MJDePoint Public Safety and Private Wireless Division
Wireless Telecommunications Bureau
Room 8332
2025 M Street, N. W.
Washington, D.C. 20554

RE: WT Docket No. 98-143

The following are my comments relative to the Notice of Proposed Rule making
for Amateur Radio.

My name is Gary S. Dewey, amateur radio call NI8Z. I have been involved in radio
communications since my teenage years. First as a radio operator in the US Navy,
then as an OCR for the CIA, now just pursuing the "hobby" of amateur radio. I am a member of
ARRL,  a VE for the ARRL, a member of FISTS #5037. I am the vice president of the Cuyahoga
Amateur Radio Society. I also am a retired electrical engineer. My comments will be based upon
my experiences with most aspects of amateur radio obviously which includes the Volunteer
Examinations.

I turned to amateur radio after experiencing what I would classify as professional
communications activity. The US government has invested a lot of money in my
training. It also helped me to obtain a BSEE from the University of Toledo. It was
because of my interest in communications that I went back to college after ten years
working for the government. 

My main interest in amateur radio is the thrill of talking to someone who has
experienced the planning of putting radio equipment together, building a radio station,
then has the competence to use that equipment within the rules and guidelines that have
been established. I especially like the "international" aspect of the hobby. It is an exhilarating
experience to communicate with foreign amateurs. This is usually accomplished using
the "international" Morse Code. Isn't that an interesting name? International Morse Code.
Almost like the concept of Esperanto. A language everyone can use to communicate to
each other. There is no continent, no country that can be contacted where this means
of communication is impossible.

With the foregoing as background, let me address the issues in the NOPR.
First, under IV, Discussion, A, 
Number of License Classes, 
The number of  license classes are too many. It should be more like 3 or 4. The Novice license is
for all consideration useless. I have given two years of VE exams and no one has come
to an examination for the sole purpose of obtaining a Novice license. 
There should for anyone who cannot or will not learn the international Morse Code an amateur
radio license classification. 
My reaction to anyone wanting to be an amateur radio operator but just wants to operate
without all of the various means available is to let them "get a taste". These amateurs
will buy equipment, join clubs, participate in local radio events, even help in times
of emergency. This in my opinion is not even the entry level to amateur radio. Its like
amateur kindergarten. Most of these amateurs don't understand the phonetic alphabet.
Some go on to explore further, many will just stay with the few privileges they have.
If it helps some think the numbers of amateur radio operators are growing then so be it.
The important thing to remember is that even though this group many be large and
vocal, it would be like the kindergarteners telling the high school students what the
curriculum should be if dumbing down the skill level for other classes is there goal.

This license is about an half step above CB. Many amateurs become NO Code technicians
not as an entry to amateur radio but to become radio mobile operators. They use local repeaters
to chat, pass the time of day but not discuss the many aspects of improving their skills or
amateur radio. In fact, many of them "bad mouth" amateur radio. Keep this group in the
UHF/VHF portion of the amateur spectrum. 

The entry level to amateur radio would be where the amateur that understands all modes of
communication. As was stated in your background this includes "voice, teleprinting, telegraphy,
digital packets, facsimile and television". Not only understands these modes but has some
competence in how to use them. Naturally, this calls for understanding and displayed some skill
in using the "international" Morse Code. Call this group Amateur 3rd class or General Class or
C class, the name is not important. My recommendation is give them access to 1/3 of the HF
amateur radio spectrum.

Then have the other classes Amateur 2nd class or Advanced or B class, again the name is not
important but the frequency allocations are. Give them 2/3 of the HF amateur radio spectrum.
Last, the highest class Amateur 1st class or Extra or A class. Give them access to 100 per cent of
the HF amateur radio spectrum.

That is my recommendation for the license classes. 

B. Greater Volunteer Examiner Opportunities.
The idea that an Advanced licensee can administer the General Code test is a lesson in
common sense, since the Advanced had to pass the General Code speed to become an
Advanced licensee in the first place. I don't see this in helping get more VEs however.
The real issue is getting enough VEs to be able to administer all the tests. If anything,
the three VE rule is at issue. Also, the issue of not allowing those VEs with an Extra
license to administer all the tests is troublesome. Especially if one of them has obtained
the Extra license by the physically handicapped examination policy. Nowhere on the license or
on the VE badge is that stated. How does a local VE coordinator determine that or verify that?
This problem can be solved easily. Just revoke all handicap waiver for the Extra license.
See my comments regarding RM-9196.
I believe the VE program has worked to provide more testing opportunity. It has saved taxpayers
lots of money. I feel my recommendation will get more amateurs to the Extra class license
category. This will then most likely get more VEs who can administer all the tests.
My recommendation supports the idea of when a VE has a license higher than the one being
tested for a VE can administer it. But I wonder how many FCC officials had an Extra class
licensee when the FCC was giving the tests? And, I don't remember three being present.

C. Races Station Licenses
No Comment.

D. Privatization of Certain Enforcement Procedures
I am in favor of ridding the amateur radio bands on intentional malicious interference. The
trouble is you may get the ARP, the Amateur Radio Police. Being an avid Dxer, I hear this 
intentional interference too many times. I also hear the DXP, the DX Police. They sometimes
are as offensive as the malicious interference.  But alas, that does nothing to solve the 
problem. As with any enforcement, it needs to be swift and sure. Any action by the FCC
to announce a workable mechanism to ensure swift and sure enforcement can only be
seen as a positive condition. 

I feel the FCC has done little in the way of letting the amateur radio community understand
what the Amateur Auxiliary is or does. Personally, I know nothing of what this Auxiliary does.
How is one recruited? Can amateurs volunteer? What kind of training, equipment do they 
have or get? How are they contacted? Where are they listed? What procedures do they follow:
What avenues of communication are open to contact them? In all the material I receive, from
amateur radio magazines, bulletins, e mail, other that a few articles of some ham has been
caught, this Amateur Auxiliary is a mystery. 

Most amateurs can detect interference but not locate it. Is there an "interference HotLine"?

I have to agree with the ARRL. This Amateur Auxiliary should be used to greater advantage.
If it is in place, active, and working for the amateur radio community then shine some light
on it. Tell us or show us how a formal complaint is submitted to the FCC in a manner that
would allow for the swift and sure enforcement.  In general, the amateur radio community is
considerate and desires to keep interference to its absolute minimum. The FCC has left a
bit of a vacuum on this enforcement issue. 


E. telegraph Examination Requirements
My comments are based on the fact that before I could use a radio for the US Navy they
sent be to Radio School to learn the code. Also it was based on these skills that I was
hired again by the US government to work for them in Foreign Service. I am thankful for
this training but then the government got its monies worth. Now the FCC is considering
comments on telegraphy and this mode of communication. The FCC should keep in mind
all modes of communication are useful. All communication is based on language.
The Morse Code is a language. One can not use it unless they learn it and practice
using it. Being able to speak this language has giving me moments of exasperation as
well and exhilaration. But what language wouldn't. And again, to think that its an
international language. It was not easy learning the code, and especially to learn to
use it at 22+ wpm to graduate from the radio school. I have taught the code to many
individuals. I see many trying to take the CW test. I know the work and time they have
given to learning this new language. Passing the code test is a victory. A victory for
the individual who wants to participate in a new activity. All of this talk about telegraphy
having a decreasing role as a communications mode is MUTE. It is about as useful as
saying English has a decreasing role in the use a of  computer. I will be the first to say telegraphy
is not for everyone. Many flunk out of radio school. They went on to do something else. Anyone
not wanting to or unable to learn the international Morse Code can learn to something else other
than amateur radio.

The first mistake was the idea that is was the amateur community who wanted to create the 
Codeless amateur. It was organizations and manufacturers that wanted to increase the 
number in the amateur community for monetary reasons. The idea that this would attract more
amateurs who would be technically inclined missed the point that a lot of technically-inclined
don't talk to each other. Amateur radio operators are used to talking to someone. How do you
do that? By tapping on a key and producing characters or pushing a switch and using a
microphone to talk. Talking to someone is a mixed blessing. One must use the same spoken
language as the receiver but there are other factors, such as dialect, tone, loudness, clarity of
words, correct pronunciation, identical meaning of the word. International Morse Code
has little of that. It is just translating a character to a letter, sorting the letters out to identifiable
words, the words can be any language. The whole idea is two people are "talking" to each other
when they normally could not understand each other. 

The concept of telegraphers being in less demand is undoubtably true. They are going the
way of the dinosaur, the horse and buggy, and iron horse. The decreasing role in military
telegraphy communications, Maritime communications gives one the idea that telegraphy
is a dying concept. No one wants to sit a hour copying CW broadcasts anymore when the
message can be sent in a flash of the eyewink via satellite.  Everyone wants faster
communications. Look at the computer industry. Every month another new xxxMhz computer
chip in on a new motherboard. Cellular telephones will be worldwide soon. Digital
communications is everywhere. FAXs, point to point modem connections all are much faster
than CW. Besides with digital communications you get graphics, pictures (in color).
But the International Radio Regulations still apply to the Amateur Radio Service.
International Morse Code is a requirement below 30 MHz. We are past the Code - No Code
issue. The FCC created the Codeless Technician. It will keep the Codeless Technician in
some capacity of Amateur Radio Service.
 So being past the issue of "Code or No Code". Then the issue comes down to not do we keep the
"international Morse Code" but  at what competency level do you have to test. Years of 
government testing should have provided for ample documentation as to the difficulty of learning
various levels of CW code speed. I understand not everyone can learn CW at 5 wpm. However, 5
words per minute constitute 25 characters per minute. This has been a minimum requirement
from the beginning. 
Since there is an effort to downsize the number of license classes, then let the 5 wpm entry level
code be for the General, Amateur 3rd class or C class entry previously recommended.
The speed levels for the next two classes get to be very arbitrary. The reason for this is
from my experience, there are physiological barriers to learning CW. While I was learning
the code for the government, from the government, the code mental transfer from hearing to
putting it down on hardcopy shifts around 12 wpm. Most, once they learn the letters and numbers
can copy from 5 wpm up to 10 wpm without problems. At 12 wpm, the code recognition must be
"automatic", its now a matter of keeping up. After that 12 - 14 wpm 
barrier is passed then most everyone can get to 20 wpm with practice. Although, there is
another plateau at 18 wpm. I have been told by individuals who can copy CW that sometimes
the characters "just run together" without any separation after 18 wpm. I am sure that
due to individual hearing acuity this is a problem. For me, after 50 wpm I think it all runs
together without separation. Its just a fact. 
Now getting back to the speed levels after 5 wpm that I would think again should be based
on government testing in the past. But my recommendation would be to have a different
level for each amateur license class for HF band privilege. Its consistent, its fair. My suggestion
based on what I feel is the general trend to make things as easy as possible is to keep three
test speeds. Make them 5 wpm, 10 wpm and 15 wpm. What is the basis for this.
Five wpm has been and should be the entry level speed for any amateur to the HF bands.
This would allow all existing Novices and No Code techs to change to the new General,
amateur 3rd class or C class license. By making the next speed 10 wpm for Advanced,
amateur 2nd class or B class license you make it a step up for the existing General class.
It would only be a very minor retesting for 15 wpm, only 2 wpm faster for anyone who
has passed General and Advanced license to become Extra, amateur 1st class or A class. 
One concern I have is some of the amateurs who take the Extra 20 wpm CW test have mentioned
to me that they take this test for credit for the FCC Commercial license
credit. They say the get credit for the CW endorsement and save money doing it.
By moving the Amateur Radio Service Extra Class CW test to 15 wpm may stop 
that activity. But I assume the FCC will be dropping the CW requirement for the 
commercial licenses soon anyway.

I think though to make it a major shakeup the FCC would have to include with the
license structure, a frequency spectrum structure change. Maybe to the 1/3, 2/3, 100 per cent
model. What would the existing Extra class get with this change, maybe not much but
they have all the allocation they need anyway. Maybe make the digital band plan wider.
There will always be those that say why keep CW at three speeds for testing. My reply
to that is if they want to be involved with the International community you have to 
have the skill to use the spectrum skillfully. Amateur radio is not just for stateside
persons. That is what makes it the jewel it was set up to be. Lets keep the eye on the prize.
There is much international goodwill going on in the world due to amateur radio. 

As to the comments regarding RM-9196, the ARRL amendment allowing  telegraphy
examination credit for higher speeds due to disability. My comment is that this
disability waiver is a farce. It has been abused. It serves no real purpose other that to let
some amateurs have extra voice spectrum. The Extra class license is held by some
who have not passed a CW test and then if they become VEs they cannot administer the
tests. I feel I cannot express my complete lack of understanding why this waiver has not been
abolished. The FCC has set license requirements then allows a waiver? Make it simple,
if you cannot pass the license requirements, then one is not entitled to it, period. If you
can't pass the bar exam you cannot become a lawyer. If you cannot pass a medical 
examination, you cannot become a doctor. Do you want doctors to become less skilled?
What if a doctor has a handicap and is not skilled to operate, do you want a waiver created?
As a VE, I have had amateurs that I know use the waiver method to become Extra. I have
had VEs with Extra class licenses with the waiver exemption as VEs. Unfortunately,
none of them had any intention of using the CW spectrum. They basically wanted the
prestige of the higher class license. Oh, they had handicaps. Sugar diabetes, kidney
operations, both did not handicap them enough to be unable to take the test.  In our
society, we have great compassion for those handicapped. And well we should. There,
but for the grace of God, go we. But as much as  I am in favor of the trying the CW test under
any circumstance, no one should get a license based on a handicap waiver. It is unfair
to the handicapped who overcame the handicap to succeed. It is unfair to those that
have succeeded without handicap and see those with bogus handicaps be given the
same privilege. Have you ever seen the no armed man play the guitar? It has been done and
very well too.

E Written Examinations
My suggestion is to make the written portion representative of the real operating world.
Increase the number of questions for each written test for all elements.
The number of questions are too few. Each written test segment should have a minimum
of fifty questions.  The new percentile for correct answers would be the same for each written
segment, 80 per cent, 10 wrong maximum. This is reasonable from the number of written tests I
have seen. If they get more than 20 per cent wrong they more than not have greater that thirty per
cent wrong. One of the considerations of lowering the CW requirement was to make the written
portion tougher. This is my suggestion on a way of doing it. Again, what is the goal. The idea
is to gain new members into Amateur Radio Service with a level of competency to begin
to operate in the frequency spectrum that is allocated to them.

Would fifty questions to check by a VE impose any difficulty. It takes about a minute to check
answers. Do the VEs have any idea of the real skill level of the examined. No, that is left up to
the designers of the questions. Therefore, increasing the number of questions has little if any real
time impact on VEs. The concept of allowing VEs flexibility to determine specific contents of
written examinations and the specifics of that flexibility is interesting but troublesome. As a
ARRL VE , I have been very satisfied with the written testing material provided. I have not
been privy to input to the multiple-choice question pool. But then I don't feel I need to be.
My volunteer activity to provide the site, timing, VE group, administer the tests and record
the results is more that enough. To "play" with the questions or have some sort of flexibility
in selection of questions, in my opinion, puts more onus on the VE. I feel the question selection
on each test should reflect what the candidate should know based on "understanding" of the
activities in the Amateur Radio Service, not memorization of answers found in books or
manuals. I would like to see more " what would you do when such and such a situation occurs".
But then again I would like to see all amateurs retested periodically. That tells you how I 
feel about using it or losing it.

My experience in conducting VE sessions has been this. I have no idea what question
is being asked. Nor do any of my volunteer examiner assisting me. Only the candidate
sees the test. The answer sheet is graded by three VEs using a template. They just mark
right answers and wrong answers. The grade is determined and the rest is paperwork.
The tests get packed up and resent to the ARRL. I may be one of the few that do it this way but
I am not in anyway involved in the questions being asked. Should I be?  I think not.
The FCC in my opinion is responsible for the question pool. It now seems that it has
been farmed out the National Conference of VECs.  Two of the VECs, I am familiar with the
ARRL and W5YI. These two have divergent views of the Amateur Radio Service. Both
have financial interests in the VE process as well as Amateur Radio. However, ultimately the
quality of the Amateur Radio Service is up to the FCC. Do we want more Amateur Radio
Service People or better Amateur Radio Service people? 


Respectfully submitted,


Gary S. Dewey
NI8Z
7009 Ivandale Road
Independence, OH 44131-5328
216-642-8705
e mail: gdewey@en.com