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
                                
                          Danny Miller
                       3330 Mercury Lane
                  Las Cruces, New Mexico 88012
                    Date: November 20, 1998
                                
I, Danny Miller, file these comments on November 20, 1998 in the FCC's Notice of Proposed
Rule Making WT Docket 98-143.

              Telegraphy Examination Requirements
                                
As a new HAM Radio operator who had the opportunity to pass the no-code technician test, I
would like to focus my views on the no-code test for all levels of licenses.  I am also an
individual who has a hearing loss and learning the code is very difficult because of my hearing
loss.  I would encourage the Commission to look at what they can do to help individuals who
have disabilities, to be able to achieve successs in becoming a HAM with regards to a no-code
test requirement.

Because of my disability, I support a no-code requirement for all licenses.  In addition, to
individuals with disabilities in achieving success with a no-code requirement, technology is 

                                                  Page 2                                               Comments of Danny Miller
                                           WT Docket No. 98-143
                                                               
changing and code does not occupy as great a priority as it did in the early days of HAM radio.  
Code is now used less as a major communications mode.  It is my understanding that there are
many other modes of communications that amateur radio operators are using that is advancing
the art of new technology.  Amateurs are not administered any other types of tests in these
modes.                           

It is my view that if an individual desires to operate with code, they can d so, but it should not be
a requirement to get a license.  Code should be an individual choice, based on their desire to use
code just as it would be with any other mode of communication available to HAM operators.

The no-code license that was developed in 1990 proved to be a great success.  It provided a
means for many technically minded individuals to become radio operators.  It also provided a
way for individuals with a disability to get involved in amateur radio, especially if learning the
code was a problem due to a disability.

It is for these reasons that I respectfully submit my views regarding a no-code requirement for all
levels of licenses.  Thank you for your consideration.
Submitted by:

Danny Miller (KD5FLX)