karn (03/10/83)
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 over 11 years, almost 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 activities (e.g., Civil Defense) 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).
Because I share the Commission's interest in furthering the state of the
art, my comments will deal almost exclusively with this potential of a
code free license.
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 colleagues 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
doing so 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 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, fully aware that the majority of my fellow amateurs
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 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 with
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.
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.
Respectfully submitted,
Philip R. Karn, Jr, KA9Q/2
61 Greenbrook Road
Berkeley Heights, NJ 07922mkg (03/11/83)
Phil's comments and suggestions are by far the best and most thought provoking of any I've seen on no code licenses. For too long all discussion has been centered around the "digital" no code license while overlooking (ignoring) other types of experimentation. When I first started in ham radio, I had lots of fun and learned quite a bit while playing with a converted APX-6 on 1296 mHz (it was fun to communicate 5 miles across town with a 1.5 inch antenna on both ends). I think it is vital to the future of ham radio to encourage all types of experimentation--not just digital. I especially like the suggestion for two flavors of license with different levels of difficulty and the use of existing theory exams for them. I think its time that the FCC should do something to encourage technical development instead of continually discouraging it. Marsh Gosnell AD2H whuxlb!mkg