Restructuring Petitions Go Public

RESTRUCTURING RECONSIDERATION PETITIONS ON PUBLIC NOTICE

The FCC has put on public notice five petitions for partial reconsideration of the Commission's amateur "restructuring" Report and Order WT Docket 98-143. The list includes a petition filed by the ARRL. Interested parties may file opposition comments. The FCC does not solicit supporting comments for such petitions, and it's under no obligation to consider them.

In addition to the League's, petitions put on public notice April 18 were filed by Alan J. Wormser, N5LF, Frederick V Adsit, NY2V, and Michael J. Dinelli, N9BOR; by Fred A Duran, W4NKI; by Millard H. Qualls, K9DIY, and by Stewart Teaze, N0MHS. The petitions were put on public notice April 25 in The Federal Register.

The League's petition, filed in mid-March, asks the FCC to continue to maintain records indicating whether or not a Technician has Morse code element credit. It also seeks permanent Morse element credit for any Amateur Radio applicant who has ever passed an FCC-recognized Morse exam of at least 5 WPM.

The Wormser, Adsit, Dinelli and the Qualls petitions also call on the FCC to rethink its plan to eliminate the "Plus" designation from the license class of Technicians who have passed the 5 WPM Morse code examination. Wormser et al say that essentially merging Technician and Tech Plus licensees into a single database would hamper enforcement.

Two petitioners also ask the FCC to retain the 20 WPM Morse code requirement for the Extra. Wormser, Adsit, and Dinelli contend the FCC's December 30, 1999, R&O "unnecessarily reduces the speed of the Amateur Extra Class telegraphy examination as a way to avoid code waivers." The petitioners argue that the General class license with its 5 WPM code test offers "reasonable accommodation to disabled persons" claiming an inability to pass the higher code test. As an alternative, the petitioners suggest that the FCC allow applicants claiming an exemption "to certify their own impairment under oath." Qualls requests retention of the 20 WPM test or at least a 12 WPM requirement for the Extra ticket.

Wormser et al also want the FCC to ban the practice of allowing applicants to retake a failed examination element at a single test session. Their petition says amateur applicants should be restricted to one exam session in any 24-hour period. It further asks the FCC to not extend exam element credit beyond the current two-year license expiration grace period.

The Wormser et al and Qualls petitions also ask the FCC to set the number of questions at 50 for the Technician and General class test and at 100 for the Extra test. Wormser et al further request that the FCC "retain sufficient question pool categories to maintain or increase the proportion of technical and theoretical questions on each written test."

The Teaze petition calls upon the FCC to institute a new entry-level Communicator license class. Under his proposal, Communicator licensees could be no older than 16, must use fixed antennas no more than 20 feet above ground or above the building or tree they're mounted on, and use not more than 2.5 W ERP. Channelized voice and digital operation would be in the range of 445 to 446 MHz. The exam would consist of "25 fairly simple questions."

The Duran filing requests that the FCC elevate former "Class A" operators licensed prior to 1951 to Amateur Extra, instead of leaving them at Advanced class--something the FCC's Report and Order specifically said it would not agree to do.

The window to file opposition comments to any of these petitions remains open through May 10. Replies to opposition comments are due 10 days later. Copies of all petitions may be viewed on the FCC Web site. Visit http://www.fcc.gov/e-file/ecfs.html, click on "Search the ECFS System" and type "98-143" in the "Proceeding" field.

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