Edward C. Sieb
P.O. Box 8377, Ottawa Terminal,
Ottawa,  Ontario   K1G 3H8
(613) 738-8924 - E-Mail: va3es@rac.ca

January 31, 2001

Chief, Authorization,
Spectrum Management
Operations Directorate,
Room 1588D, 300
Slater Street,
Ottawa, Ontario, K1A
0C8.

Re: DGRB-001-01
January 6 A Proposal to Grant
Full Operating Privileges in all Amateur Radio Frequency Bands
Below 30 MHz to Amateur Radio Operators Holding a 5 word per
minute (w.p.m.) Morse Code Qualification

Dear Sir,

The Amateur Radio Service is a noble and beneficial service with much history and accomplishment. Whenever changes are made to it’s structure or it’s technical requirements and qualifications, care must be taken to ensure that the intentions and purpose of the service are not adversely affected. Such changes, when poorly implemented, or thoughtlessly imposed can often lead to the original aims and objectives of the Service to disappear. Today, there is much emphasis in our society for “progressive” change. Old ideas and ways are swept aside in an effort to make room for more modern state-of-the-art technologies and methods.

This clamour for the “new” is unabated and sometimes deafening.   Though swept aside, and rendered silent, the old technologies and methods still maintain useful application, both as practical techniques and as important links to the heritage of the service. Of course, I’m talking about Morse code and it’s application in the Amateur Radio Service. As mentioned in  Notice No. DGRB-001-01, there are “a number of petitions from individuals who contend that the current regulatory requirement for maintaining an operator proficiency in the transmission and reception of Morse code at a speed of 12 words per minute can no longer be justified. Their view is that CW is an outdated modulation technique and that proficiency in the Morse code should no longer be the basis upon which amateurs are granted enhanced operating privileges.”   I believe that these contentions are mistaken and I will endeavour to explain my reasons.

“CW is outdated”

This contention is based on the evidence on the numbers of government and commercial users who have abandoned this mode.  What has not been considered is that these commercial users demand increasing speed, efficiency and cost effectiveness in their communications systems requirements. As well, a major criterion for a commercial communications system is manpower resource availability. With the development of advanced, highly cost-effective digital communications techniques via satellite and other facilities, plus the decreasing requirement for specialized training to use these systems, has led to the over-all decrease in the cost of operating and maintaining these systems.  Cost-effectiveness is the main engine of change in commercial communications. For commercial users, Morse code is both too slow, and too expensive; it has been superseded by faster, more advanced, more efficient state-of-the-art techniques. Since these criteria, (efficiency, cost-effectiveness) do not apply for the Amateur Radio Service; they can be dispensed with as an argument.  What is applicable in Amateur Service, is technique and the basic understanding of radio technology.

Morse code as sent in Amateur Radio is sent as an interrupted, unmodulated carrier or continuous wave, (CW).  The basic knowledge involved in understanding how a CW signal is generated and how intelligence is transmitted over it is fundamental to understanding how radio works.  But a theoretical understanding of CW is not enough. It is important for Radio Amateurs to gain a practical understanding of CW and it’s attributes through hands-on experience. It’s simplicity and spectrum efficiency can only be fully appreciated through practical experience. *Today, the world’s communications systems and networks almost exclusively employ digital modulation schemes and protocols. These schemes all use the basic binary method of a series of ones and zeros in a serial sequence to generate a digital “word”. More sophisticated modulation and coding schemes incorporate this basic binary sequence into a complex composite algorithm, but in all cases, the fundamental digital word stays the same: a series of unique “on-off” sequences” that each describe a unique digital word. Except for the specific order of each “on-off” pulse, the nature of binary language and Morse code is almost identical. Morse code was the world’s first digital language!.

Consider further: Morse code is the original digital language, and the only digital language, which allows humans to communicate directly with a machine  (i.e.: computers) without the intervention of any external interfaces, or converters, etc. 

This unique aspect makes it indispensable for situations where a person must communicate with an automated
communications system, or un-manned station, using the simplest facilities available, (i.e.: emergencies, etc.).  All that is required is a simple radio transceiver and a Morse key. All these elements are essential components of the stated purpose of the Service, “…in which radio apparatus are used for the purpose of self-training, intercommunication or technical investigation by individuals who are interested in radio technique… ”. 

If Radio Amateurs are to be pursuers of the art and science of the “radio technique”, then a basic competency in CW is mandatory. In order to be sufficiently competent in CW, it must be sent and received at a speed that makes it useful and practical as a communications medium.  

A speed of 5 words per minute may be adequate for basic familiarity with the International Morse alphabet, but it is nearly useless as a practical means of communication. To effectively send messages via CW requires the use of prosigns, abbreviations and operational signals.

To do this requires a speed proficiency of at least 10 words per minute, and that is at very minimum.

One of the major complaints over the years has been the so-called difficulty in learning the Morse code. Within the last twenty years, both new, innovative computerized methods, as well as older, proven techniques have been successfully used to teach Morse code. The current approved technique using characters sent at high speed, with long spaces in between the characters, has demonstrated that any determined and motivated student can learn the “code”. With this “state-of-the-art” method of code training, the beginning student is sent the characters at an initial rate of 18 – 20 WPM, with spaces equivalent to approximately 5 WPM. Using this method, it has been demonstrated that it’s just as easy to achieve equivalent 10WPM proficiency, as it is to achieve equivalent 5WPM. There is virtually no difference in effort required other than the short time necessary to achieve the added 5 WPM.

“Many have also questioned the logic of maintaining a regulatory regime whereby operator proficiency in the Morse code is the standard applied in order to grant Canadian amateurs enhanced operating privileges in telephony.”

To be a Radio Amateur is be a "lover" of radio, one who studies it and appreciates all aspects of Amateur Radio as coherent whole, a complete system, if you will. One of the aspects of this system is Morse code, and therefore it is legitimate to demand proficiency in this aspect. Demanding proficiency in Morse is not a prerequisite to privileges in telephony, but a requisite in parallel with other, technical qualifications.

Morse code is not an isolated skill, disconnected from any other aspect of Ham Radio, but an essential element, integrally linked to all the other elements. Never the less, if the proficiency level in Morse is to be reduced, then the required level of technical qualifications should be made more rigorous. If such emphasis is to be made on telephony techniques, then a commensurate level of qualifications should be demonstrated. If Morse code proficiency is to be reduced, the technical qualifications must be increased.

As well, the prohibition on the building of transmitting apparatus by “Basic” license holders must be abolished, as this goes counter to the purpose of the Amateur Radio Service, “…self-training, … …technical investigation by individuals who are interested in radio technique…“.

To reiterate:

Morse code is a basic digital language, and the only one directly compatible with both man and machine and which allows one to communicate directly with the other, without technical intervention.

A 5 WPM proficiency is useless and impractical; with modern training methods, a 10 WPM proficiency is as easy to achieve as 5 WPM. With this in mind, I sincerely believe that it is a mistake to drop the 12 WPM Morse requirement for HF privileges. Any reduction in Morse proficiency must be balanced by an increase in technical qualifications along with the abolition of the prohibition on the building of transmitting apparatus by “Basic” license holders.

Quite frankly, I would like to see re-established an examination scheme identical to the one in place prior to October 1990; a single examination, identical to the original “Amateur” exam: 10 WPM Morse, theory and regulations questions, diagrams and essays.

Yours truly,

E. C. Sieb, VA3ES