Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of:	)    WT Docket 98-143)
	)
1998 Biennial Regulatory Review -	)
Amendment of Part 97 	)
of the Commission's	)
Amateur Service Rules	)
	)


I. COMMENTS of John E. Leonard, Jr.

	1.  John E. Leonard, Jr., hereby submits his comments in response to the Notice of 
Inquiry    in the above-captioned proceeding.  In the Notice, the Commission has solicited 
comments regarding the proposed changes to Amateur Radio Service to eliminate 
unnecessary and duplicates rules and to streamline licensing processes.

II. Interest of Mr. Leonard

	2.   He is the holder of Amateur license WA6UAR,   In late 1959 he was licensed as 
KN3HSL; a Novice class license.; subsequently during 1964 as WA3CUB, then Technician 
class license.  Relocation resulted in the issuance of WA9UVU; followed by the creation of the 
Technician Plus: resulting in the current WA6UAR.  Amateur Radio is a hobby for him, and has 
no commercial involvement in relation to Amateur Service.

	3.  Commercial involvements have created his filing of comments with the 
Commission in relationship to the services pertinent to Parts 73, 74 and 94 of the Rules.  The 
Commission's efforts with this Notice are to be applauded, and its recognition of perceived 
realities of this Service.

III DISCUSSION
	4.  The Notice has asked for comments regarding  Telegraphy Examination 
Requirements and Number of Licensee Classes.  Considerable efforts have been extended by 
the American Radio Relay League (ARRL)  to present possibilities that have been discussed 
at great length among members of this Service.

A. Telegraphy Requirements

	5.  The historic significance of the telegraphy requirements exist upon a legitimate 
requirement.  That requirement can relate to emergency, safety and similar situations.  With 
the state of technology, devices or equipment can exist to both send and receive information 
using telegraphic techniques..  Such would not provide the inherent understanding that may be 
required in actual use of telegraphy during emergencies.  It may be viewed as learning another 
language.  Languages are only mastered by being able to read, write, listen to (understand) 
and verbally present (talk) the specific language.  The same applies to international Morse 
code.  Morse code is but one of the languages necessary for participation in this hobby.  The 
three speed structure presented in the Notice, and supported in other filings, seems the ideal 
solution.  Such should result in further interest in the hobby by others.

B.  Number of Licensee Classes

	6.  With the actual numbers of licensees being issued by the Commission, the need 
for a code-less class exists.  The numbers of applications received in 1997 by the 
Commission  for the no-code (21,416) as compared to Novice (961) emphasize this need.  A 
need does, however, continue for telegraphy communications.  Three (3) speeds (5, 10 and 20 
words-per-minute) to support the associate three (3) Classes  of licenses is valid.  Thus four 
(4) classes seems appropriate for the Amateur service.  The specifics as suggested by the 
ARRL seem very acceptable, thus specifics are not presented here.

Conclusion

	7.  The underlying concepts presented by the Commission, and exemplified by 
comments from the ARRL and others, are sound and in the best interest of the Amateur 
Service.  After almost four decades of involvement with this service, I add my support to the 
concept.

Date: 16 November 1998	Respectfully submitted,
	John E. Leonard, Jr.




	By: ___________________________
	John E. Leonard, Jr.
  Amendment of Part 97 of the Commission's Rules, Amateur Radio Service, WT Docket 98-143, 
  Notice of Proposed Rule Making,(August 10, 1998); Errata (August 31. 1998) (hereinafter "Notice").
   American Radio Relay League (ARRL), multiple filings, including July 22, 1998 Letter.
  See NPR Docket No. 98-143, IV, A, 12.
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