July 1, 1998

[Head of department]
[filled in with specific name/address/administration]

The Main Objective of No-Code International

Ending Morse Testing Requirements in Amateur Radio

No-Code International was founded in 1997 as an amateur radio organization that is dedicated to the abolition of Morse code testing requirements as a prerequisite for any class of amateur radio license. NCI will continue as a lobbying organization for as long any mandatory manual telegraphy testing requirement exists in international and respective national regulations. NCI was established in the USA, so consequently most of our initial membership consists of USA amateur operators, however, NCI also has members from all ITU Regions, and intends to continue to attract and represent membership from radio amateurs worldwide on Morse code testing and related licensing issues. The NCI world wide web site at: http://www.nocode.org is our main vehicle for interacting with members and providing information, with international access.

No-Code International is not opposed to manual Morse code operation. We see the value of Morse code (also known as CW) communication in the amateur service as primarily being recreational in nature, as the personal choice of individual operators. NCI is opposed to mandatory Morse testing as a licensing requirement for an amateur operator to use certain frequency bands. We believe that international radio regulation S25.5 should be removed as soon as is practicable, and consequently respective national regulations should be updated as promptly as is practicable to offer no-code alternatives. In the meantime amateur radio continues to fall behind the times in the image seen by many potential recruits. Relative interest in amateur radio may be able to be estimated by inspection of the amateur radio license statistics of your administration in recent years. Many countries are showing declining amateur radio license numbers in recent years. We believe that having Morse code testing as a restrictive practice is a significant factor in the apparent downturn in interest in recent years, and is not a good indication for the future survival of amateur radio.

The Main Regulatory Problem In Amateur Radio Is Simple To Solve

Removal (suppression) of S25.5 involves minimal administrative involvement. Even if some administrations want to retain compulsory Morse testing, which we doubt, then that can of course be addressed within national regulations. The course of action proposed by New Zealand at WRC-95 to suppress S25.5 (was 2735) is simple and effective, giving a suitably deregulated and simplified result in the international regulations. We suggest that there is no need to carry out a ponderous review of all of Article S25 to remove S25.5.

We point out a parallel case implemented via the Voluntary Group of Experts (VGE) where WRC-95 agreed to the removal of international radio regulation number 2800, which was for Morse code testing for persons operating experimental stations. The texts of former international radio regulation number 2800 and S25.5 are reproduced in Attachment 1 so that comparison can easily be made. We agree that removal of number 2800 is a suitable simplification of the regulations, and so it should also be for S25.5 and the amateur service.

Polarization On Morse Code Policies Within Amateur Radio

A strong stimulus in the formation of NCI was to achieve an organized reaction to polarized views within amateur radio on the role of Morse testing to qualify for amateur licenses. There are some curious ideas in amateur radio on the subject of Morse testing, and we see that exposing the policies to external scrutiny can make progress. Some already qualified amateurs have certain self-interests at heart and seek to restrict the number of participants by using Morse code testing as a license requirement. NCI is fundamentally opposed to using Morse code testing as a restrictive practice, which involves human rights and discrimination issues, and is especially objectionable, when it appears in international regulations.

While NCI is not in agreement with some amateur radio societies on the future of Morse code speed testing, we can draw attention to a significant "turn around" in the policy of one major society, namely the Radio Society of Great Britain (RSGB). The content of their recent statement is attached to this letter.

A Summary Of NCI Views On Improved Licensing Structures, International Uniformity And Reciprocal Agreements

NCI is currently developing policies on qualification requirements for amateur radio licensing and will provide more details in due course. A summary of NCI views to date is to have no more than three classes of license, such as:

Introductory:

limited in power to say 10 watts, limited in spectrum access to the 3.5, 28, 144 and 430 MHz amateur bands (where amateur bands are nationally allocated), accordingly has lower level technical and operational examinations. This is a "try it and see if you like it" license, and it can be expected that most of the interested newcomers would in time obtain a general or advanced qualification, with associated increases in spectrum access and transmitter power privileges.

General:

access to all amateur bands, with power limited on each band to whatever is considered to be generally safe for non-ionizing radiation exposure in the neighborhood, accordingly has increased level of technical and operational examinations compared to introductory licenses.

Advanced:

access to all amateur bands, with maximum power limited to values and bands set by individual administrations. Licensees need to be technically qualified to safely use higher transmitter powers and to be able to minimize interference problems associated with higher powered operation.

We see reciprocal licensing as being secondary to making the appropriate high level changes to international regulations. We caution administrations to not waste time "re-arranging the deck chairs on the Titanic" with the existing infrastructure that has Morse code proficiency as a central theme, when in the near future Morse code testing is hopefully to be much de-emphasized as a regulatory factor.

NCI Supports A 5 wpm Morse Test As Interim Compliance With S25.5

As an interim step in the right direction we support immediate reduction of Morse speed testing to 5 words per minute for any amateur radio license. This is regarded as providing threshold compliance with S25.5, in the interim prior to removal of S25.5. Of course, any individual wanting to improve their Morse proficiency is free to do so, and that should be quite separate from regulatory and licensing issues. An interim step of requiring a 5 word per minute Morse test for any license should be part of a scheme with smooth transition between existing license arrangements and future ones which have no mandatory Morse code test element. We are aware that several administrations are investigating an interim step of a 5 word per minute Morse test and we await formal developments with interest. NCI will comment further on this in due course.

Our Offer To Provide Free Advice On Updating Amateur Radio Regulations And Policies

NCI seeks modernization in amateur radio regulations and licensing policies, especially regarding timely removal of S25.5 from international regulations and consequential changes to national regulations. In order to facilitate changes we are willing to provide free advice to any administration that puts questions to us. We can arrange for correspondence by email or conventional mail, and we will respond within a reasonable time of receiving questions.

This is our first general mail out, which is going to many administrations. We will provide further information as we develop our material and we look forward to dealing with questions put to us.

(signed) NCI Board of Directors

 

Attachment 1: References from International Radio Regulations

Text of Article 34, Experimental Stations, number 2800, which was removed by WRC-95 and does not appear in the new international radio regulations:

  • "In experimental stations any person operating radiotelegraph apparatus, either on his own account or for another, shall have proved his ability to transmit by hand and to receive by ear texts in Morse code signals."
    •

    Text of Article 32, Amateur Service and Amateur-Satellite Service, number 2735, which is S25.5 in the new international radio regulations. S25.5 is the target of NCI and others to be removed as soon as is practicable.

  • "Any person seeking a license to operate the apparatus of an amateur station shall prove that he is able to send correctly by hand and to receive correctly by ear texts in Morse code signals. The administrations concerned may, however, waive this requirement in the case of stations making use exclusively of frequencies above 30 MHz."
    •

    Attachment 2: Statement from the Radio Society of Great Britain

    The following is the statement made by RSGB president, Ian J. Kyle GI8AYZ in the June issue of RadCom, the RSGB monthly journal.

    "In this year of 1998 Amateur Radio is one hundred years old. Yet although the technology used has changed dramatically during that period, with a multitude of new techniques, in some other respects there has been little change. December’s RadCom leader contained the phrase "...we live in interesting and rapidly changing times" and that statement and those changes have been reflected in Council deliberations during recent months.

    "At its meeting in April, Council agreed that it would open discussions with the Radiocommunications Agency to begin a process of liberalizing access to the HF amateur bands. Council sees the first step in this as an additional license category giving full access to the HF bands to existing Class "B" [No-Code VHF/UHF] licensees subject to a 5 wpm Morse capability. The Society hopes that the RA will support this approach. If agreed, however, this license would only be available for use within the United Kingdom, and would not grant privileges on HF bands in other countries under the CEPT arrangements. [The full Class "A" license requires 12 wpm Morse proficiency.]

    "The maintenance of Morse as a mandatory requirement for access to the HF bands is IARU policy. Council, however, now believes that this position can not be sustained in the longer term and will be opening discussions with IARU Societies and other interested bodies to reconsider the position to be adopted at the WRC in 2001, when the matter of Morse as a necessary qualifier for access to HF bands is likely to be considered.

    "In taking its position on Morse, Council is mindful of the strength of feeling around this issue. Morse has many advantages, including spectrum utilization, relative simplicity of equipment and cost. The Society wishes to see Morse (and Morse segments of the HF bands) preserved as core elements of amateur radio globally. However, Morse is but one mode among many in current use, and it should take its place alongside the others as an equal.

    "Council is also seeking ways of making the qualifications for the Amateur License - be this the RAE or a new qualification - more accessible and less expensive. Also under discussion are proposals that might lead towards an acceptable system of progressive licensing.

    "Our hobby is in need of stimulation. The numbers of radio amateurs are falling in many parts of the world and this trend is an unhealthy one for the future of amateur radio. We must be seen as progressive and forward looking. We believe that this position will be welcomed by the majority of Radio Amateurs in the United Kingdom who share the view that the Society should take a forward looking and progressive stance on the future of our hobby."