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. ----------------------------------------------------------------------- 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 cc: American Radio Relay League Radio Amateur Satellite Corporation Amateur Research and Development Corporation USENET computer network