My comments to the proposal by the FCC to eliminate the Morse Code requirement from Amateur Radio exams:
There have been may persuasive arguments put before the Commission as to whether or not the Morse Code requirement should be kept as part of the examination process. It appears the Commission deems that Morse Code requirement is an anachronism that no longer has any validity and should be eliminated. In my opinion, I believe the Commission is being shortsighted and that we should maintain the requirement.
Many amateurs and organizations point to the fact that the military and other professional communications services have abandoned Morse Code. To some extent, this is true. But those services have gone on to highly advanced satellite communications systems. Amateur radio operators, at least for the majority, have not. Our communications depend mostly on voice or radiotelegraphy in the High Frequency portion of the electromagnetic spectrum. Radiotelegraphy has proved itself to be the most reliable method of communications using those portions of the spectrum that we, for the most part are relegated to. During times of "radio blackout" due to increased sunpsot or other types of geomagnetic activity, often Morse Code communications using Continuous Wave transmission is the only permissible means of radio communications. It should also be noted that the most "cutting edge" frontiers of Amateur Radio - meteor scatter, spread spectrum, low power and microwave and weak signal communications all rely on Morse Code and CW as the "mode of choice" in completing communications.
The Commission has expressed a concern that the providing of Morse Code testing presses an "undue burden" on the part of the VE examining teams. I would like to say, that in over ten years personal experience as a Volunteer Examiner, my team and I never found administering the Morse Code exam to be a burden. In fact, we took extreme pleasure in administering the exam and watching untold numbers of candidates pass. Again, in my personal experience of over a decade as an examiner, I have never come across an individual who was unable to pass the exam given enough time to properly prepare.
The argument has been proposed that the Morse Code exam is a roadblock, preventing untold numbers of qualified individuals from entering the Amateur Radio service. I believe this claim to be unsubstantiated at best; and just another "urban myth" at worst. The Commission has indeed licensed children as young as the age of six or seven as Radio Amateurs. While this is the exception rather than the rule, I would suggest this points to the fact that anyone with a fair amount of ambition, desire and discipline can master a 5 word per minute Morse Code exam. For those who honestly and truly have a valid medical reason for being unable to complete the Morse portion of the test, the Commission had already provided recourse via the medical waiver. I would like the supporters of this argument substantiate their claims with some kind of documentation. It is not proper to make "wild claims" before the Commission without proper documentation. Furthermore, it would seem inappropriate for the Commission to accept these unproven claims as the rule; rather than the exception.
Were the Commission to delegate the Amateur Radio Service as some non-essential radio service such as CB, GMRS or the FRS then I would accept the hypothesis that the Morse Code exam is of little value and should be eliminated. But clearly, the Commission has repeatedly avowed the importance of the Amateur Radio Service and the need for it's continued health and well being. I would hope the Commission would agree with me that to maintain that health and vitality; that it is paramount to not lower standards; but on the other hand to maintain or increase them.