The ARRL again has urged the FCC to provide meaningful operating privileges to entry-level Amateur Radio licensees, including access to HF, even if the Commission doesn't want to create a new license class. Commenting in response to the FCC's July 9 Notice of Proposed Rule Making and Order (NPRM&O) in WT Docket 05-235, the League also stood by its stance that the Commission retain the 5 WPM Morse code requirement for Amateur Extra applicants, but do away with it for General applicants. "Retaining Morse telegraphy as a requirement for only the Amateur Extra class license, in ARRL's view, places Morse telegraphy in a proper, balanced perspective," the League told the Commission October 31, the deadline to comment in the proceeding. Reply comments are due November 14. The FCC's NPRM&O proposed eliminating the 5 WPM Morse code requirement for all Amateur Radio license classes but denied requests to create a new entry-level license class with limited HF privileges. The League said the FCC needs to finish the job of license restructuring it began in 1998 by reviewing operating privileges for all classes--especially at the first rung of the licensing ladder. "The elimination of Morse telegraphy, absent a more thorough review of operating privileges in the Amateur Service, will not address the ascertained flaws in the only entry-level license class," the ARRL asserted, referring to the Technician license. "That license class is not attracting or keeping newcomers in its present configuration, and it needs fixing right now." The ARRL argued that if the FCC will not create a new Novice class license as the League had suggested in its earlier Petition for Rule Making (RM-10867) in the proceeding, it should modify Technician operating privileges instead. The present licensing regime limits Technicians to VHF bands and above, "leaving newcomers to the Amateur Service isolated from their peers holding higher class licenses," the ARRL said. "The Technician class is, for too many, a 'dead end' to what might otherwise be an active, progressive interest in Amateur Radio, technical self-training and incentive-based educational progress in the many facets of the avocation." The ARRL reminded the FCC that its restructuring plan enjoyed the support of the two Amateur Radio licensees in Congress--Rep Greg Walden, W7EQI (R-OR) and Rep Mike Ross, WD5DVR (D-AR). Eliminating the Morse requirement for General class applicants "creates an anomaly with respect to the Technician class license," the ARRL noted. "If the telegraphy requirement for the General class license is eliminated, the distinction between the Technician class licensee and the Technician Plus class licensee will have disappeared completely." Therefore, the League contends, there is a logical basis for affording Technician licensees entry-level HF privileges. Under the ARRL plan, Technicians would have telegraphy and data privileges on 3.55-3.7 MHz, 7.05-7.125 MHz and 21.05-21.20 MHz at 100 W output and on 28.05-28.3 MHz at 50 W output. The League wants the FCC to provide HF phone and image privileges to Technicians on 3.9-4.0 MHz, 7.2-7.3 MHz and 21.35-21.45 MHz at 100 W output, and on 28.3-28.5 MHz at 50 W. These recommended privileges take into account the FCC's proposal to adopt the ARRL's so-called "Novice refarming" plan in WT Docket 04-140. The ARRL had earlier proposed the same privileges for a reconstituted Novice license. The time is right to take a look at the operating privileges of Amateur Radio license classes, the ARRL said in its filing, "because the entry-level license class is demonstrably neither attractive to newcomers nor encouraging in terms of retaining the interest of license holders." To back up its assertions, the League pointed to surveys it conducted in 1992 and 2003. Nearly half of the licensees responding in the latter poll indicated that they were not currently active in Amateur Radio--up 30 percent from the earlier survey. "The number of inactive Technician class licensees is 46 percent," the ARRL noted, adding that more than a quarter of Technicians responding in 2003 said they'd never even been on the air. The League pointed out that the FCC's proposed across-the-board elimination of the Morse requirement eliminates a simple mechanism for current Technician licensees to obtain HF operating privileges--passing the 5 WPM code exam. If the FCC does nothing other than eliminate the Morse requirement for the General license, the ARRL commented, it would make no sense to continue to deprive Technician licensees the HF operating privileges that Tech Plus licensees now enjoy. "To do otherwise is to draw a distinction that is entirely arbitrary," the League concluded. Material from The ARRL Letter may be republished or reproduced in whole or in part in any form without additional permission. Credit must be given to The ARRL Letter and The American Radio Relay League.