No Code International's Comments on the ARRL's Restructuring Proposal

The board of No-Code International (NCI) would like to comment on the ARRL's latest license restructuring proposal.

1. The ARRL has proposed a 5 WPM "General Class" license, which they call "Class C". NCI applauds the ARRL board for making this brave decision. We'd like to encourage the ARRL's directors and membership to do more thinking in this direction.

2. No-Code International stands for the elimination of the Morse code examination as a criterion for amateur licensing. We note that the ARRL has proposed a 12 WPM exam for the proposed "Class B" and "Class A" licenses. We feel that these licenses should also require only a 5 WPM exam, and we urge the ARRL to make that change to their proposal. This is not to say that we are opposed to the use of high-speed CW on the air. We simply think it is something that amateurs should do voluntarily, and it should not stand in the way of their becoming HF operators.

3. The sole remaining reason for Morse code examinations stems from a 50-year-old regulation now called "S25.5" in the International Telecommunications Union treaty which requires manual Morse proficiency to be demonstrated before a license can be issued for operation in amateur spectrum below 30 MHz. S25.5 should be struck from the treaty at the next ITU meeting. We urge the ARRL, the IARU and its member societies, and all ITU member nations and observers to work toward the elimination of S25.5 as soon as is practicable.

4. Once S25.5 is struck, Morse code examination should be eliminated entirely as a criterion for amateur licensing. We urge FCC to adopt a "sunset clause" that will immediately drop all Morse requirements for amateur licensing once S25.5 is struck. We urge the ARRL and all American radio amateurs to join us in this proposal.

5. Given that CW speeds over 5 WPM should be irrelevant for amateur licensing, the ARRL proposal includes one more license class than is necessary. NCI proposes a modification to the ARRL plan which would combine the ARRL's proposed "A" and "B" classes into a single Class "A" license with the combined privileges of the ARRL's proposed "A" and "B" classes, a combined written test, and a 5 WPM Morse requirement. The ARRL's proposed "C" class (entry level HF) would therefore be called Class "B" and the ARRL's proposed Class "D" (equivalent to the current Technician Class) would become Class "C".

6. We don't yet know what the FCC Notice of Proposed Rule-Making will contain. Obviously, once it's released, we will present the no-code case to FCC, and we may choose to write them while they are still composing the NPRM, as the ARRL already has. You can expect us to comment on the obsolescence of all code-testing, on the number of license classes, and on many other relevant issues.

The NCI Board of Directors