ARRL Proposal to Give Technicians More Operating Privileges

I did that, I only found you repeating the same two sources. I also noticed you did not mention 06-178 even once, why is that?

I'm not forcing you to reply. I'm merely curious on these "repeated" FCC comments you've mentioned.

I specifically asked you to post something other than another reference to the same 05-143 and TMRA. If you don't want to repeat yourself then stop doing it. The decision made in 05-143 was reversed in 06-178. When researching the TMRA petition I found the petition itself and some articles commenting on it being denied by the FCC, but not the entire FCC decision. If you can provide more evidence on how the FCC has decided on this in the past then I'd really like to read it. So far all you have done is repeat the same two data points, and leaving out a very important one in the middle, and extrapolating that out to a place that may not necessarily follow. You claim "repeated" denials from the FCC but I only saw one, that being from the TMRA petition, and even then the entire document was not made available and so the extent of this denial is unclear.

 

In the context, that is a nonsense request, since those rulings form an enormous portion of the FCC's current policy on the matter.

No, it wasn't. If you read the TMRA decision, it specifically lists principles from 05-143 as the basis for the TMRA rejection. You are misreading the case from 2006, and you are mischaracterizing the FCC's position on the entire matter by making it about whether Techs are HF-qualified.

Wait a few years, and you'll get to read where they repeat their position again in the future.

That's true. I should stop replying to people who refuse to do their homework. Have a nice holiday.

 

Well put. I'm usually less diplomatic about it, but it's frustrating to have a discussion with someone who doesn't research the issue well enough to present a coherent argument.

My opinion on the matter? The ARRL is trying to show it's usefulness by doing "something" whether it needs to be done or not. In the days where you had a deadline to upgrade or lose it, maybe it was an exersise worth trying. Now....... Meh.

Again, just my less than humble opinion. ;-}

 

I'd love to read it. Would you post a link for me?

I'm not asking you to do my homework for me, as you've claimed in the past. I'm asking you to cite your sources. You've repeatedly made quotations that were supposedly from the FCC but made no effort to allow readers to verify that, or look at it in context. It appears you've done your homework, which I can certainly appreciate, but if you cannot be bothered to show where you got your quotations then it's just hearsay. I'm not going to go looking for where you got those quotations since it is quite possible you just made them up.

To show I did my homework I'll post some links for you. Starting with what I believe to be the FCC decision on the TMRA petition from 2013 that you were referencing.
https://transition.fcc.gov/Daily_Releases/Daily_Business/2013/db1017/DA-13-2023A1.txt

Where in this document was there any mention of denying digital and phone privileges to Technician license holders on 80 and 40 meters? The topic never came up.

Also, there's beginning to be ample evidence of people preferring digital modes above all others. There's an interesting article on this.
https://g7vjr.org/2019/03/proportion-of-modes-used-on-the-air-2018-update/
And a chart.


I realize that there could be all kinds of things wrong with this chart. There's an inherent selection bias, this is a very small sample, etc. One thing I noted was that the use of phone and CW changed relatively smoothly over time, they didn't have the big "jump" like FT8 and "Other". My guess is that "Other" was just a stand-in for a number of digital modes that people were experimenting with. Once there was an obvious stand-out performer those that were scattered about all congregated to where everyone else was. A kind of network effect took place.

In doing my "homework" I noticed not only a large jump recently in digital mode usage on Amateur radio but also a tendency for the FCC to place considerable weight behind the comments they receive from the petitions they posted. The FCC did indeed deny requests for expanded Technician privileges from the flurry of petitions between WRC-03 and their 2007 decision that followed from it. That was because they saw no single petition gain any significant community support, and at the time they only wanted to focus on the matter of the Morse code testing requirement.

Does this mean the FCC will decide to implement this ARRL proposal? I don't know. It does mean that your claims that nothing changed is difficult to defend. I did some sampling of the comments submitted to the FCC on this petition and there does appear to be considerable support. There are many "opposition" comments concede that they would not be opposed to allowing digital modes in the existing Technician CW only bandwidth.

I'm simply not seeing how you can say with such confidence that the FCC will dismiss this petition without any actions. It's possible, but far from certain. I recall many years ago people stating with considerable confidence that the FCC would side with the ARRL and keep a Morse code testing requirement for Amateur Extra. They cited numerous previous FCC decisions to support their claim. I see plenty of parallels from then to now.

Here's my prediction, the FCC will do something with the Technician privileges. I don't know what that will be though. There's plenty of opposition to the expansion of phone privileges, and opposition to the phone privileges being SSB only. I do not expect the FCC to rubber stamp this petition as is. I expect them to modify it based on the comments received. They will consider quality of the argument over the quantity of those supporting the argument. Those opposing the SSB only restrictions make a good logical case. Those opposing the expansion make mostly an emotional case, effectively devoid of logic. But then FCC decisions aren't always logical.

 

All reasonable....but remember one thing: The easiest thing for FCC to do is.....nothing.

 

In many cases that is true. When a petition makes a very bad case, gets few comments submitted to them, or the comments submitted to them are largely in opposition, then it's easy to do nothing. As pointed out many times in this discussion this is not the first time the ARRL made a petition like this. Each time they make a new petition they modify it to address complaints from the Amateur radio community and comments made in the FCC decisions. In the past it would be safe to predict the FCC doing nothing. I don't know if that is a safe prediction any more.

Again I point to the growth in digital modes on HF and the growth in support for an update to Technician privileges. I don't believe the FCC can just ignore this one.

I have my theory on how the FCC views Amateur radio, I won't go into depth on it right now because the last couple times I did so I got a dozen replies on how wrong I was. With that in mind I see this relatively modest update to Technician privileges as something that would be in line with the goals of the FCC. I will say that part of my theory on how the FCC views Amateur radio is with a near disdain for CW. They will tolerate it, of course, but they will not encourage it. I believe that they will remove the CW only restriction for Technician HF privileges. This petition gives them cover for doing so. I'm sure other petitions in the past proposed removal of this CW only restriction but they were met with considerable resistance from the public and/or went too far beyond the FCC view on what Technician means to them.

 

All good points.

However I don't think FCC has a "near disdain" for CW. Rather, what I think they have a disdain for, is having to deal with proposals that are either not clearly thought out, or which get massive opposition in the comments and reply comments.

IMHO, here's what happened with CW testing.....

All the way back into the 1960s, the FCC had a big problem with 11 meter cb folks, "freebanders", "HFers", and the like. It was clear to FCC that many of these folks wanted some sort of "radio hobby", and were often willing to spend serious resources on it. So....why didn't they get amateur radio licenses?

The answer they usually got was "the code tests" - specifically, "why do I have to learn Morse Code in order to talk on the radio?"

The folks at FCC began to think that perhaps a no-code-test Amateur Radio license would draw people from 11 meters, "freeband" and "HF" and solve the FCC's problem. In the mid-1970s, FCC proposed a 7 class "dual ladder" license system that included a no-code-test VHF-and-up "Communicator" license. Opposition to it was widespread, and the proposal went nowhere......but FCC didn't forget. They noted that there was some support for the idea.

If FCC couldn't get rid of the code test, they could change it - so in 1978 the "waivered" the sending test, and soon after allowed the use of multiple-choice and fill-in-the-blank receiving tests, plus all sorts of "accommodations" to the receiving tests.

FCC tried to sell a no-code-test license in 1983 or so, and again met fierce opposition....but not as much as in the mid-1970s. This was the same time period when they created the VEC system and 10 year license terms, both of which saved them resources.

In 1989 or so, a Technician was in a ragchew QSO with a King who was a ham, using 10 meter 'phone. The band began to go out, and the King suggested they QSY to 15 or 20. The Technician explained that he couldn't do that; his license didn't give him any voice privileges below 28 MHz, and he couldn't get his code speed up to the required 13 wpm to upgrade. The QSO ended when the band faded, but the King thought about this, and the next time he was talking with president George H. W. Bush, told him the story and asked if anything could be done about the situation. President Bush wanted to do the King a favor, so he passed on a "request" to FCC. FCC responded by creating "medical waivers" for the 13 and 20 wpm code tests in 1990. They couldn't waiver 5 wpm because of the ITU-R treaty.

In that same time period, FCC tried once again to create a no-code-test. and this time they didn't take no for an answer. In 1991, the Technician lost its code test.

Meanwhile, FCC began to receive proposals to eliminate the code tests. An organization sprang up dedicated to eliminating all code testing for all amateur licenses everywhere. Finally FCC resolved to drastically simplify everything, reducing to 3 license classes (by attrition) and all but eliminating code testing. And they stated that the only reason they kept 5 wpm was the treaty.

When the treaty changed in 2003, FCC got about a dozen proposals, and it took almost 4 years to process all the proposals, comments, reply comments, and enact the end of code testing in the US amateur radio service.

IMHO, FCC is just plain tired of all that paperwork and complaining and proposals.

Or to put it another way:

"Mom doesn't want 'fair'. Mom wants QUIET!"

 

Dude, I already did. I even gave you the search terms to use to find more of the same in the forums.

The problem isn't with the citations I'm providing. The problem is that several of you don't accept the cited works as authoritative on the subject. No matter what FCC says, you're going to make it sound like something it isn't.

That's fine. We'll see you all in the thread immediately following their ruling (if it happens), and we can discuss it further then.

If you look at how that data is collected, I don't think it supports that specific conclusion -- at best, it supports the conclusion that digimodes are better suited towards electronic logging, which is rather obvious in context. When you have digimodes capable of fully-automatic operation, where the software runs for hours on end raking in contacts, you would expect a skew in Q count towards the digimodes.

But let's just say that digimodes are more popular. After all, in six months' time, I logged something like 10,200 contacts in FT8 alone, so I'm certainly helping the assumption.

Even if that's true, it changes nothing about ARRL's petition. Again, FCC were the ones who pointed out that they wanted digimodes (among other modes) to be an incentive for people to upgrade to the General class. That is, they wanted people to have to upgrade to obtain the privileges to emit those modes. If digimodes really are that much popular today than they were in 2005 or 2013, then it just means that FCC is better off leaving things the way they are if they want to continue that incentive, because the (allegedly) more popular modes are on the high side of the General upgrade path.

If you look at it from their perspective (the one they publicly documented, anyway), the case you are making just encourages them to keep the status quo.

So by all means, keep it up.

 

Thank you.

I'm not claiming they always had this distaste for CW, it was developed gradually over time.

As I understand it this story could not be verified, but also does not contradict my own theories.

Yes, indeed, the FCC wasn't going to take no for an answer and my theories see correlation between the dates you gave on the FCC proposing the elimination of Morse code for Amateur radio and the development of GMDSS. This is what got me in "trouble" before as people thought I meant to imply that the only reason Amateur radio exists is as a training ground for future maritime radio operators. I'm not saying that is the only reason Amateur radio exists. I am saying that the FCC looks at industry trends and wants to see Amateur radio keep pace with them.

I'll highlight a few dates from the Wikipedia page on GMDSS history. In 1979 the groundwork was laid for GMDSS development and use. In 1988 ships were required to carry some GMDSS equipment. By 1999 ships were no longer required to carry any radiotelegraph equipment.

To the FCC the Amateur radio service is, in part, a pool of trained radio operators from which industry can draw. The FCC sees no need to encourage CW use, and this has been building since they ended the commercial aircraft radiotelegraph endorsement sometime in the 1960s. As industry reduced it's need for trained Morse code operators the FCC reduced the testing requirements for Amateur radio operators.

I agree. The FCC does appear to see a need to keep the Amateur radio community happy, because otherwise they make a lot of noise. They must serve other masters though, those include the commercial and military sectors. You seem to agree that the FCC did in fact see a need to reduce Morse code testing through the years. Even so they kept the 20 WPM testing for Extra up until 1990, when the medical waivers started. They could have simply reduced all Morse code testing to 5 WPM then, but they didn't. They apparently saw a need to maintain this pool of people that were trained in Morse code at a speed sufficient to be considered eligible for commercial licensing. A presidential request for such a waiver on behalf of a foreign king and ham radio operator may have sped this process along, but that was still a process in the works since the 1950s when aircraft started using radio teletype and radiofax equipment.

The HF CW only bandwidth for Technician is an old artifact of this demand by the industry for Morse code trained radio operators. The FCC got push back from the Amateur radio community before on the elimination of this CW only bandwidth. I believe that there will be a point that the FCC simply will not take no for an answer, just like before. That point, I believe, will come soon.

 

"Search terms"? Whatever. Lots of things come up in search terms, much of which is not relevant. This makes me think you are trying to hide your own lack of research in the topic.

Oh, I see. I;m not reaching the same conclusion because I'm not "doing my homework". If my laziness bothers you so much then why bother replying to me? You know that will only prompt me to respond.

I laid out how I see it from the FCC perspective in my reply above to @N2EY. The FCC spelled out the basis and purpose of the Amateur Radio Service in the federal regulations. That includes providing a pool of trained radio operators from which industry can draw. Encouraged use of CW does not meet that need when the number of trained Morse code operators needed by government, industry, and military users numbers in the dozens per year. What they do need in far larger quantity are people that can operate radios that do voice, data, and image modes.

 

No, I gave you very specific search criteria that would give you posts by me that were on-topic, with references to specific Commission documents. That you haven't used them just reinforces that you are just talking, and not doing any research.

Mostly.

Honestly, I kind of enjoy watching people argue nonsense based on their deliberate ignorant of the plain-language facts. It's a side-hobby, really.

 

That sword cuts both ways, you know that don't you? I laid out my "homework" on why the FCC has little concern for maintaining any semblance of a CW knowledge requirement and since you disagree then therefore you have not done your homework. If you don't agree with me then you do so out of ignorance.

 

...a subject that is irrelevant to the proposal being discussed.

LOL!

 

I missed these points before...

So the FCC should... excuse me, will, keep these HF Technician bands as CW only precisely because it encourages digital mode use? Wow, that's some tortured and fevered logic. Speaking of fevered logic, are you feeling okay?

I see, you don't actually believe that the FCC will keep the status quo, you just want to argue for the sake of argument. Well played.

 

Perhaps to you. It made perfect sense to FCC when they explained that -- in detail -- in the passages I cited from their orders. They want people to have a reason to upgrade, and upgrading to obtain the authority to use new modes is part of what they see as significant incentive. They mentioned that very specifically.

If you disagree, that's fine, but that puts you at odds with their stated reasoning.