In the Matter of                   )       NPRM 98-143
     )
1998 Biennial Regulatory Review -  )       RM-9148
Amendment of Part 97 of the Commission's     )       RM-9150
Amateur Service Rules.             )       RM-9196

COMMENTS OF DATE: September 20. 1998

                                 INTRODUCTION

Warren T. Reese
P. O. Box 4694
Santa Rosa CA 95402-4694

Internet: Radions@jps.net
Telephone: 707-527-8124

I have received the following FCC licenses:

- Los Angeles CA Dec 22, 1967 - Radio Telephone First Class P1-11-25495
- San Francisco CA Feb 11, 1976 - Amateur Extra Class WB6TMY AE-12-352
- San Francisco CA Sep 21, 1977 - First Class RadioTelegraph T1-12-2737
- Gettysburg PA Jul 18, 1994 - GMDSS Radio Maintainer License DM-GB-3090

These licenses have been maintained and renewed as their form has evolved
through the years.  The first 10 years of my employment was spent at
broadcasting stations across the United States in various capacities.
In 1976 I began 21 years service for Coastal Telegraph Station KPH.
15 years as a radio telegraph operator and 6 years more as the transmitter
technician.  Currently I am employed in a technical capacity in the
broadcasting industry.

I appreciate the opportunity to present these comments and request the
Commission to consider the possibility that I represent an example of
"Expansion of the existing reservoir of trained operators, technicians,
and electronics experts;" having started as an amateur in 1964 with the
Novice callsign WN6KXH.

                                 TEXT

In brief summary, I have four concerns:

1. Providing an influx of new operators to assure continued viability of the
    Amateur Radio Service.
2. Encouragement of technical proficiency and operating skills.
3. Alleviation of the ever increasing overcrowding in the HF amateur bands.
4. Protection of Amateur Service traditions.

In specific, I would like to comment:

A. License Classes (NPRM para. 12)

    I agree that there should be 4 license classes.  No amateur should lose
    present privileges; where applicable I recommend expanded privileges as a
    greatly preferable choice.

1. Introductory Class (Current No-Code Technicians)

a) Technician written exam
b) Privileges: Same as current No-Code Technician VHF privileges

2. Intermediate Class

    (Pre-1987 Tech, Tech Plus, Novice)

a) Written General Class exam and 5 wpm code element
b) Privileges HF Telephone: Same as current General Class License
c) Privileges HF digital and CW: Same as current Extra Class License

3. Advanced Class

a) Written Advanced Class & Extra Class exam plus 12 wpm code element
b) Privileges HF Telephone: Same as current Advanced Class License
c) Privileges HF digital and CW: Same as current Extra Class License

4. Extra Class

a) Holder of a valid Amateur Advanced Class license
b) Holder of a valid General Radiotelephone Operators License
c) Holder of a valid First Class RadioTelegraph Operators License, or a
    passing grade on applicable code elements.
d) Privileges: Same as current Extra Class License

5. Discussion:

a) The outline I propose is similar to the ARRL's July 1998 proposal and has
    an element that should enhance technical and CW skills. As with both the
    ARRL proposal and the NPRM, voice operating frequency privileges are used
    as a motivation.
b) The Introductory License technical exam should be eased as necessary to
    maintain an influx of new operators to the Amateur Service.
c) The Extra Class License should be an "aspiration" that leads the Amateur
    Service to create an "Expansion of the existing reservoir of trained
    operators, technicians, and electronics experts."  As such, anytime more
    than 5% of the total licensees achieve this goal, the requirements should
    be increased.  At present, requiring parity with commercial licenses would
    be appropriate, but should by no means be considered the maximum
    requirement to achieve this license.
d) To accommodate the ever-increasing congestion on the HF amateur bands, it
    is important and necessary to economize on use of bandwidth.  In
    accordance, this plan gives no increase to voice frequencies, where
    bandwidth is at it's greatest.  Instead, it gives enhanced frequency
    privileges to narrower bandwidth digital and CW modes.
e) In view of the history and tradition of the Amateur Radio Service, and in
    consideration of the ever-decreasing actual spectrum available to CW
    operators, this plan would create a new sub-band of the low end of each HF
    band limited to CW (A1A) emissions.  I would recommend setting 25% of each
    HF band aside for this purpose, but in no case in excess of 50 kHz.

B. Deleting the Novice Bands (NPRM para. 12)

    I concur with the deletion, but with the stipulation that the Novice bands
    should be released for digital modes, not voice/image modes.

C. How the Novice bands should be distributed (NPRM para. 12)

1. The Novice portions of 80, 40, 15, and Novice CW sub-band on 10 meters
    should be released to digital modes, not voice modes.
2. Added spectrum given to the digital modes should enable the
    establishment of CW (A1A) emission only sub-bands on the lower end of all HF Bands. 

D. Allow General (Intermediate) and Advanced VE's to test applicants of lower
    license class (NPRM para. 14)

    I concur completely. Good proposal.

E. How many levels of CW exam? (NPRM para. 24)

    I favor three levels: 5, 12, and 20/25 wpm.  

1. A 5-wpm element will help to secure an influx of new operators into the
    HF portions of the Amateur Service.
2. A 12-wpm element instead of 13 wpm will bring the Advanced Class into
    alignment with the Europeans under CEPT.
3. At present a 25-wpm plain language/20-wpm coded groups requirement using
    the existing First Class Radiotelegraph License code elements would give
    stature to the Extra Class license that it now sorely lacks.  At some
    future point, the code requirements for this license class could be
    increased to 30/25 or greater.

E. Type of CW exam (NPRM para. 24)

1. I favor a test of 1-minute solid copy out of 5 minutes.
3. Only use multiple choice or fill-in blanks on accommodated exams for
    persons with disabilities.

F. CW Exam Waivers (NPRM para. 25)

    I agree with the ARRL that the candidates for a CW exam waiver should
    attempt an accommodated test before being allowed a waiver.

G. Are the Categories of the Questions Adequate? (NPRM para. 27)

1. For the Introductory License the current question categories level of
    difficulty might well be reduced.  This license should be intended to
    create an influx of new operators for the Amateur Radio Service.
2. For the Intermediate Class License the present pools are adequate.
3. For the Advanced Class License the present Advanced & Extra Class pools
    are adequate.
4. For the Extra Class License at this time an appropriate question pool would
    be holding a valid General Radiotelephone Operator License.  Requiring this
    license to obtain the Extra Class would grant stature to this class of
    license it now sorely lacks.  In some future time, the requirements could
    be increased by requiring possession of the GMDSS, GROL, and Second
    Telegraph licenses and could even include a BSEE degree.  There should be
    no upward limit on the difficulty of obtaining this license; any time more
    than 5% of the total amateur population has achieved this level, it should
    be increased.

                                 CONCLUSION

I hope these comments prove helpful. Once again, thank you for the opportunity
to comment on the restructuring proposal.

Sincerely, 

Warren T. Reese
P. O. Box 4694
Santa Rosa CA 95402-4694

Internet: Radions@jps.net
Telephone: 707-527-8124