Okay, come up with a new license structure, justify why it's a good idea, and write an FCC petition. You only have to convince the FCC it's a great idea, will reduce their administrative workload, it's in the public interest, and will benefit the amateur service as a whole. Simple? Be ready to fight the arrl for starters and do some historical research on what happened when the old A, B, C licenses were replaced with "incentive" licensing. If you have 10 or so years to waste on the project it might get a hearing. You should also consider convincing current licensees to back it before submission, strength in numbers goes a long way, but it's like herding cats.
The answer to this question is for the FCC to provide expanded statistics showing upgrades from one license to the next in their daily/monthly/annual figures.
What makes you think I haven't been working on a new license structure? Rather than go through what I have been doing in getting a new license structure I'd like to ask a few questions of those that believe nothing is wrong. Roughly every decade since the end of World War 2, when the FCC re-opened Amateur radio to start transmitting again from the wartime ban, they've made some changes to Amateur radio licensing. Some changes have been bigger than others. It's been nearly 15 years since the last change, and that was only a few years after making a much larger change. The question I have is, just how long should we expect the FCC to do nothing? I believe this is a worthwhile question because at the time of the last two changes the FCC made plenty of hints on changes to come. When the number of license classes was halved from six to three then FCC made hints that they expected people in the grandfathered license classes to upgrade fairly quickly. It was, after all, an incentive license structure and so there should have been an incentive to upgrade. How well has that worked? There must be some rules that the FCC follows on the role that Amateur radio fills. Not all of these rules are necessarily written down for all to see. When it comes to fulfilling the role of encouraging the advancement of the radio art how does the current licensing fulfill that? I'm thinking that when it comes to Amateur radio being a means of providing emergency communications that it fails miserably when more than half of those licensed are only minimally equipped (in both skillset and hardware) to operate on HF. I believe that the status quo will not last. The FCC set things in motion on modernizing Amateur radio licensing a long time ago. They tolerated a lot of BS from the Amateur radio community through the decades, especially when it came to Morse code testing. They tried to get a "no code" license since the 1960s but the Amateur radio community revolted. They gave up on getting "permission" from licensed Amateurs in 1990. This was then doubled down on in 2000, and made it about as clear as could be in 2007 that they did not care about Morse code knowledge among licensed Amateurs. Incentive licensing died sometime around 1985, or at least how incentive licensing was envisioned in the 1950s and 1960s. They tried real hard to get people interested in operating above 30 MHz. It worked. Now it's working so well that few bother to get licensed to operate below 30 MHz. So, again, how long does everyone expect the FCC to do nothing about Amateur radio licensing? I believe that expecting the FCC to cater to the whims of those that wish to be buried with their Advanced and Novice licenses will not continue for much longer. How will the FCC act on this? If their actions on commercial licensing is any guide then it's that Advanced will renew as General and Novice will not be allowed to renew at all. This will likely come with other changes. The ARRL and others have already given the FCC enough to work with over the years on making the case for some changes. The FCC has also dropped plenty of hints on where they want to go. What I've been begging for people to do, and pleading for people to do, is not go back to battle over ground already lost. The FCC is not going to bring back Morse code testing. What they might do though is allow for an endorsement on the license stating Morse code proficiency. Make a case on how this is needed to comply with IARP reciprocal licensing since Brazil still has a Morse code proficiency requirement. What I'm also seeing a lot in comments submitted to the FCC with every petition opened for comment is endless Technician bashing. The FCC is not going to make any changes to the written testing, that's the responsibility of the VECs and the question pool committee. If there's something that needs to be fixed then be very specific on how to fix it or the FCC will simply ignore it. If you want more question on the exam then say specifically how many there needs to be. If the Technician grants too much in privileges then be specific on where that is. This gets into any proposed changes to Technician privileges, the FCC has stated over and over again that they will be very reluctant to make changes to the privileges of any existing class of license. I believe it would be far easier for the FCC to justify a new license class to replace Technician than to try to fix whatever anyone believes is wrong with Technician. There's going to be people that will exclaim loudly that nothing needs to be changed. Again, just how long does everyone expect the FCC to do nothing? There are people feeding the FCC ideas on changing the licensing, and with each proposal and every passing year it's harder to maintain the status quo on this. I believe the "nothing's wrong" crowd needs to stop screaming about how nothing is wrong long enough to think about what is right. Think about what is important to you in the current licensing and fight to keep it. You cannot just say everything is equally important in keeping the same, that will not stand when there's another group saying something has to go. One more time, how long does everyone expect the FCC to do nothing about Amateur radio licensing? There will be changes coming. You can let the FCC know what you believe is important to keep or claim everything is equally important, which means that everything is equally unimportant.
That does not show how effective incentive licensing is today because it says nothing about the goals incentive licensing is supposed to achieve. Without a stated goal behind incentive licensing then there is no means to measure the effectiveness. Stating that the goal is to get people to upgrade is nonsense because there is still the matter of why the FCC should care if people upgrade. The goals should give guidance in how the question pools are constructed at a minimum. As stated over and over again by the critics there's a simple means by which to increase the rate of upgrades, simplify the testing to the point that it's little more than a giveaway. Claiming that the basis and purpose from Part 97.1 provides guidance is nonsense, it's far too broad to give any meaningful measure of the success of incentive licensing.
Of course it provides information on how effective incentive licensing is. It does not provide TOTAL knowledge about effectiveness. Still, more information is helpful. You wander off into absurdity in service to your disdain for the present license structure and the proposals. -No, the FCC does not have to set upgrade goals or attempt to actively manage them. The FAA has similar license structures, and does not have goals for license upgrades nor attempt to force or manage them.
Great!! It's a start. As a suggestion check out the countries with the top ten number of licensed amateurs, specifically license structure and privileges offered for each class of license. Try the list at N0HR Japan must be doing something right with their numbers, it might be interesting to get a breakdown by license class for JA hams. The top 10 on the N0HR list are a fair representation of all 3 I ARU regions.
Yes, more information would be helpful but with the grandfathering of Advanced and Novice we have some indication without having to dig too deep. We see nearly 40% of Advanced and nearly 20% of Novice license holders failing to upgrade in 20 years. That indicates incentives are failing. Another indication is that 20 years ago Technician/Technician-Plus made up about 50% of the licensed Amateur population, and today this is still the case. It appears that reducing then eliminating the Morse code testing did not incentivize people to upgrade. The population of those with Extra doubled in this time while the total numbers of licenses increased by about 20%, so there's that. I'm not sure you understand what I mean by "setting goals". I don't mean goals as in, "We expect 20% to upgrade to Extra in 20 years." I mean goals as in, "We expect licensed Amateurs to be prepared to offer emergency communications when and where needed." In both cases there is some expectation of licensed Amateurs to improve their skills over time. This should translate into people upgrading as access to HF frequencies will be important, if not vital, in being effective communicators in emergencies. As I understand incentive licensing the "carrot" was greater access to HF frequencies, and passing the knowledge exams was the "stick" to beat this information into them. I believe that during the Cold War the FCC was using the Amateur radio incentive licensing to create a pool of trained radio telegraph operators in case of another global scale war. This was important for national security up until the year 1996, that being the last year ships were required to have trained telegraph operators for keeping watch on the radio for distress calls. This meant that while the FCC was free to issue Amateur radio licenses for passing a 5 WPM Morse code test they set the Morse code proficiency for Extra at 20 WPM. 20 WPM was the required minimum for commercial and military radio operators. This was vital for national security as it took the military months to train new recruits to operate at 20 WPM, and in wartime that may as well be a decade. This doesn't mean someone with an Amateur Extra would be employed as a military or commercial radio operator with no additional testing or training. It means that instead of training that might last 2, 4, or even 6 months that instead it would be weeks of training. So, what's the goal now? No doubt the FCC still sees licensed Amateur radio operators as a pool of people from which to draw on short notice for training as commercial radio operators. Is the Technician license supposed to be roughly equivalent to the commercial MROP? And is Extra a pool for future GROL license holders in a time of war? You are correct that the FAA doesn't have to set goals on upgrades to higher classes of licenses. The FAA also never had a policy of incentive licensing. There was a goal behind incentive licensing. Whether or not the FCC stated it publicly it's quite clear that they wanted to see people learn Morse code during the Cold War, and reach a level of proficiency in Morse code to the level of commercial and military radio operators. If that wasn't the goal then why have the Morse code proficiency for Extra be the same as that for commercial radio operators? Why would the FCC grant Morse code credit towards the commercial radiotelegraph license for people that held the Amateur Extra license? A policy that obviously ended when they started offering medical waivers for Morse code in 1990. There was a goal for incentive licensing in the past. What's the goal now? If there is no goal then why maintain the policy of keeping incentive licensing? The FCC appears to still have an interest in incentive licensing, why is that?
I disagree with your premise that an earlier FCC policy somehow needs to be be "maintained," as if pursued with vigor and resources until something replaces it. Incentive licensing is a previous approach toward the recruitment and retention of licensees. There is no compelling need for the policy to justify itself in order to remain on the books. It can just be there, passively, as we have seen in the absence of any stated intention to have something, anything, replace it. There are many, many examples in the FCC's world today of prior policy, practice and regulatory structure outmoded by design, communications changes, and shifts in business. One that I happen to think of every summer, right now, out on the boat, is the wasted set of VHF-FM "marine" radio channels that had been used with land-based marine operators to connect vessels with the conventional telephone system. These channels presently could be re-purposed for a variety of local water activities, such as repeater coverage, or, with a transition by radio manufacturers, to additional simplex channels that would provide a more generous choice of those available for casual, boat-to-boat communications.
Every policy should be justifiable if challenged or we have a government made of arbitrary nonsense. The ARRL, and others, have challenged the FCC on the arbitrary nature of the current licensing. In a functioning republic the FCC would then be obligated to justify the rules as they are or change them to be less arbitrary. That's one example of rules that made sense earlier but are now rather arbitrary. If the FCC is challenged on this then I expect the FCC to defend the rules or change them. Much like with challenges in the past to make changes to Amateur radio licensing the proposed changes need to be justified to not become just another arbitrary rule. The status quo rules and so an unsuccessful challenge will likely mean nothing changes. If these marine VHF channels could be put to better use then someone needs to come up with a logical plan to do so and make that case to the FCC or nothing changes. The FCC maintained in the past that they want to keep incentive licensing for Amateur radio. What I'm not seeing is a description on what is being incentivized and how the current licensing is supposed to get there. So, again, status quo rules but the public and the courts are not fond of arbitrary rules. The FCC is obligated to have logical rules. Arbitrary FCC rules can be challenged by petitions to the FCC, and any failure for a satisfactory response can be taken to the courts. There is going to be some debate on how the ARRL plan is any less arbitrary, as well as any other proposal that comes along, and if a good case is made then the FCC can be expected to act on it. There appears to be the impression that this ARRL proposal is little more than change for the sake of change, and I believe it is not. If it is just change for the sake of change then it's just as arbitrary as the rules are already and that means status quo rules and the FCC is not obligated to do anything. If the changes are logical and not simply something arbitrary then that doesn't mean the FCC is obligated to take it as it is. The FCC is free to take parts of this proposal, parts of any other proposal, and parts of the status quo.
Actually, that credit for Morse testing was not even implemented until 1998, and it continues to this day. The rule was last changed so that a current or expired Extra license would get you element 1 and 2 (of the commercial radiotelegraph tests), but only if the license was issued previous to April 15, 2000. It appears, from looking at the rule revisions, that it might have been possible to get the commercial telegraphy credit for a license issued between April 15, 2000 until somewhat after April 25, 2001, which would mean that the applicants tested in that time period only had to provide a minimum 5 wpm amateur testing credit to get a 20 wpm commercial testing credit. At least the rule was worded like that, from what I can tell. Perhaps the FCC did a directive to test givers that did not provide that credit, I don't know.
Screw it.....let's give everyone a participation trophy forget knowledge, goals, achievements, or working for something worthwhile Do away with all incentives let every freq become 14.313
Why would you assume that every frequency would become like 14.313? Are the people now inhabiting that spectrum new to the hobby? Have they not taken the proper tests? What makes you equate some sort of minor test as some sort of major accomplishment? Technicians have already qualified for every mode at up to 1500 watts of power. They have already qualified for 200 watts of RF on HF. What qualification do they lack to be able to operate SSB or digital at 200 watts on 80M and 40M?
