Gazette Notice DGRB-003-05

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• Regulatory Changes and Background Documents

Department of Industry

Radiocommunication Act

Notice No. DGRB-003-05 – Revisions to Amateur Radio Operator Requirements Relating to Morse code

Notice is hereby given that Industry Canada is revising the amateur radio operator requirements relating to Morse code. Morse code will no longer be the sole additional requirement by which Canadian radio amateurs will gain access to the HF bands, but it will remain as one valid criterion.

Background

During the World Radiocommunication Conference in the summer of 2003 (WRC‑2003), a decision was made by the member administrations of the ITU to remove from the international Radio Regulations the mandatory requirement for proficiency in Morse code as a qualification for access to the bands below 30 MHz (i.e. high frequency (HF)) within the Amateur Service. In July of 2004, the Radio Amateurs of Canada Inc. (RAC), the national association representing Canadian amateurs, submitted to Industry Canada a proposal in which they made several recommendations as to how the Canadian amateur service could be restructured to recognize the changes in the international regulations. Industry Canada subsequently sought public comments to that proposal for a 60 day period starting August 20, 2004.

An analysis of comments received was published on Industry Canada’s Spectrum Management and Telecommunications Web site in January 2005. The analysis concluded that there is general support for the de‑emphasis of the ability to send and receive Morse code as the sole additional requirement for radio amateurs to gain access to the bands below 30 MHz. The Department, through this notice, is announcing its revised policy change to the required standards for radio amateurs accessing bands below 30 MHz.

Assessment of the RAC Proposal and Consultation

Prior to analyzing the elements of the RAC proposal, the Department first assessed the validity of the following three factors presented by the RAC as fundamental arguments:

1. There must be an awareness of the impact of this action (i.e. elimination of the Morse code requirements) upon existing reciprocal agreements and other arrangements which permit Canadian radio amateurs to operate in other countries and foreign radio amateurs to operate in Canada.
   
   
2. The Morse code examination must continue to be available in Canada for the benefit of radio amateurs who may require such a qualification for operation in another country, and for those who wish to acquire skill in the use of Morse code.
   
   
3. Operation in the HF bands requires special knowledge and skills not necessary for most operations in the bands above 30 MHz. This difference should be reflected in the examination arrangements.

Industry Canada has accepted the validity of these three factors, and consequently, they were taken as the basis from which the specific recommendations were assessed.

The Department then analyzed the public reaction to the RAC proposal from the extensive survey of the RAC membership as well as subsequent comments which came from the public consultation initiated by Industry Canada. The Department acknowledges that how one obtains access to the bands below 30 MHz is a subject of debate between Morse code enthusiasts and other amateurs. A sincere effort to determine a balanced approach to implement the decision made at the WRC has resulted in the following amendments to the Standards for the Operation of Radio Stations in the Amateur Radio Service.

New Criteria for Operation in the HF Bands

1. Morse code will no longer be the sole additional requirement by which Canadian radio amateurs will gain access to the HF bands, but it will remain as one valid criterion.
   
   
2. Amateurs showing superior knowledge of operational, technical and regulatory requirements by attaining an 80% score on the basic exam or passing the advanced exam, will also be granted access to the HF bands.
   
   
3. “Grandfathering” of existing amateurs will be based on the following criteria:

(1) Amateurs certified after April 1, 2002, who have demonstrated a superior knowledge of operational, technical and regulatory requirements by achieving a mark on the basic examination of 80% or above will be allowed to operate in the HF bands below 30 MHz.

(2) Amateurs certified prior to April 2, 2002 will be allowed to operate in the HF bands below 30 MHz based on the experience and knowledge they have acquired over this period of time.

(3) Amateurs holding basic and advanced qualifications will be allowed to operate in the HF bands below 30 MHz.

Implementation and Rationale

General Criteria

In recognition of an amateur's ability to send and receive Morse code as a valuable operational skill that can result in more efficient utilization of amateur spectrum from the perspective of occupied bandwidth as well as the ability to communicate under adverse propagation conditions, the Department will continue to include this criteria as a consideration in granting access to the HF bands. However, this is only one criteria and the measure of HF operator abilities should not be limited to this one facet of operator skills. As underlined in an RAC recommendation, knowledge of proper radio operating procedures, the regulations governing amateur radio, as well as technical knowledge important to preventing the emission of spurious radiation in the HF bands are arguably of equal importance.

Consequently, attaining an honours mark (80% or above) in the Basic examination will grant the amateur full HF privileges as well. The Advanced Certificate by virtue of its increased technical emphasis will also qualify the holder for access to the HF bands, plus it will continue to be used as a means of measuring an amateur’s ability to design and construct equipment, as well as his/her ability to oversee club station operations and repeater station installations.

Certificate Equivalence

Amateurs holding a Basic Certificate who have been certified for at least three years will automatically receive authority to operate in the HF bands. This is based on the rationale that three years of experience will have allowed the amateur to acquire sufficient experience to operate proficiently in the HF bands. Amateurs who received their Basic Certificate within the three year interval prior to the date of the new standards will be required to prove that they had attained a mark of at least 80%.

This three-year period has been selected to match the record keeping requirements which are expected of all accredited examiners. Amateurs who did not attain the honours mark on their original exam within the three-year interval will now have three options to attain HF privileges:

(1) complete the Basic exam and achieve an honours mark of 80% or above;

(2) complete the Advanced exam and achieve a pass mark of 70%; or

(3) complete the existing Morse code qualification.  

Non-Morse code related elements of the RAC proposal

The RAC proposal went considerably beyond the single question of eliminating Morse code as the means by which an amateur is evaluated for operation in the HF bands, and suggested additional changes to the amateur certification structure. However, some of the suggestions are outside of the scope of change that can be introduced at this time within the existing certificate structure.

When the General Radio Regulations were replaced by the Radiocommunication Regulations in the fall of 1996, the amateur operator certificate structure was simplified considerably, reducing the previous four certificates (i.e. Basic Amateur, Amateur, Amateur Advanced and Amateur Digital) to essentially two levels (Basic and Advanced) plus two levels of Morse code proficiency (i.e. 5 and 12 words per minute). The RAC proposal to create a third level of certification (the intermediate qualification with the associated building privilege at 2.3 GHz, plus the entry level certificate - recommendations 4, 8, 9 and 10) cannot be implemented without more extensive regulatory review and an amendment to create the new certificate levels.  Additionally, any major restructuring of the examination syllabus and examinations could only be introduced after such a review. The Department has no plans for a complete regulatory review of the radio operator certificate structure at this time.

The Department does agree to make adjustments to the existing two-tier certificate structure, with respect to pass marks and associated privileges, which the Department feels will achieve the intent of many of the suggested the RAC changes, while still adhering to the existing certificate regulations.

The Department agrees with the RAC's contention that 60% on a multiple choice format examination is not sufficient as a test of the candidate’s ability, and therefore the pass mark for the Basic and Advanced examination will be raised to 70% as suggested by the RAC.

Implementation

With the amending of the amateur technical standard, Radiocommunication Information Circular 2, Standards for the Operation of Radio Stations in the Amateur Radio Service (RIC-2) to reflect the criteria listed above, the regulatory amendments required to implement the changes discussed above have been completed. The Department has also used this opportunity to update RIC-2 and RIC-3 with other administrative details relating to the amateur service.

Obtaining Copies

Copies of this notice and documents referred to are available electronically on the Spectrum Management and Telecommunications Web site at: http://strategis.gc.ca/spectrum.

Official printed copies of Canada Gazette notices can be obtained from the Canada Gazette Web site at: http://canadagazette.gc.ca/publication-e.html or by calling the sales counter of Canadian Government Publishing at
(819) 941-5995 or 1 800 635-7943.

July 22, 2005

______________________
Jan Skora
Director General
Radiocommunication and
Broadcasting Regulatory Branch