Comments on Proposed Changes to FCC Part 97

These comments are in support of the FCC's proposed changes concerning the
Amateur Radio Service. Overall, the complexity of the licensing system should
be reduced while maintaining some incentives for increased knowledge of the
radio art. Also, the licensing requirements should reduce the emphasis on the
ability to receive Morse code reflecting the changes in technology that have
occured over the past couple of decades. 


1. The Novice License is clearly obsolete as demonstrated by the low number of
people entering the Amateur Radio Service via this means. Clearly, the
Technician license is the preferred entry point. The Novice license should be
eliminated, with existing licenses phased out over time.  A reasonable
approach would be to grant no renewals of Novice licenses after 5 years from
the date of the rule change. This would force existing Novice licensees to
upgrade to General Class (assuming that the Technician Plus license is
eliminated) or lose all operating privileges.

2. The elimination of the Novice license and Technician Plus license allows
for the correction of a problem with the Technician license exam. Presently, a
Technician license applicant must pass the Novice written test (Element 2) and
the Technician written test (Element 3A). Many of the questions in Element 2
relate to the high frequency privileges of the Novice license and are
irrelevant for the Technician license. A new exam (probably a revised
combination of Elements 2 and 3A) would replace the existing written exams. 

3. The FCC asked for comment on the Morse code requirement for the Amateur
Radio Service. Since under the proposal, the General class license would be
the entry license for high frequency (HF) privileges, the Morse code
requirement should be reduced to 5 WPM. This is consistent with the principle
that Morse code is still a useful skill but less important as technology
advances.  Note that this means that an existing Novice licensee could upgrade
to General by passing a written exam (probably Elements 3A and 3B or their
replacement). 

4. The Morse code requirement for the Extra class license should be reduced to
13 WPM. This supports the idea that the knowledge of Morse code is dropping in
value and simplifies the licensing and testing in amateur radio. Only two
levels of Morse code test would be required (5 WPM and 13 WPM). 

5. The FCC did not specifically mention the issue of memorization of the
question pool by applicants. The finite nature of the question pool for all
exam elements leaves the possibility that applicants can pass the exam by
simply memorizing the answers to the question pool. I have encountered
licensed radio amateurs that have passed the exam using this method. The FCC
should investigate the existing science behind human memory capacity and
increase the size of the question pool so that very few people are capable of
memorizing the entire pool. In particular, questions that have numerical
answers can be easily replicated with varying parameters so that the answer
can not be memorized.  Such an action would go far in restoring the integrity
of the examination process. 

6. The FCC should be very cautious about giving VECs additional flexibility in
generating written exams. This has the potential for inconsistent testing
standards being used at different exam sessions. Similarly, the FCC should
specify exactly how the Morse code exam is to be administered, so that testing
standards are consistent. 


In closing, I point out that I hold an Amateur Extra license, so I will not
personally benefit from the proposed changes in license requirements. However,
I think these changes are positive for the Amateur Radio Service. 

    Robert A. Witte
    KB0CY