amateur community of the purpose and background of RACES. There are limited active RACES groups in the United States and they operate very much in parallel with other volunteer Amateur organizations such as the ARRL sponsored Amateur Radio Emergency Service. D. Improvement of FCC enforcement of the existing rules governing the Amateur Radio Service. 12. The problem of enforcement on the Amateur frequencies is an issue that is in critical need of resolution. The lack of effective enforcement has continued for much too long. This coupled with the continued growth of the Service in the United States has created a problem of ever increasing magnitude. This is especially true in the HF bands but increasing incidents of interference and unacceptable language and behavior are also increasing on the VHF/UHF bands. 13. One factor complicating any solution is the lack of resources within the FCC and it's limited budget. Little more than a decade ago similar resource shortages were impacting the availability of examination opportunities before FCC examiners. That problem was resolved through the cooperation of the FCC and the amateur community itself. Today a successful program utilizing volunteer examiners serves the amateur community with literally thousands of examinations given annually. I believe a similar cooperative is possible in this case. Two issues have inhibited an effort of this nature in the past. One is that in the past, volunteers participating in enforcement activities and any data they may have gathered, have little standing in the legal aspect of any resulting enforcement process. This must be remedied for any volunteer program to be successful. 14. The second area that has been a stumbling block to any volunteer activity is the lack of protection from civil action for issues related to their voluntary activities. Several attempts have been made to pass legislation in Congress to address this issue. Until it is resolved and volunteers in this program as well others such as the Volunteer Examiner program will continue to have reservations regarding their participating. The FCC must take an active lead in seeing that this legislation proceeds through the Congress at the earliest opportunity. 15. Once the problem of indemnification has been resolved, I believe that FCC should establish a corps of certified volunteer observers. These volunteers would be certified to gather data and passively develop information that could be used by FCC in the enforcement process. The certification process could be carried out by organizations approved by FCC for this purpose with the costs borne by the volunteer. Once certified, these observers could play a large role in gathering information and evidence that could be used in many minor enforcement proceedings. This would release the critical FCC resources needed to handle the more serious problems. E. Competence level for telegraphy examinations and written examinations. 16. Telegraphy has been a part of Amateur Radio since the dawn of radio itself. Indeed this mode still enjoys great popularity within the Amateur community despite the fact that commercial communications and military systems have moved to other modes. In order to successfully operate and enjoy the telegraphy (CW) mode requires an Amateur posses a minimal knowledge and skill set before attempting on-air operation. 17. The fact other services have abandoned the telegraphy mode does not diminish the enjoyment many Amateurs get from operating this mode but it should signal a reduction in telegraphy's importance as a primary form of communication and as a significant licensing requirement. I believe that the telegraphy mode is important in terms of teaching discipline and proper operating techniques. However the need to demonstrate proficiency in telegraphy at speeds in excess of 5 words per minute should be removed and not longer required for any class of license. 18. The resulting licensing structure would consist of two entry level licenses. The Novice license which would require successful completion of Elements 1(A) and 2 and Technician license which would require successful completion of Elements 2 and 3(A). Both of these license classes would remain unchanged. 19. Testing methods for Element 1(A) would still include multiple choice tests as well as fill in the blank with both allowing credit for one minute of solid copy. 20. The General class license would require successful completion of elements 1(A), 2, 3(A) and 3(B). This would reduce the telegraphy requirement for the General class license to 5 words per minute consistent with the declining importance of telegraphy being experienced in other services. Amateurs who entered the hobby as Novices would need to complete elements 3(A) and 3(B) to advance to General Class. Amateurs who entered the hobby as Technicians would need to complete elements 1(A) and 3(B) to advance to General Class. 21. Existing Technician Plus Licensees would become General's upon successful completion of element 3(B). 22 The Extra class license would require successful completion of elements 1(A), 2, 3(A), 3(B) and 4. Element 4 would be a new element from the combination of existing elements 4(A) and 4(B). The Extra Class license would have no additional telegraphy requirement. 23. Existing Advanced Licensees would become Extra's upon successful completion of element 4. 24. When the Incentive Licensing Program was introduced to the Amateur community in the 1960's it was explained that the system was designed to encourage each Amateur to acquire additional operating skills and technical knowledge. The rewards for demonstrating these skills and knowledge through examination were additional operating privileges and operating spectrum. This policy has prevailed for over 30 years has resulted in growth and health within the Service and should be continued. The changes proposed above would continue much of that system while defocusing on the telegraphy requirements, minimizing license classes and reducing the number of question pools. 25. I further propose that reducing the focus on the telegraphy aspects of Amateur Radio should be offset with more difficult written tests. I specifically propose that the difficulty of the subject material for Elements 3(B) and Element (4) be increased. These tests should be more challenging and possibly contain information from other aspects of the hobby. 26. To further increase the difficulty of the written examinations, I suggest that the question pools no longer are made public. Sample tests compiled by the Commission or the VEC's would allow potential licensee's a method to check their preparedness. 27. I feel that the telegraphy examination should remain a part of the overall examination process but it should hold much less importance in the overall licensing structure consistent with it's declining importance in other services. To offset the decrease in licensing difficulty brought about by the reduction in telegraphy requirements, the subject matter for the higher level written examinations should be increased and the question pools no longer be made available for public inspection. Respectfully submitted, Robert J. Crockett N9KUT