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Comments Received on Gazette Notice No. DGRB-003-04 Recommendations from Radio Amateurs of Canada to Industry Canada Concerning

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Comments Received on Gazette Notice No. DGRB-003-04 Recommendations from Radio Amateurs of Canada to Industry Canada Concerning Comments Received on Gazette Notice No. DGRB-003-04 Recommendations from Radio Amateurs of Canada to Industry Canada Concerning Morse Code and Related Matters ---------------------------------------------------------------------------------- Commentaires reçus à la suite de l’avis de la gazette DGRB-003-04 Recommandations de Radio Amateurs du Canada à Industrie Canada concernant le code Morse et autres sujets connexes # 1 - Duncan Elliot Re: Notice No. DGRB-003-04 - Consultation on "Recommendations from Radio Amateurs of Canada to Industry Canada Concerning Morse Code and Related Matters" Publication Date 2004-8-20 I support the proposed elimination of the Morse code proficiency requirement as stated in notice DGRB- 003-04. I question whether the Intermediate qualification is sufficient to operate 250W home-built transmitters. Today, we use a wide variety of modulation and information coding techniques. CW and International Morse code are just one example of each. From the Industry Canada web pages, "amateur radio service" is defined as "radiocommunication service in which radio apparatus are used for the purpose of self-training, intercommunication or technical investigation...” Following the lead of the ITU and many countries, eliminating the Morse code requirement would facilitate greater participation in all three of the stated purposes of the amateur radio service. The elimination of the Morse code requirement will make it easier for the students I work with to become licenced to conduct novel experiments of their own using the unique characteristics of the bands below 30 MHz. I cannot support the RAC's Recommendations 8 & 9 regarding home-built transmitting equipment with the current Basic exam syllabus and the current 250W power limit. (Of course changes to the syllabus have also been proposed.) Perhaps a lower power limit (e.g. 5 watts) could apply to home-built transmitters, including kits. I am concerned that the current Basic syllabus does not have sufficient depth in electronic circuit and radio theory and that such amateur radio operators could cause interference or risk personal safety in building radio transmitters (including kits). After all, the quality factor (Q) of a tuned circuit appears only in the Advanced syllabus. The RAC's specifications for "kits" didn't indicate whether or not these kits would require tuning/alignment prior to use or could be inadvertently detuned during construction. Perhaps some kits are nearly foolproof. Is Industry Canada prepared to test and type-approve kits as not requiring the Advanced qualification? Perhaps there should be an amateur qualification (Advanced or otherwise) that entitles licence holders to certify home-built higher-power transmitting equipment made and operated by Intermediate qualification holders. The meaning of the Intermediate qualification being a "prerequisite" for the Advanced should be clarified. It should always be possible to take both tests at one sitting (with computer administered tests, this is a non-issue). While I don't have an appreciation of the record-keeping overhead, there would be some 1 advantage if passing the Advanced test without passing the Intermediate test could give the person credit for the exam but no Amateur Radio Operator privileges. Such technically qualified individuals would have more incentive to repeat a basic test if not successful the first time. One procedure for record keeping of partial credit for passed sections of examinations is to give this discretion to the Accredited Examiners. Accredited Examiners, at their option, could require only failed sections to be completed at a subsequent exam sitting. There would not necessarily be transfer of partial credit between Accredited Examiners if a different examiner was administering a subsequent exam sitting. Sincerely -- Duncan Elliott, Associate Professor Dept. of Electrical and Computer Engineering ----------------------------------------------------------------------------- #2 - Joe Craig This proposal has no provision for protection of users of other modes from interference from SSB. This is frequently a serious problem, especially during contests and, as is acknowledged in the proposal, will likely be compounded if this proposal is implemented. RAC in its representative capacity for all amateurs in Canada, including those who use these other modes, could address this deficiency and submit a revised proposal to Industry Canada. This could be done, for instance, by requesting the bandwidth restrictions currently on the 10.10 to 10.15 MHz band be extended to portions of all bands below 30 MHz thereby ensuring spectrum is available for the use andm development of other modes and experimentation with possible new modes. The proposal removes the incentive to learn Morse code. A decade ago the International Amateur Radio Union asserted the utility of Morse code in "intercommunicat[ion] without regard to equipment or language barriers, to ensure the orderly shared use of a limited resource." This is equally true today. Additionally, no mode has emerged as an "alternative means for ensuring that amateur stations can intercommunicate" which has become "sufficiently universal to obviate the present [Morse code] requirement". Amateur radio is by definition a service of intercommunication and if provisions are not made to encourage learning Morse code, intercommunication will be adversely affected. Additionally, Morse code remains an enjoyable aspect of Amateur Radio for a substantial portion of those who learn it. Without an incentive, many will be deprived of this enjoyment. To provide incentives, the Basic + 5 WPM should be retained and an option to HF privileges and the Advanced qualification should include passing a 5 WPM test for example. Yours truly, J. Craig ------------------------------------------------------------------------------ #3 - Robert Allison My response to the recommendations: 1. Yes. 2. No - have a separate exam for Intemediate Qualification. 2 3. Yes. 4. No - keep it simple. 5. No - let us encourage people to get into the hobby. 6. Yes, but no to the 70%, again, we are trying to encourage people. 7 .Yes. 8. Yes. 9. Yes. 10. No. 11. No. 12. No. KEEP IT SIMPLE AND NO COMPLICATIONS SUCH AS #2 AND #4. ------------------------------------------------------------------------------ #4 - Guy Dumas Je suis tout à fait d'accord avec le retrait de l'exigence de la connaissance du code morse pour l'utilisation des fréquences inférieures à 30 MHz dans la bande HF du service d'amateur. À mon avis la vocation de la radio-amateur a beaucoup changée, et avec le développement fulgurant des radio-communications est plustôt devenu un hobby et une source d'apprentissage extraordinaire. Certes, en certaines région éloignées et/ou moins développées, ce mode de communication demeure un lien prioritaire. Dans de tel cas, la liaison se doit d'être fiable et conviviale. Le morse, est fiable et non conviviale. Il ne devrait plus être exigé de connaître un code afin d'avoir accès à un monde fascinant. Guy ------------------------------------------------------------------------------ #5 - Bob Tenty Abstract. As RAC member I'm pleased with the RAC proposals but don't agree fully with Recommendation 7 & 8 and would modify recommendation 10 also. Combine recommendation 7 & 8 to: Design and Construction of transmitters from scratch should be allowed on ALL amateur bands for the Intermediate Qualification! Recommendation 10 should be modified as follows: Recommendation 10: New Entry Qualification should include operation on HF shortwave, 144 & 440 MHz bands all mode and including commercial kits. This along the lines of the Foundation license in the United Kingdom. 3 Explanation RAC recommends in "Recommendation 8" that holders of the new Intermediate Qualification be permitted to construct and use commercial transmitting equipment kits and in Recommendation 9 that holders of the Intermediate Qualification are permitted to construct and use their own transmitting equipment in the bands at 2.3 GHz and above. If Intermediate Qualification holders are allowed to design and construct their own transmitting equipment above 2.3 GHz they should be more as qualified to construct their own transmitting on the HF shortwave bands. Construction of microwave transmit equipment is much more difficult and also asks for a much larger investment in test equipment as it is more expensive for these bands. Those who can construct transmit equipment for the many amateur (and shared!!) microwave bands above 2.3 GHz can certainly handle the construction, design and responsibility for the HF amateur shortwave bands and VHF/UHF. It is very much in Canada's economic interest to support innovation. I recommend combining Recommendation 7 & 8 as follows: Allow holders of the new Intermediate Qualification to construct and design their own transmit equipment for ALL amateur bands! A practical assessment for the Intermediate Qualification like in the UK maybe worthwhile to consider. (They have a practical assessment for the Foundation and Immediate qualifications) Recommendation 10 RAC recommends that a new entry-level qualification be introduced I fully support a new entry level qualification but along the lines of the Foundation license in the United Kingdom. This means a license with 10 Watts transmit power, access to the HF shortwave bands (HF - 440 MHz) all modes with a theoretical and practical assessment. with permission to use duly constructed commercial transmitting kits. 4 Don't hide those people on VHF/UHF
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