I would appreciate any comments you might have regarding the following. . .
Federal Communications Commission
1919 M Street N.W.
Washington DC 20554
RE: WT Docket No. 98-143 1998
I am writing to comment on FCC NPRM WT Docket No. 98-143 1998. My comments
come from the perspective of an Amateur Radio operator for over 20 years and
an instructor for the past 4 years. I have participated in teaching 4 classes,
three of which I led. In the last class that I taught, only one student who
completed the class failed to pass a test and obtain an amateur license. Of
the other students in the class, all of which were new to amateur radio, all
passed a code test-one at 5 WPM, one at 20 WPM, and the rest at 13 WPM; one
became a novice, one became a General, and the rest all became Technician
Basically, I approve and applaud the ARRL's latest comments and proposals in
response to the above referenced FCC NPRM. I will not comment item by item but
rather mention my two concerns:
¨ First, the lesser concern, I understand the concern about reducing
privileges. Never-the-less, I believe that the Technician class license should
have a reduction of privileges-specifically, maximum power of 50 W on all
authorized bands, and restriction from owning and operating a repeater. I
believe that this would be an important protection for an "Entry level"
license and also an incentive to upgrade. But as an alternative, read on.
¨ Second, the greater concern, I wish to take some exception to the following
statement in the NPRM, "We believe that the no-code Technician Class operator
license has replaced the Novice Class operator license as the entry-level
license class of choice. Therefore, we tentatively conclude that the Novice
Class operator license no longer serves a significant, useful purpose and
should be phased out, with the current holders of Novice Class operator
licenses being grandfathered." In response, please note the following:
· As an instructor I believe that the FCC proposal, and indeed the ARRL
proposal, both, fail to recognize several factors in appealing to young people
to enter the ranks of Amateur Radio and thus lead them into the great
challenge and pursuit of technology. I recognize that presently few people are
entering the amateur ranks through the Novice license. Yet I believe that the
Technician license is too high an entry point for many young people to whom we
should be appealing.
· I believe the reason the Novice class license has fallen into disuse is
simple: The attractiveness of an "easy" path - No-Code license. The promotion
of this "easy" path has muted the efforts of those who may have accepted the
code requirement. My experience may illustrate the point. In the first class,
in which I was involved as an instructor, my instructor/partner did not
enthusiastically present the code and provided an easy "no-code" alternative.
Few pursued the code and the code lesson time became a drag on the class. Few
would work for the code and a Novice license and some dropped out when we
moved into the tougher technical material for the Technician class license. In
the end-NO ONE passed the Morse code requirement. On the other hand, in more
recent classes, I have presented the code enthusiastically and in the case of
only one student have I not had a student pass at least 5 WPM. (In the most
recent class, one young man of Jr. High age, passed 20 WPM!!!)
· I believe that the bar of the Technician license will be too high for some
promising young people. If we wait until young people are able to learn and
deal with the material currently required in the Technician pool of questions
they will be at a point in their life socially and educationally where the
beat of different drummers will drown out the "rhythm of the code" of amateur
radio. We must catch them before they are "too busy" with other things.
· The immediacy of VHF communications, small equipment, small antennas, use of
repeaters and phone patches, etc. make VHF privileges attractive for first
time amateurs and detract from pursuing HF privileges that require Morse code
· Morse Code is most easily taught to young people. I believe in this mode and
I believe in the discipline required to learn the code as valuable preparation
for those who would pursue the Amateur Service. Studies of language study
(Morse code is a language) demonstrate that children learn languages much more
easily than adults and that those who have learned a language by about the age
of puberty develop the ability to learn other languages more easily later in
life. It only makes sense to appeal to young people to pursue amateur radio
early before learning Morse code becomes more difficult later. Besides, young
people find the code fascinating (if presented positively) rather than onerous
as most adults seem to do.
· As I have said, I recognize that presently few are entering the amateur
ranks through the Novice class. However, this is a failure on the part of the
Amateur community in some places to appeal to these younger potential
amateurs. This is an indictment on the Amateur community not on the licensing
structure. Please do not take away from me the best tool that I have to entice
young people into Amateur Radio.
In light of the above discussion, I would propose the following:
¨ An entry level license (with a Morse code option): Neophyte NC and Neophyte
C, replacing the present Novice, Technician, and Technician Plus licenses:
· Neophyte NC-This license would require passing what is essentially the
Novice Question Pool technical, operating and rules issues and Technician
Question Pool operating and rules issues (not Technician technical). The
privileges would include the present Technician VHF privileges limited to 50
· Neophyte C-This license would require passing what is essentially the Novice
Question Pool technical, operating and rules issues and Technician Question
Pool operating and rules issues (not Technician technical) and Morse Code at 5
WPM. The privileges would include the present Novice HF privileges and the
present Technician VHF privileges limited to 50 watts.
¨ A General class license (with a Morse code option) defined and testing to be
· General NC and General C roughly corresponding to the Neophyte C and
Neophyte NC class
· General Class question pool fall somewhere midway between Neophyte (present
Novice) question pool and Advanced test pool questions.
· The difference between General C and General NC is the code requirement as
proposed by the ARRL proposal where: General NC would not have a code testing
requirement and would have use of the HF bands by CW only and General C would
have a code testing requirement at 5 WPM and would have use of the HF bands as
all present General Class licensees do now.
¨ Present licenses be grandfathered as follows:
· Present Novice class licensees become Neophyte class C
· Present Technician class licensees become General class NC as proposed by
the ARRL for the Technician class with self limiting code privileges in the HF
· Present Technician Plus class licensees become General Class C in keeping
with the ARRL proposal for General Class
· Present General class licensees become General class C
¨ Adoption of the balance of the ARRL proposal regarding
· Advanced, Extra Class testing
· Advanced, Extra Class privileges
· CW requirements and privileges adapted to fit the above proposals
By in large, I believe that the ARRL proposal, as most recently presented, is
very good except for my great concern about appealing to younger people. I
recognize that the FCC is seeking to reduce the number of classes of license.
I realize that my proposal seems to run away from that. On the other hand I do
not think that may be as true as might seem to be the case. My proposal is for
four classes: Neophyte, General, Advanced, and Extra. Since the No Code tack
has been taken, I have attempted to preserve that tack while providing for a
true entry level license. The result is two tracks for both the Neophyte and
General class licenses. Written testing would be for four classes of license
only. Code requirements would be the variation of tracks and privileges within
the first two classes.
I realize my comments are not comprehensive, not dealing with the entire NPRM.
I am narrowly concerned and have addressed only the matters of concern to me.
My great concern is the preservation of a true entry level license which would
be obtainable for young people before they reach the highly active schedules
of high school, and sometimes even junior high, students.
I trust that I have effectively communicated my thoughts and hope that my
comments, though embryonic, are helpful in your deliberations. I am hopeful
that this presentation will stimulate some discussions and ideas that will
effectively address my concerns for an entry level class for young people.
Leonard W. Budd
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