Greetings:

I hold amateur license KB0VBJ, at the tech plus level. I have held my
license since 1992, and I have lived and operated in three regions. I have
used FM privileges, but I have planned actively to begin using HF
privileges during this time.

My first concern is the disposition of the tech plus class of license under
a new structure. Section 13 mentions that novice class operators would
retain their privileges, but no new licenses would be issued. That same
section states  that the tech plus class would be phased out, with some
language about holders of licenses issued in 1989. My assumption is tha the
tech plus class would be  treated in the same manner as the present novice
class, but I want to go on record to assert that this should happen.

The FCC solicits comments on the role of CW proficiency in licensing.
Section thirteen states that the only difference between tech class

operators and tech plus operators is that tech plus operators have passed a
code test. Further, tech plus operators, like tech operators, mostly use FM
and packet. These are literally true statements, but they seem to miss the
point of intent. A new Ham can become active in amateur operation in the
VHF and UHF bands with minimal financial investment, minimal equipment
involvement and minimal infrastructure. For many Hams, new and old, this
level of involvement suffices. For others, HF operation represents a
desirable goal, irrespective of an individual's present capacity to reach
that goal. I believe this is the real distinction between technicians and
tech plusses. I assert that licensing should recognize and accomodate that
distinction. I believe the ARRL proposal does so appropriately.
Additionally, the ARRL proposal gives appropriate attention to the role of
various levels of code proficiency.

In my own case, money concerns and apartment liveing concerns haves kept me
out of HF operation. I have found means to overcome both of these problems
lately, and I would like to enter the HF operation arena soon as a tech
plus code operator using QRP, low power, emissions. I would very much
regret losing that privilege. 

A further concern that I have not seen addressed bears on usage of
frequency bands. At present, with the exception of novice-only subbands,
large areas of the HF bands are accessible by all sorts of users, rather
like a lake or river used by all sorts of boats, from kayaks to commercial
shippers. I would like to see small subband protection in HF for QRP, or
low-power, users. Presently, even the novice subbands are permitted very
generous power outputs. QRP users use at mose one tenth the power permitted
to novice users. QRP is a growing segment of Ham use and deserves official
accomodation in light of its inability to overcome the inherent obstacle of
being overwhelmed by massively stronger signal.

Finally, no operator should be penalized by any licensing change. Subsets
of the amateur population that need help should get help. Innovation among
amateur must continue to be encouraged. Thank you   









                                                                  
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