FCC Consolidates Commercial Radiotelegraph Licenses & Related Issues

[W3WN]

From today's FCC Digest:

AMENDMENT OF THE COMMISSION'S RULES CONCERNING COMMERCIAL RADIO OPERATORS.
Amended Part 13 of the Commission's Rules Concerning Commercial Radio Operators. (Dkt No. 10-177 ).
Action by: the Commission. Adopted: 01/08/2013 by R&O. (FCC No. 13-4). WTB
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-13-4A1.doc
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-13-4A1.pdf
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-13-4A1.txt

In this Report and Order, we amend our rules concerning commerical radio operator licenses for maritime and aviation radio stations.
< snip >
As supported by the commenters, we will consolidate First Class Radiotelegraph Operator's Certificates and Second Class Radiotelegraph Operator's Certificates into a new license class, the Radiotelegraph Ooperator License. Radiotelegraph Operator License applicants will be required to pass written Elements 1 and 6, and Telegraphy Elements 1 and 2.
< snip >

[kb2vxa]

That makes no sense except perhaps consolidating existing licenses like they did with radiotelephone. What baffles me is an applicant for a T1 must have one year experience in sending and receiving public correspondence by radiotelegraph at a public coast station or both. Now with consolidation has that requirement been dropped? Another strange thing, why the license when nobody but hams use CW anymore, even the military went digital. When the FCC stops confusing itself maybe it'll stop confusing us.

[W3WN]

According to the FCC documents, they recognized that it was almost impossible to get the 1 year experience to move from a 2nd Radiotelegraph to a 1st... so yes, the new Radiotelegraph Operators License will no longer have the 1 year experience requirement.

The documents also explain under what circumstances (primarily maritime & aviation) the RTOL's are needed -- it's not just for sending code.

[kb2vxa]

Yes, it's required for inspection and maintenance which at least to my thinking would be covered by the GROL. I guess they have the CW requirement because there are a few beacons still around.

[N2NH]

Seems that elements 3 and 4 have been made a bit easier. IIRC, the requirement used to be 15 minutes at 35 WPM for the 1st Graph and it was send and receive.

[W6AJ]

The Radiotelegraph license is still required in a few limited cases. I am one of the radio operators on the SS Lane Victory which has a radiotelegraph station (KECW). We are not allowed to move the ship without a licensed radiotelegraph operator on board.

Has anyone heard an implementation date for the new rules?