August 31, 1998
                              
                              
             Federal Communications Commission
  
                      Docket No. 98-143
  
                      RM-9148
                      RM-9150
                      RM-9196
  
  
               NOTICE OF PROPOSED RULE MAKING
  
  
       Listed below are my comments to Docket No. 98-143.  Comments are
  in reference to specific paragraphs as listed in the Docket.  From:
  
  Jo Sanford
  WA6UCI
  5779 N. Date Ave.
  Rialto, CA 92377
  
                   II. EXECUTIVE SUMMARY
  
  3.   I concur in reducing the number of license classes from 6 to 4.
  
                              
                       IV. DISCUSSION
  
  A. Number of License Classes
  
      12.   It would not be appropriate to delete frequency limitations for
      current Novice's, and Technician Plus licenses as any deletion
      would take away any incentive for them to up-grade to General,
      Advance, or Extra Class.
  
      13.   Licensees for the new Technician Class should be restricted to the
      VHF and UHF bands only.
  
  B. Greater Volunteer Examiner Opportunities
  
      14.   I concur with the commission's proposal to authorize Advance Class
      VE's to administer the Morse code exam to General Class examinees. 
      However, the Advance Class VE should have actually passed the code
      exam and not have been given credit pursuant to a doctor's
      certification.  Such a situation would be unethical.
  
  E. Telegraphy Examination Requirements
  
      24.   Three levels of Morse code should be implemented as follows: 20 wpm
      for Extra Class; 15 wpm for Advance Class; and 12 wpm for General
      Class with subsequent band restrictions.  Also, an examinee should
      fill-in-the-blank or copy one minute of code with no errors.
  
  
      25.   Eliminating the code element for the benefit of a few people with a
      disability is not sufficient justification.  In the three years
      that I have been a VE there have been two applicants with a
      physician's certification.  I do not agree with the conclusion " 
      that these proposals place an unfair burden on examinees with
      disabilities ". It is not a burden on examiners to accept a
      doctor's certification.  I have not seen any abuses by examinees of
      a doctor's certification.
  
  
  F. Written Examinations
  
      27.   The integrity of the examination and amateur radio would be
      greatly improved if the questions and answers were not made
      public.  The exact same questions and answers that appear on the
      exam also appear verbatim in various study materials.  A person
      can literally memorize all questions and answers for the exam even
      though test questions are taken from a large pool.  If a person
      knows their theory and regulations they should be able to answer
      any questions no matter how it is asked.  A high degree of
      integrity could be achieved and maintained by not making public
      exam questions and answers.
  
  
  
                           Sincerely,
                           
                           
                           Jo Sanford
                           WA6UCI
                           5779 N. Date Ave.
                           Rialto, CA