[net.ham-radio] ARRL directors & no-code

karn (04/23/83)

Adam's message regarding the ARRL directors voting to "oppose the
no-code license in the strongest terms" is exactly what I needed to get
me to polish off my comments and drop them in the mail.
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				Before the
		    FEDERAL COMMUNICATIONS COMMISSION
			  Washington, D.C. 20554




       In the Matter of		       )
				       )       PR Docket No. 83-28
       Establishment of	a Class	of     )
       Amateur Operator	License	Not    )
       Requiring a Demonstration of    )
       Proficiency in the International)
       Morse Code.		       )





		    COMMENTS OF	MR. PHILIP KARN, KA9Q

       I have been a licensed  amateur	for  12	 years,	 10  as	 an
       Amateur Extra Class licensee.  During this time,	I graduated
       from high school, obtained Bachelor's and  Master's  degrees
       in  Electrical  and  Computer  Engineering,  and	 obtained a
       professional position with Bell Telephone  Laboratories.	  I
       consider	the technical knowledge	and motivation for learning
       gained through amateur radio to have been a strong factor in
       my  choice  of  a  career in the	communications and computer
       industry.

       During my years as an amateur, although I  have	contributed
       to  public  service  (e.g.,  Civil  Defense)  activities, my
       primary	interests   have   always   been   technical:	new
       communications modes, techniques, and higher frequencies.  I
       am currently involved in	two new	technologies: packet  radio
       and  amateur  satellites, as an Assistant Vice President	for
       Engineering with	the  Radio  Amateur  Satellite	Corporation
       (AMSAT).

       This is an exciting time	to be involved in such	activities.
       As   technology	 advances,  distinctions  between  formerly
       separate	disciplines become ill-defined.	 A whole new  range
       of   interdisciplinary  opportunities  (e.g.,  the  proposed
       PACSAT store-and-forward	packet radio  satellite)  are  only
       now   beginning	 to   appear.	The  realization  of  these
       potentially substantial contributions to	the  state  of	the
       art depends almost entirely on the availability of motivated
       and technically knowledgeable amateurs,	and  the  voluntary
       financial support of a large user population.












				  - 2 -



       As one who has both professional	and  amateur  interests	 in
       communications,	I  am  constantly  struck  by  the contrast
       between the people in my	two environments.  On the one hand,
       a  disturbingly large fraction of radio amateurs	with access
       to the spectrum appear relatively uninterested in  advancing
       the  state of the art.  On the other, many of my	non-amateur
       colleagues  also	 have  a   personal   interest	 in   radio
       communications.	While they certainly have the capability to
       make significant	contributions to  low-cost  implementations
       of  advanced technologies, they are barred from the spectrum
       by even the 5  wpm  code	 requirement  associated  with	the
       Technician Class	license.

       I have often tried to  encourage	 interested  colleagues	 to
       obtain  amateur licenses.  The replies are often	along these
       lines:

	 1.  "I	don't need or want to learn the	code; I	 just  want
	     to	 experiment  with  packet  radio". [or,	satellites,
	     microwaves, etc]

	 2.  "Why should I want	to be  part  of	 a  service  that's
	     snobbish  enough  to  insist  that	 everyone learn	the
	     code?"

	 3.  "Nobody does anything technically	innovative  in	the
	     Amateur  Service.	 I  wouldn't  have  anybody to work
	     with."

       These three reasons reinforce each other.  Opportunities	for
       innovation  are	often missed because many "technical types"
       aren't hams.  They resist what they perceive as an arbitrary
       requirement  kept  in place by an elite group more intent on
       maintaining their "exclusive rights" than in  advancing	the
       state  of  the  art.   While  I usually point out that CW is
       still a useful mode in many  situations,	 even  in  advanced
       systems	such  as  OSCAR	satellites, I cannot help but agree
       that  the  code	should	not   be   a   mandatory   entrance
       requirement.

       I therefore strongly  support  the  Commission's	 desire	 to
       create	a  form	 of  "code  free"  license  and	 am  deeply
       disappointed that the ARRL and the  majority  of	 my  fellow
       amateurs	 appear	 to  disagree  with this position.  My only
       concerns	are practical: while  there  is	 general  agreement
       that  the  "microwave  bands" (1215 Mhz and up) could easily
       support many more amateurs, it is not as	clear  with  regard
       to the 50-450 Mhz bands.

       For this	reason,	I feel that if the  Commission	adopts	any
       code-free  proposal,  it	 should	 also  do  the following to











				  - 3 -



       alleviate congestion if at all possible:

	 1.  Grant no new services access to the 220 Mhz band.

	 2.  Maintain  the  use	 of  420-430  Mhz  by  the  Amateur
	     Service.

	 3.  Expedite the allocation of	additional VHF/UHF spectrum
	     to	 the  Amateur  Service,	 particularly  the  902	Mhz
	     WARC-79 band.

       Even with additional VHF/UHF  frequencies,  simply  removing
       the  code  test	from  the  Technician  license would likely
       result in severe	overcrowding on	the popular 144	 Mhz  band.
       Overcrowding,  such  as	that  in Southern California, not a
       lack of code proficiency, is the	major cause  of	 accidental
       and  intentional	 interference.	 It therefore unfortunately
       becomes necessary to limit access to 144	Mhz, but  I  cannot
       justify the code	requirement on its own merits for that band
       any more	than I can for the less	crowded	higher frequencies.

       The best	way to	limit  crowding	 on  144  Mhz  while  still
       encouraging  talented  newcomers	 and  the use of the higher
       amateur bands would  be	through	 two  types  of	 code  free
       license.	 The lower grade would require only the	theory test
       associated with	the  Technician	 license  and  provide	all
       privileges  on 220 Mhz and up.  The higher grade	would grant
       all privileges above 50 Mhz to licensees	who  demonstrate  a
       knowledge  of theory equivalent to that required	of Advanced
       or Extra	 Class	licensees.   I	would  recommend  that	the
       Commission  reserve  the	option to later	modify requirements
       for this	grade of license, based	on actual experience.

       While a "digital" specialty license would undoubtedly appeal
       to  a  number of	potential amateurs, I feel that	it would be
       too restrictive.	 Such a	license	would ignore the  needs	 of
       potential  amateurs  interested	in  other  areas,  such	 as
       microwaves and satellites, and isolate those who	 do  obtain
       the   "digital"	 license  from	the  rest  of  the  amateur
       community.

       Summarizing my suggestions, I would create  two	classes	 of
       code free license as follows:



















				  - 4 -




       Class	       Privileges	       Theory Test
       -----	       ----------	       ------ ----
       "second"	       all on 220 MHz and up   Existing	Technician/General
       "first"	       all on 50 MHz and up    Existing	Advanced (or Extra)









				       Respectfully submitted,



				       Philip R. Karn, Jr, KA9Q/2
				       61 Greenbrook Road
				       Berkeley	Heights, NJ  07922
				       201-322-4724





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