Federal Communications Commission
Wireless Telecommunications Bureau
1919 M Street, N.W.
Washington, D.C. 20554

AUG 14 1998

Gentlemen:

Re: Amateur Service Review,

Your desire to simplify the amateur radio service is probably
well founded but it can also be improved. First, instead of
having 6 license grades, only 3 are needed. These are:
   
The LOWEST license class, termed "Class c", would be for amateurs
who are not interested in making long distance (DX) contacts and
who have no desire to use what has historically been the basis of
all amateur work, the Morse Code ("CW'). This license would allow
such people to operate on all VHF and UHF amateur bands (above 30
MHz), using any legal amateur mode including practicing CW or MCW
with other amateurs. This license test should cover basic
electricity, basic active devices, basic radio circuits, basic
radio systems, VHF and UHF antennas, and radio laws pertaining to
amateur operations on VHF and UHF bands.
   
The MIDDLE License class, termed "Class B", would be for amateurs
who want to operate in the HF range (1.8 MHz to 29.7 MHz, as well
as on the VHF and UHF amateur bands, using either CW or any other
legal mode. The lowest 25 kHz of all HF bands above 3.5 MHz,
which are usually used world-wide for DX CW communicating, would
be limited to CW for both class B and class A license holders.
The second 25 kHz should be reserved for Class A (see next
paragraph) licensed amateurs for higher speed CW work. The next
25 kHz would also be for CW. The next 50 kHz would be for all
modes other than forms of radiotelephone. The remainder of all
bands would be for CW and radiotelephone only. (CW must be
allowed on all amateur frequencies because it requires the least
sophisticated equipment for 2-way emergency radio communications)
This license test should go deeper into electricity, active
devices, radio circuits, radio systems, HE, UHF and VHF antennas,
radio laws pertaining to amateur operating on all bands, plus a
CW sending and receiving test at 13 words-per-minute (wpm). * *
  
The TOP License class, termed "Class A", would be for higher
speed CW amateurs. It would only differ from the Class B license
in requiring a CW sending and receiving test at 20 wpm. (The more
advanced theory test given for the Class B license should include
all of the theory required for any mode of HF amateur
operations.)
 
**The suggested 12 wpm test by ARRL is not quite high enough.
(ARRL is mostly interested in increasing the number of amateur
operators to sell more magazines and other items and attract more
advertisers). This writer taught CW and radio licensing
professionally, at Community College level, for 27 years besides
working as a licensed CW operator aboard ships and in police
radio. His 700+ page text, "Electronic Communication", published
by McGraw-Hill, includes chapters on "Operating Fundamentals", on
"Amateur Radio" and on "Radio Rules and Licenses". He has found
that the human mind first tries to learn code reception by
memorizing what dots and dashes are in letters being heard. This
can be done fairly well up to perhaps 12 wpm. His first amateur
test was at 10 wpm and he can remember still counting dots and
dashes for some letters. Students take almost as much time to
progress from 10 to 13 wpm as they take for 0 to 10 wpm. By the
time they reach about 13 wpm they no longer hear separate dots
and dashes but recognize the letter sounds as specific letters.
They have finally learned the code! For anyone not familiar with
Morse Code: The letter "S" is sent as dot-dot-dot. A person
capable of receiving at 13 wpm hears it as "dididit" and
recognizes this sound as the letter "S". Similarly, the letter
"I?" is sent as dot-dot-dash-dot. The sound of "dididahdit" is
instantly recognized as the letter "F". The same is true of all
letters, numbers, punctuation and special operating signs
used in Morse Code. Back in the 193O's, the FCC recognized that
code is learned at 13 wpm so it increased amateur Morse Code
speed tests from 10 to 13 wpm. (Just because many foreign
countries give 12 wpm tests is no reason why the U.S.A. shouldn't
do it properly.)
   
There is only one way of giving worthwhile code tests - plain
language words including some numbers are sent at 13 (or 20) wpm
for 4 or 5 minutes. The test should be considered passed if there
is one minute during this copy time at 13 (or 20) wpm with at
least 65 (or 100) letters copied correctly in succession. The
same is true of a 4 or 5 minute sending test - 65 (or 100)
letters must be properly sent in succession in one minute. (Any 5
letters plus a space is considered one word.)
  
The present method of sending for a given time at a required
speed and then giving a multiple-guess test on what was
transmitted does not test code receiving ability. One amateur
told me he went in to try for a Novice 5-wpm test but was talked
into trying the 20-wpm Extra Class CW test. He was not sure if he
really knew 5 wpm or not when he went in, but he passed the
20-wpm multiple-guess test! Of course no sending test was at 20
wpm, which would have proved him unqualified. Sending tests have
not been required for years! I am constantly working Extra Class
licensed operators who can not send or receive at even 10 wpm.
The method presently being used is a BAD method of testing code
ability! It should be changed.
  
A 5-wpm code test is of no use except to raise the number of
amateurs. This is proven by the 5-wpm tests given Novices in the
past, now recognized as being essentially useless. If it is
desired that someone know the Morse Code let them be tested at a
speed which will show that they are capable of proper operating -
that they do know how to send and receive at that speed.
   
There will have to be a "Grandfather" clause regarding present
license holders if new license classes are adopted. "Extra" class
would become "Class A" - "Advanced" and "General" classes would
become "Class B" since these operators have all passed 13-wpm
tests - Other class license holders who have not passed a 13-wpm
test would become "Class C".
 
It is hoped that this simplified plan for possible changes on our
present Amateur Radio licensing method will be considered
favorably.

Respectfully,

Robert Shrader
11911 Barnett Valley Road
Sebastopol, CA 95472
w6bnb@aol. corn