Comments received on Gazette Notice DGRB-003-04

Consultation on "Recommendations from Radio Amateurs of Canada to Industry Canada Concerning Morse Code and Related Matters"

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Summary

On August 28, 2004, Industry Canada published notice DGRB-003-04 in the Canada Gazette,seeking public comment to the proposal submitted to Industry Canada by the Radio Amateurs of Canada (RAC), entitled, Recommendations from Radio Amateurs of Canada to Industry Canada concerning Morse Code and Related Matters.

In general, this proposal was intended to suggest how the Department might deal with the potential to implement relaxed Morse code requirements made possible as a result of the decision taken at the World Radiocommunication Conference 2003 (WRC-03). This decision gives the regulatory agencies of International Telecommunication Union member states the option of maintaining or removing the existing Morse code requirement for operating on the amateur radio bands below 30 MHz. However, the RAC proposal went substantially beyond the issue of Morse code, and made recommendations to modify the existing amateur certificate structure through the introduction of a new certificate (Intermediate) as well as a general increase in the pass level for obtaining the existing basic and advanced certificates. While these recommendations received various levels of support as indicated in the comments received, it is not clear whether each element of the proposal can be entertained without the benefit of a more comprehensive certificate review, and substantial regulatory amendments to accommodate an additional amateur certificate.

As the RAC's proposal consisted of twelve specific recommendations, we have attempted to gauge the level of public support for each of these elements as a first step in selecting a course of action with respect to the changes that will be made to the structure of the Canadian amateur certificate.

Results of Public Comment

During the 60 day comment period, the department received 150 submissions from individuals or associations (Amateur clubs, Radio Advisory Board of Canada (RABC) etc.) Where clear support or disagreement for each element was indicated, we attempted to capture and tabulate those opinions (see graphs). However, in many instances, the comments simply indicated agreement or disagreement with the general issue of relaxing the code requirements and this was captured in a separate graph.

This analysis shows that there is overwhelming agreement that Canada should move away from having a Morse code requirement as the sole means of gaining access to the amateur spectrum below 30 MHz. There were 123 comments in favour of relaxed code requirements and only 19 that were clearly opposed. The remaining six comments were either neutral or did not address that issue.

The Department will now formulate a plan to implement the changes that have emerged from this consultation process. The results will be published in a revision to Radiocommunication Information Circular 2, Standards for the Operation of Radio Stations in the Amateur Radio Service (RIC-2), and a notice to that effect will appear in the Canada Gazette at that time.

Graphical Representation of Comments Received

Graph 1:

Graph 2: