Testing a quote of lots of formatted text

AC0GT · Feb 24, 2020

Does formatting copy/paste? How long of text can I past in?

The following is a draft proposal for changes to the Amateur radio licensing. Even though I'll be using the first person plural in this proposal so far it's just me writing this, hopefully I'll gain support from others with similar concerns. The intended audience for this will be the FCC but as with any proposal of this kind it will be more than the FCC reading this and needing convincing of the changes proposed. To this end I'm wording in a way such that hopefully could be taken as a proposal to the FCC largely unmodified or as something suitable for gathering support from the Amateur radio community. - Kurt AC0GT

It has come to our attention from a number of proposals to the FCC that there is a desire among the Amateur radio community to make changes to the current license structure. The specifics may vary but the general theme appears to be a concern on the large portion of licensed Amateurs not upgrading their license, even after many decades of holding their license under incentive licensing. In order to address this has been attempts to shore up the incentive to upgrade, we believe this to be misguided. The primary means of incentivizing upgrade, perhaps the only real means of incentivizing upgrades thus far, is access to HF privileges. It should be apparent that this does not hold the same incentive that it used to. Trying to find a new incentive is likely to be a fool's errand as not everything will hold the same incentive to everyone. So long as there is a tiered license structure, with increased privileges after further testing for these privileges, there will be an inherent incentive as there will be people seeking whatever privileges those might be.

There is an apparent reluctance with both the Amateur radio community and with the FCC to create another class of license. This is a reluctance we can understand but feel is unavoidable. What should be apparent from comments posted in response to RM-11828 is that any changes in privileges will be met with resistance by the Amateur radio community. RM-11828 is a proposal from the ARRL to make changes to the privileges granted by the Technician license, changes that the ARRL hopes will incentivize the growing population of people with a Technician license to upgrade. While we can agree with the ARRL on many of the changes they propose the disagreement is on this being effective in producing an incentive to upgrade among large numbers of those holding a Technician license.

There''s a number of comments on RM-11828 with concerns that the changes ARRL proposed will not increase the desire to upgrade but will instead diminish it. We do not agree with this concern. So long as there is another tier of license above that of General there will still be an incentive to upgrade. Even if the proposed changes were to make Technician privileges identical to that of General the incentive to upgrade to Extra would remain unchanged. With no new Advanced licenses issued since the year 2000 the numbers are obviously diminishing every year, but it appears this is not from people upgrading. There was a rush of people with an Advanced license upgrading after the license restructuring in 2000 but since then there does not appear to be much of an incentive to upgrade. There is still growth in the number of people upgrading to General but the rate of upgrades to Extra is greater. It appears to us that the only incentive to get a General license today is that it is the path to Extra.

We believe that this problem of people not upgrading their license exists at every level, with the primary evidence of this being the fairly large number of people retaining their Advanced and Novice licenses even after two decades of them no longer being issued. After this initial surge of upgrades after the 2000 restructuring there is still nearly half of those with an Advanced license then that have retained this level of license to today. The reasons from those willing to comment on why they have not upgraded varies, and therefore it will take more than any single change to the licensing to address every lack of incentive and disincentive that there is to upgrading. These reasons are not unique to the Advanced license, only that the incentive to retain this license is most apparent with a class of license with so many privileges in Amateur radio and with no new licenses of this type issued for so long. This same lack of incentive to upgrade can be found in those holding Novice, Technician, and General licenses. What we will propose is a new licensing structure that we believe will address this lack of incentive where it is possible as well as provide for a means to simplify the license structure and provide other benefits.

What is being proposed here should not be considered as all or nothing proposal, instead it should be considered as a series of proposals that could each stand on their own. At the core though is two changes to Amateur radio licensing that the other changes build upon. The first change proposed is to create the concept of endorsements on a a single operator's license where both commercial and Amateur endorsements will be placed. This is not all that different than with a commercial FCC license getting endorsements which grant additional operating privileges. The difference is that there would be a single FCC license document and database entry which will contain endorsements for operation on commercial and Amateur frequencies. This is not vital to implementing the other changes proposed but we believe that this will make several goals we wish to achieve easier to reach and enforce.

The second core proposal is for a new license class, or endorsement to a license, which we will call Amateur Basic. This is a license that will replace both the current General and Technician licenses. If this new license is adopted then there would be only two Amateur radio licenses open for new issue, Amateur Basic and the existing Amateur Extra. What we see from the ARRL proposal in RM-11828 is expanded HF privileges for Technician license holders, this is proposed with the expectation that with more access to HF in a first tier license that this exposure will lead to more people upgrading their license. The primary opposition to this expansion of Technician operating privileges is that this is too much too soon, that someone with a Technician license should not be given so much with so little testing and experience. We believe both arguments have merit. In fact we will take this lack of testing and experience a bit further and state we believe that the Technician license as it exists today grants too much too soon. We will discuss this further after summarizing the other changes we propose.

What we have seen in how other nations license Amateur radio operators is that there is only two classes of license. What has been seen in comments from the FCC in the past, as well as from licensed Amateurs making comments to the FCC, is a desire to keep a three tiered license structure. We do not see the need for three classes of license but in order to improve the chances of the other changes being proposed we will make a proposal on what this third license should look like if this is deemed necessary to meet the goals of the FCC and the Amateur radio community. We propose calling this license Amateur Restricted and have it modeled after the UK Foundation license, and on the grandfathered Novice license. What we prefer is a two tiered license structure which is popular in many nations in which licensed Amateurs in the USA will be communicating with and seeking reciprocal privileges from. While the FCC is not required in any way to model their Amateur licensing after that of other nations we believe having as much harmony as possible with other nations will aid in minimizing difficulty in maintaining goodwill with other nations, especially that with our neighbor Canada on which our proposal borrowed from heavily in crafting this proposal.

One matter that appears to create a disincentive for some in upgrading is the lack of any means to have Morse code knowledge indicated on their license. This is a concern among some licensed Amateurs because there are still many nations that will require passing a Morse code exam for gaining operating privileges under a reciprocity agreement. If these people were to upgrade then they risk losing privileges and once the license has changed there is no going back. To resolve this, and other disincentives many see in upgrading, we propose a Morse code endorsement be available to licensed Amateur radio operators. This goes along with the more generic endorsement proposal given earlier. This Morse code endorsement would not grant any privileges to FCC licensed Amateur radio operators in the USA. This endorsement is only to comply with international reciprocity agreements where it states that testing for Morse code knowledge needs to appear on the license issued by the FCC. Some nations will allow for indication of Morse code knowledge by other means but by having this on the license there is all doubt removed of it being accepted. We will go into this in more detail later in this proposal.

While this might not be a matter of great concern in proposals filed with the FCC in the past we believe that there would be value in having a portion of the questions on the Element 2 written exam be pulled from the same question pool as that used for commercial licenses. Even if there is a single license, the Amateur Basic license, to replace both Technician and General we propose keeping the Element 2 and Element 3 exams separate. One recurring complaint seen in comments filed with the FCC when the issue of changes to Amateur radio licensing is proposed is how little material is covered to get a license, and how inexperienced operators of any class are lacking knowledge that experienced operators deem critical. One means to address this is to grow the size of both Element 2 and Element 3 exams to 50 questions each. This increase in the number of questions will be a common theme in this proposal regardless if questions on Element 2 come from the commercial license pool. By drawing questions from the commercial license question pool there would be an enforced continuity between the knowledge of commercial radio operators and Amateur ration operators. Matters of good operating procedure on the radio are the same for both commercial and Amateur radio operators, this continuity between services would be especially critical in emergencies where a commercial radio operator might need to use Amateur radio frequencies to summon assistance, or a licensed Amateur finds only a radio certified for commercial use available. Also unchanged are technical matters based in physics, such as Ohm's law, radio propagation, good antenna design and placement, and so forth. What will be discussed later in this proposal is which questions on Element 2 exam questions would come from the commercial licensing question pools and the effect this might have on the other changes proposed in this document.

A recurring theme of a number of proposals and comments to the FCC is to return to a non-renewable license for the first tier license, which was once done with the Novice license but applied to Technician. Those making this proposal believe this necessary to drive people to upgrade from Technician or whatever may be the first tier license under their proposal. We believe that this problem of licensed Amateurs not upgrading exists at every license tier, not just at the Technician and Novice level. Again, this should be evident given the large portion of people retaining their Advanced license for 20 years after any new license in this class has been issued. We have no doubt that if one were to perform a close analysis of the FCC database that this would be true of other classes of licenses. We can understand the logistical problems making every license class non-renewable would cause so this is not what is being proposed. The Amateur Extra license would be renewable, all others would be allowed a limited number of renewals before an operator would be required to take a test to upgrade or retain their license. Unlike the policy in the past of radio operators being allowed to hold the Novice license only once in their life we propose that any radio operator could test for the same license if it is still being issued. For grandfathered licenses those that have already met the allowable limit of renewals would have to take a test for whatever license is issued at the time, with exam credit given based on the class of their license held at the time. What we propose is that exam credit alone from a previous license would be insufficient to obtain a new license, the applicant would have to pass at least one written test to remain licensed. If incentive licensing is to remain a policy with FCC licensing of Amateur radio operators then we believe it should be based on an "up or out" model rather than holding back desirable privileges in the hope this drives people to upgrade on their own. By allowing for a single renewal of Advanced, General, or Amateur Basic this allows an operator 20 years upon which to learn the material needed to upgrade to Extra, which should be more than sufficient. Even then this is not locking anyone out of any currently issued license, like what was down with the old model of the "one and done" Novice license. Applicants would still be allowed to retain the same or similar license by retesting. This proposal is not dependent on any other proposal and has benefits of clearing the FCC database of long grandfathered licenses, and creating an incentive to upgrade that appears to have been lost, even if no other proposals given here are adopted. More detail on how testing credit would be applied will be discussed as appropriate within the discussions of other proposed changes.

With a summary of each change proposed given we will move on to giving each more detail.

AMATEUR BASIC LICENSE

This proposal for a new Amateur Basic license class to replace the existing Technician and General licenses should be considered the primary intention of this proposal document. Even though the adoption of a new class of license is the primary goal the refusal to adopt this should not be cause to refuse any other changes proposed in this document. The intended goal with the creation of a new license class is to satisfy a number of groups calling for changes to the licensing for the first tier license in Amateur radio. There's those calling for the elimination of the Technician license, making the General license the license which new applicants would enter the hobby. The reasoning is that the Technician license offers too many privileges for the testing that is required. We believe that there is some merit to this. There are those wanting to expand privileges to the Technician license, granting more privileges on HF, in order to incentivize people to upgrade by giving a "taste" of phone and digital modes rather than the CW only privileges that Technician has currently. We believe that if those with a Technician license has been tested on safe and proper operation on a portion of any given HF band then this should apply to the entirety of the band. The laws of physics do not change from one end of any band to another, and the means of operating safely and courteously do not change either. We fully support the changes proposed under RM-11828 and will go further, the band privileges for Technician on 80, 40, and 15 meters should be expanded to that of the next tier license but power output limitations remain as they are at 200 watts.

Rather than dwell on the changes to Technician we believe a more productive change is to create a new license. A license with more material covered in the testing but with privileges in some ways below that of General. We believe that not only is the privileges granted to Technician too much too soon but this is also true for General. In the interest of not removing substantial privileges from those upgrading from Novice or Technician we will define the RF power output limits at 1500 watts above 30 MHz and 200 watts below 30 MHz, excepting of course cases where limits are defined lower elsewhere in FCC rules. We believe that the RF output limits should be lower until one has reached the level of Amateur Extra but in the interest of reducing any opposition this is somewhere we are willing to compromise.

In the interest of simplifying the Amateur radio band plan the frequencies one with an Amateur Basic license would be the entirety of all frequencies available to the Amateur radio service, excepting those deemed "experimental" currently, access to these frequencies would be held back until an operator upgrades to Amateur Extra. Other privileges held back until one upgrades is the ability to be a Volunteer Examiner and to be the control operator of a repeater. While the inability to be a control operator on a repeater can mean a loss of privileges for someone coming from a Technician license this is something that can be regained with an upgrade.

Some nations will restrict the first tier Amateur license from operating a self built transmitter, this is not what we will propose here even though we are taking the lead from other nations here in guiding privileges granted. We feel this is a reasonable restriction if there is to be a class of license below that of Amateur Basic. We will go into this with the description of the Amateur Restricted license later.

One recurring complaint of current testing for licensed Amateurs is that it does not cover enough material, leading to people on the air not knowing how to properly operate and maintain their radio. In order to address this complaint we propose that the Element 2 and Element 3 exams be kept separate even though passing both would be required to obtain an Amateur Basic license. The proposal is that the Element 2 exam be expanded to 50 questions and primarily cover matters of proper on air behavior, and the Element 3 exam also be expanded to 50 questions but cover primarily technical details. Even though the intention is to have Element 2 cover primarily proper operation on the radio there would still have to be matters of a technical nature covered. One example is that in order to understand that RF power output would be limited the radio operator would have to know how power is defined and measured.

One point that may prove difficult in this new license is how to properly manage the transition from the current licensing to the new. The licensing is different enough that Amateur Basic is is some ways higher than Advanced and General but lower in others. To manage this in what is hoped to be the most equitable manner is to continue to allow those with an Advanced or General license to upgrade to Extra by passing the Element 4 exam. In accordance with FCC policy that no one can proctor an exam that they have not passed themselves those with Advanced or General would be allowed to proctor the exams for Amateur Basic, this would be reserved for Amateur Extra. It would be placed on the VECs to assure all VEs understand the material in the exams. Element 2 and Element 3 credit would only apply if upgrading to Extra, otherwise those with an Advanced or General would start with Element 2 before being allowed to sit for the Element 3 exam. Those with Technician or Novice would have no credit for any new written exam.

AMATEUR RESTRICTED LICENSE

The existence of any license below Amateur Basic is not being proposed here but in the interest of keeping this left an open question on what would be the first tier license if there is a desire for continuing a three tiered license structure we will cover our vision of what that would look like instead of keeping the Technician and replacing the General with Amateur Basic.

Privileges for the Amateur Restricted would be having access to all frequencies of the second tier license, be that Amateur Basic or General. This is in the interest of keeping the band plan as simple as possible. Those holding the Amateur Restricted license would not be allowed to build and operate their own Part 97 transmitter or amplifier, they would have to use commercially produced transmitters and amplifiers or those built by someone with a higher license class. This should not be construed to place any restrictions on anything done under Part 15 or other FCC rules, the license simply does not grant any more privileges on building a transmitter. This license would restrict operations to 200 watts, unless there are rules placing further restrictions. Testing should consist of a 50 question Element 2 exam, updated to cover the new regulations and limitations of this new license.

We believe that if the FCC allows the operation of a GMRS or marine SSB radio without any testing that a 50 question exam on FCC rules, emergency communications, and some matters of technical proficiency should be sufficient to operate a radio on any Amateur radio frequency.

We wish to emphasize that a continuation of a three tiered license is far from desired, we only propose this as preferable to keeping the current Technician license. We agree with those that believe the Technician license grants too many privileges too soon, and we go further that the General, and perhaps even Advanced, offers too much too soon. We do not propose removing licenses from anyone that has already obtained a license, only that no more of these licenses be issued and those with these licenses be encouraged to upgrade. This will come with seeing their newly licensed peers having greater privileges, with an introduction of licenses other than Extra being allowed to renew only once, and the inherent incentive that comes with any tiered license structure.

MORSE CODE ENDORSEMENT

So long as other nations call for a test of Morse code ability to operate on Amateur Radio frequencies there will be a demand for people to have some indication of having passed a Morse code exam on their Amateur radio license. This proposal is consistent with the general idea of endorsements on a single license for commercial and Amateur radio operations and therefore should be considered a part of a wider proposal to have a single license for both. What's also still in some demand are those holding a commercial Radiotelegraph Operators License but a lack of testing centers willing to hold the Morse code exams. There's an existing pool of volunteer examiners willing to perform this service, and the FCC has already in the past recognized Amateur radio testing for Morse code credit to obtain a commercial radiotelegraph license.

This proposal would restore the Element 1 Morse code exam to the Amateur radio license but only as an endorsement for reciprocal licensing and for commercial radiotelegraph licenses. With this goal in mind there would be a change from the previous testing for 5, 13, and 20 WPM exams. Instead there would be testing with commercial licensing in mind. There would be the 5 WPM testing that is consistent with most nations that still require Morse code testing for Amateur radio. The 20 WPM testing would be like it was with the pre-2000 restructuring testing for Amateur Extra. Instead of reinstating the 13 WPM testing we propose having testing for 16 WPM code groups, consistent for testing to get a commercial radiotelegraph license. This should satisfy the requirements for nations that want to see higher speed Morse code testing than 5 WPM but not to the level of 20 WPM. We believe the 13 WPM endorsement is largely redundant with testing at 5, 16, and 20 WPM.

Consistent with previous FCC policy on testing for Morse code those proctoring such exams would have to be those that have taken such exams themselves. Also consistent with FCC policy is that credit would be given for those showing a current or expired license which had such testing.

In order to discourage Amateurs from muddying the FCC database with Morse code endorsements on every existent license class the Morse code endorsement would only be available for Amateur Extra or shown with the Radiotelegraph Operators License. This alone should provide an incentive to many to upgrade as they placed value in their grandfathered license showing Morse code knowledge.

As we anticipate this coming up in discussion of this proposal we will make something clear, any Amateur license issued after the availability of physicians waivers for Morse code will give credit for only 5 WPM, as the FCC database did not track the presence of these waivers in the application for a license. Also, any testing at 13 WPM will not count towards the 16 WPM endorsement as this has not been considered equivalent by the FCC in the past.

What would be far more preferable is the FCC negotiating new reciprocity agreements which do not require any Morse code testing. This does nothing for those that want to keep an indication of having passed a Morse code test on their license for reasons outside of reciprocity agreements. For that there is nothing that can be done with the licensing.

AMATEUR LICENSING AND COMMERCIAL LICENSING CROSS TRAINING

Unlike the other proposals made in this document this is the one proposal that is dependent on the adoption of another. For this to meet the intended goal of creating some cross training between licensed Amateur radio operators and commercial radio operators, without taking away from what applicants for an Amateur radio license must demonstrate knowledge, there must be an expansion of the Element 2 exam from 35 to 50 questions, as well as a simplification in the rules being tested, as described in the proposals for a new Amateur basic or Amateur Restricted license.

What is not proposed is splitting the Element 2 exam into an Element 2A and Element 2B. We believe that increasing the number of exams is undesirable and unnecessary. There's two variations on this theme that we are proposing which can be considered a "hard start" in commercial licensing for Amateur radio and a "soft start", with the first pulling questions from the commercial Element 1 question pool and the second from the combined pool of Elements 1, 3, and 6. What should be made clear is that passing this exam for an Amateur radio license would not itself grant the applicant any commercial license. That would still require going to a COLEM and completing the application for a license there.

With the "hard start" variation on this we'd have 24 of the 50 questions in the Amateur Element 2 exam would come from the commercial radio licensing Element 1 question pool, with the questions pulled from the pool just as they would for someone testing for the Marine Radio Operator Permit (MROP). A passing score would remain as 74%, or 37 out of the 50 questions. One intended goal with this is to have the applicant learn FCC rules on what the rules are for operating a commercial radio, primary among this is that the applicant would have to demonstrate knowing that an Amateur radio license does not allow operation on a radio for commercial radio services, and vice versa. While this may not be all that common there does appear to be a tendency for those with an Amateur radio license not knowing the distinction between an Amateur radio license and a commercial radio license. This can be further clarified with questions in the pool for the remaining 26 questions on the 50 question exam.

Another intended goal is to maintain a consistency between how licensed Amateur radio operators and licensed commercial radio operators communicate on air. As it is currently this is largely true because good practice is the same on all radio services. By having both services pull questions from the same pool in testing this commonality is enforced, which would be valuable in an emergency where something lost in translation could cost lives. This is especially valuable for recreational boating where obtaining the MROP is optional, use of VHF marine radios are allowed, and the person had obtained an Amateur radio license. There does appear to be a trend for recreational boaters will obtain an Amateur radio license for ship to ship and ship to shore communications on HF, using an Amateur radio or marine SSB radio that's had the VFO opened up to transmit on both marine and Amateur frequencies. By obtaining the Amateur radio license the radio operator has been exposed to the rules on operating a marine radio, even if the operator has not obtained the MROP but instead obtained the Restricted Radiotelephone Operators Permit which has no testing requirement.

Even if the licensed Amateur will never operate a marine radio there is still a lot of good things to learn from the commercial licensing pool. Much of the testing is on good operating practice, use of phonetics, and basics of radio operation that is identical to how all radios operate on all services. The questions that do not directly relate to Amateur radio still offers a good example as it pertains to good practice generally by giving examples of things like using a calling frequency to reach another station and continuing the communication on a different frequency or of using the minimum power needed to maintain communications.

One concept that can be borrowed from Canadian Amateur radio licensing is the idea of passing the exam "with honors". This would not grant additional privileges for Amateur radio but a score of 90% on the Element 2 Amateur radio exam in this case is that the applicant has shown they met the same requirements needed to get the MROP, that is answering correctly 18 out of 24 questions from the commercial Element 1 question pool. This CSCE could then be presented to a COLEM to get credit for the MROP. We believe that there would be little or no opposition from COLEMs on this as this could drive business to them. COLEMs make their money on the GROL, GMDSS, and other commercial licensing and endorsements.

Could these same goals be met by other means? Absolutely. The Amateur radio community could voluntarily adopt questions from the publicly available commercial radio question pools. This would not allow credit for commercial testing credit without the FCC's blessing though.

With the idea of a "soft start" of starting people off in Amateur radio with 24 of the 50 questions drawn from the combined pool of the questions for the commercial Elements 1, 3, and 6. This is a pool of over 1000 questions from which the Amateur radio Question Pool Committee could draw to select questions that might be preferred for better preparing applicants for Amateur radio. This still assures some commonality on training between services but removing any potential for credit for commercial licensing.

What would be preferred to have this commonality in training for commercial and Amateur radio operators is a question pool that has an equal "ownership" by both commercial and Amateur radio communities. That should be a long term goal but for now this is a place to start.

This shared credit in testing can then go from commercial radio licensing to Amateur radio in that showing a VE team that the applicant has a GROL or Radiotelegraph Operators License they obtain credit for Element 2 in order to take the Element 3 exam for the Amateur Basic license. This would not apply for credit to obtain the Amateur Restricted license, should the proposal for that license be adopted, as commercial radio operators did not demonstrate knowledge of any rules on Amateur radio operation.

LIMTED RENEWALS OF AMATEUR LICENSES EXCEPT AMATEUR EXTRA
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KA9JLM · Feb 24, 2020

AC0GT said: ↑

Does formatting copy/paste? How long of text can I past in?
Click to expand...

It depends how much memory that you have.

Using "Select all" then copy will work for very large files.

Copy and paste works for pictures and most files also.

ND6M · Feb 24, 2020

What a waste of bandwidth

AC0GT · Mar 29, 2023

can I spoil something?

rotten eggs

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PY2NEA · Mar 30, 2023

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Testing a quote of lots of formatted text

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