Before the Federal Communications Commission Wahington, 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 By Anne K. Fanelli, WI2G 541 Schultz Road Elma, New York 14059 (716) 652-6719 e-mail I am an amateur Extra Class licensee and a VE with the ARRL and W5YI VECs, and there are several aspects of the proposed Part 97 rewrite which are of deep concern to me-- specifically, those pertaining to telegraphy. In my opinion, there is a continued need for proficiency in International Morse telegraphy as a backup to satellite and automated terrestrial communications systems for distress and safety communications. Watt for watt, Morse is the most effective communications mode yet devised and particularly important during meteor showers and geomagnetic disturbances, which can wreak havoc with satellite communications and digital-mode throughput. In addition, the narrow bandwidth of Morse signals helps to conserve spectrum space, thus allowing the same number of amateurs to occupy a smaller band allocation. Many, if not most, amateurs are interested in building (or at least maintaining) their own equipment, and Morse transceivers are simpler in design and layout than transceivers utilizing other modes. On a personal level, there is the uniqueness of Morse communication in amateur radio. If I want to talk to someone, I can pick up the telephone more easily than by obtaining an amateur license. If I want to type to someone, I can do so over the Internet much more economically than by setting up a transceiver and wireless modem. But Morse telegraphy, for most of us, is unique to amateur radio--an avocation which offers an increasingly-rare opportunity to truly participate in technology (beyond programming a VCR!). This being the case, however, there is certainly room for simplification of the amateur license-class structure and testing requirements. I agree, reluctantly, that the Novice and Technician-Plus licenses can feasibly be eliminated, and RACES licenses discontinued because of the overlap in function between RACES and the Amateur Radio Emergency Service. Current Novices should be allowed to operate Morse with 200 watts output anywhere within the 80, 40, 15 and 10 meter bands and the current Novice subbands should be reallocated only to narrowband operations (Morse and digital modes). Morse requirements could be simplified to 10 words per minute for the General license and 18 wpm for the Extra Class. VEs should be continued to be allowed to determine how to test for code speed. However, I concur with the ARRL proposal to require VEs to attempt the higher-speed Morse examination for applicants with disabilities, because of the wide latitude allowed in testing and the abuses which have already occurred in this area. In the area of enforcement, I believe that the Amateur Auxiliary's function should be separated from the ARRL, to allow the majority of amateurs--who are not associated with the ARRL--greater participation in the enforcement process. Appearances to the contrary, the ARRL does not speak for the majority of amateurs. As for the written-examination process, I believe that the current list of topics covers current technology and contemporary amateur operating practices fairly well and no major changes are needed. I would like to see, though, a greater emphasis placed on station design, troubleshooting skills, and maintenance to counteract the current trend toward amateurs as "appliance operators." In conclusion, while I am far from certain that a drastic overhaul of Part 97 is necessary, much care and consideration is required to avoid mere change for change's sake or the illusion that all change is constructive.