Thank you for accepting my comments to the proposal for Amateur License
restructuring.  I think we need to simplify the license classes and process.
This would attract more individuals into amateur service and lessen the burden
on government. To start, I think we only need three license classes. We need
an entry level class, the average or middle license class and the expert or
advanced license class.

The entry license class would be for beginners in amateur radio. It should not
require code but need to have a written test on the rules and technical
matters. The technical matters should be just hard enough to require some
meaningful learning and not just memorizing facts. The privileges of this
class should be similar to today's Novice and Technician privileges. HF
privilege should be kept to a minimum on not so popular bands and limited to
low power voice. NO currently licensed amateur should be transferred into this
class. It would be ONLY for new amateurs after the rule change went into
effect.

The middle class would be where the average amateur would be licensed. To
upgrade from the entry class, you should be able to copy 5 wpm code and pass a
written test in rules and technical matters. Again the technical matters
should require some additional learning processes and not just facts.  It
should be similar to today's General/Technician written test. The privileges
of this license should be similar to today's General class license. Amateurs
current holding a valid Novice, Technician, Tech+, and General class for less
than 5 years should be put in this
class licence.

The expert or advanced class license would be the highest. To upgrade, a
middle license holder should be able to copy 10 wpm code and pass a written
test in technical matters. It should be similar to today's Advanced class
test. Privileges should be similar to today Extra class. Holders of a valid
General for 5 years or more, Advanced, and Extra should be put in this license
class. 

I have advanced the holders of today's General class license into the expert
class to give them credit for passing the 13 wpm code. Some General class
holders had to work hard to copy a minute solid, and even traveled to FCC
field offices in order to master that requirement. That accomplishment should
not be overlooked when we lessen the code requirements for the new license. A
general class who has held his licence for any length of time has experienced
most of the things he or she needs to be an expert.

Thank You
Dr M P Mullaly-Quijas
N0UEA