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.
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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
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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:
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Class Privileges Theory Test
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"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
cc:
American Radio Relay League
Radio Amateur Satellite Corporation
Amateur Research and Development Corporation
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