Before The 
               Federal Communications Commission
                     Washington D.C.  20554
                                
In the Matter of                                  WT Docket No. 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:
     Duane Henderson,  KC5NID,  R.R.1  Box 171,  Mooreland, OK 73852, 
Submitted November 21, 1998.

     I am a No Code Tech licensed ham radio operator.  I currently serve as
President of Tri-State Amateur Radio Group in Northwest Oklahoma. We as a
Group serve as a Skywarn volunteers with the National Weather Service out of
Norman Oklahoma. We serve from time to time the public service needs of 
organizations and cooperate with local Law enforcement when needed for man
hunts etc.
       I think the code requirement for the HF privileges should be a two tiered
system.  The upper licenses set at 10 WPM,  an entry level of 5 WPM for a Tech +
license or entry license into HF.  The test of technical knowledge should be held to
a level high enough to assure the skills of the top licenses holders have the skills
and knowledge of the frequencies, equipment, and safety concerns of those
privileges.

     I agree with the elimination of the Novice license. However,  the No Code
Tech license privileges is what attracted me, and my wife, into ham radio,  I think
a small portion of one of the HF bands needs to be opened up for the No Code
Tech's to work with, with the phone privileges.  This would then encourage the
purchase of HF radio's and start the process of wanting more privileges on higher
class licenses.  The extra cost of HF radios, the learning of the code, the larger
antenna structures and the unknown of just what frequency or band to focus on,
when starting to buy gear and get on the air stops many of the No Code Tech's
from getting into the process of upgrading.  
     I think the technical knowledge should be held as a qualifying factor with
the upper class licenses.  I do not think the higher code speeds make a better
qualified person to handle traffic on a phone net.  I agree that Morse Code should
be preserved and be used if a operator desires that portion of ham radio privileges,
even to the setting off more space for code only,  but to hold that as a qualifying
factor is probably holding on to the past a little to tight,  and making the growth
and use of HF bands slower than what it should be.  I think it makes no more sense
than the qualifying of a person to program a computer before allowing one to
operate on the Internet under full Windows control.  I think the use of ham radio
frequencies could be better served by changing the license structure to reflect
these guidelines. 
     Thanks so much for the things that the Federal Communications
Commission has been doing to bring things up to modern standards.  The granting
of licenses and working through the electronic communications is great in the
speed of getting licenses to new ham radio operators and handling of upgrades.  
                                   Submitted By:

                                   Duane Henderson KC5NID
                                   R.R.1 Box 171
                                   Mooreland, OK  73852
                                   Date  November 21, 1998