Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of

Amendment of Sections 97.5,
97.7, 97.21, 97.23, 97.27,
97.28, 97.35, 97.36, 97.39,
97.61, 97.67, 97.85, 97.86,
97.87, 97.507, and 97.515.

Creating the Limited class
operator license; providing
for examination elements and
standards; and establishing
the privileges thereof.

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Received: July 17, 1989

I, David K. Stall, hereby petition for the amendment of Part 97, Amateur Radio Service, to create a new class of license titled "Limited"; and, that this license be issued upon successfully passing Element 2 administered by the same process as that required for the Novice class license; and, further providing, that Limited class privileges duplicate those of the Novice class above 30 megahertz.

The Limited class license removes the Morse code barrier for those who don't seek the full range of amateur privileges. It provides a no-code entry into amateur radio without disrupting the existing classes, privileges, or incentives. Additionally, it builds upon the Novice class enhancements, preserving the progressive license structure, while introducing a large corps of potential Novices to amateur radio. Previously adopted Novice enhancements will induce a significant number of Limited class operators to join traditional amateur ranks by upgrading, despite the five word per minute code requirement.

Implementation of these amendments will require the scope of the Element 2 Question pool be expanded or modified to address the restriction of the Limited class license. High frequency Novice privileges and operating knowledge not specific to the Limited class privileges contained in Element 2 are deemed basic to the understanding of amateur radio theory and principles and not to constitute a barrier to licensing. Limited and Novice class call signs should be issued from group D call signs concurrently.

The creation of a no-code license is supported by Office of Plans and Policy, Working Paper Number 6, "Deregulating Amateur Radio" and Working Paper Number 20, "Alternatives for Improved Personal Communications." In the 1981 OPP Working Paper Number 6, Alex Felker and Dr. James Brown conclude that the amateur service could likely be enhanced by an influx of "individuals who have both the Knowledge and desire to utilize the amateur bands for technically innovative communications. but who have no requirement to utilize Morse code." In the later 1986 OPP Working Paper Number 20, James McNally expressed a concern that examination elements directly correlate with operating privileges and concluded that "any unnecessary requirements that may constitute a barrier to entry should be eliminated." Of course, Morse code has been long recognized as a substantial barrier otherwise quite talented individuals.

While this particular proposal has not yet received wide distribution for comment, numerous recent surveys have demonstrated that the concept of a no-code license is rapidly attracting a wide base of support within the amateur community. Movement in this direction has strengthened since the 1979 World Administrative Radio Conference that reduced Morse code requirements above 30 megahertz. This trend has continued as recently as 1988 with abolishment of shipboard code capability requirements by the International Maritime Organization and even more relevant, Canada's adoption of a no-code amateur license.

This measured response to the issue of no-code licensing creates an appealing, yet manageable, class of license that protects the basic values of the amateur radio service. It's in the best interest of the public and the amateur community to create a no-code class license that doesn't set itself apart from, or complicate, the established licensing structure, privileges, or nomenclature.

As petitioner, I will benefit from increased use of underutilized band segments and thereby assist to preserve these radio frequencies for my future use an amateur radio operator.

Since all modes are authorized, I will benefit from the innovative advances of radio technology made by future Limited class operators who would otherwise be excluded by current code requirements. The restricted frequency allocation may even spur rapid development of spectrum-conserving modes and associated technology. I will benefit from the influx of new amateurs who will provide support for countless public service and emergency communications. And not least, the availability of equipment for these bands will increase and thereby reduce the cost and continue the cycle of cultivating band usage.

Respectfully submitted by David K. Stall, N5MKK, 15710 Piper's View Drive, Webster, Texas 77598.