Mystery Solved: "Missing" Petition was No-Code International's

NEWINGTON, CT, Sep 2, 2003--The mystery of a "missing" rule making petition, RM-10786, has been solved. It was filed by No-Code International (NCI). When the FCC invited public comments on six other Morse code-related petitions for rule making in the sequence RM-10781 through RM-10787, petition number RM-10786 failed to show up on the FCC's Electronic Comment Filing System (ECFS), and it remained missing through September 2. Nonetheless, the FCC put No-Code International's petition on public notice along with the others on August 29 and invited comments. NCI calls on the FCC to delete Element 1--the 5 WPM Morse code exam--"totally" from the Amateur Service rules and grant "Tech Plus" privileges to current Technicians. It also wants the FCC to act on the matter as soon as possible, preferably in a separate rule making and without further ado.

"Petitioners believe that the facts in this matter and in law, with particular emphasis on the Commission's previous determinations in this matter and the body of record in prior proceedings, as outlined herein, show that the Commission clearly has the authority to modify its rules on its own initiative and without further public notice or comment," NCI asserted in its 20-page petition.

NCI notes that World Radiocommunication Conference 2003 (WRC-03) made optional the requirement to prove the ability to send and receive Morse signals to operate below 30 MHz. As a result, "the Commission is no longer bound to maintain any Morse proficiency requirement." The Morse requirement, NCI contends, is keeping newcomers from Amateur Radio. NCI Executive Director Carl R. Stevenson, WK3C, filed the petition on the organization's behalf.

In the meantime, comments have begun to pour in from members of the amateur community on the other six petitions reported August 29 (see "FCC Invites Comments on Six Morse Code-Related Petitions"). Clearly ahead in the comment-collection race is the petition filed by the National Conference of Volunteer Examiner Coordinators, RM-10787, which has collected nearly 280 comments. The other petitions have each garnered in the vicinity of 70 comments apiece. So far, the FCC has put seven of nine Morse code-related petitions for rulemaking on public notice.

Interested parties may file comments on any or all petitions now on public notice by using the FCC's Electronic Comment Filing System (ECFS). The ECFS also permits users to view all comments on file. There is a 30-day comment window.

To file a comment, click on "Submit a Filing" under "ECFS Main Links." In the "Proceeding" field, type the full RM number, including the hyphen, and complete the required fields. "RM" must be in capital letters, and you must include the hyphen between "RM" and the five-digit number. You may type your remarks into a form or attach a file. ECFS also accepts comments in active proceedings via e-mail, per instructions on the ECFS page.

To view any comments already submitted for each petition, click on "Search for Filed Comments" under "ECFS Main Links" and type in the complete RM number, including the hyphen, in the "Proceeding" field. "RM" must be in capital letters, and you must include the hyphen between "RM" and the five-digit number.

Several countries--including Switzerland, Belgium, the UK, Germany, Norway and the Netherlands--already have moved to drop their Morse requirements. Austria, New Zealand and Australia are expected to do so soon.

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