Comments of Thomas R. Swisher, Jr., WA8PYR In the matter of WT Docket No. 98-143, including petitions RM-9148, RM-9150 and RM-9196, adopted July 29, 1998 and released August 10, 1998. Commenter has been a licensed amateur radio operator since 1980, having been originally licensed as KA8KCE (Novice Class), then upgrading to N8GQK (Technician Class) in 1985. Commenter now holds Technician-Plus class license with "vanity" callsign WA8PYR. Commenter is also a public safety professional, having served as a full-time police and fire dispatcher for 12 years. Part I - Comments on Proposed Licensing Structure In regard to the Commission's discussion regarding restructuring of the licensing classes of the Amateur Radio Service, I am in agreement with the Commission's opinion that the licensing structure of the Amateur Radio Service is in need of revision, but feel that several changes are necessary. 1. Novice, Technician and Technician-Plus Class Licenses I agree that Technician license class should be retained as an entry-level VHF license, and that the Novice and Technician-Plus Class licenses should be phased out. However, I do not feel that "grandfathering" existing Novice and Technician-Plus licensees would be a very efficient way to simplify the licensing structure. A more appropriate alternative is presented below in connection with my comments regarding the General Class license. 2. General Class License As to the structuring of the General Class license, I feel that some changes are necessary to the Commission's proposal. As there is a need for a "codeless" entry-level license, fulfilled by the Technician Class, there is also still a need for an entry-level HF class license. This is especially so since, as noted in sub-section E, parts 20-24 inclusive of the Commission's comments in WT Docket No. 98-143, there is a greatly diminished need for telegraphy. Telegraphy is a slow, relatively inefficient communications mode which is no longer required for communications and has for the most part been phased out by most commercial and military users in the world. That this is so is demonstrated by the fact that most maritime services, as well as the United States Navy and the United States Coast Guard, have mostly or completely phased out telegraphy operations on the HF bands. Telegraphy's day has passed, and the time has come to consider a codeless entry-level HF license. Also, providing emergency communications is a vital facet of the Amateur Radio Service, and as a public safety professional in addition to being an amateur radio operator, I have seen this demonstrated time and again by the valuable service of radio amateurs during times of emergency when all or most other public safety and commercial communications services are unavailable or are seriously overloaded. However, this function of the Service requires not only capabilities in the bands above 50 MHz for local emergency communications, but also communication capabilities in the bands below 50 MHz, in that most long-distance emergency "nets" operate in these bands. While the large pool of Technician Class licensees is invaluable in providing local communications, the availability of licensees in possession of higher-class HF privileges is sometimes limited, leading to a shortage of operators qualified to operate on these long-distance HF "nets". I feel that the public good and the needs of the Service would be better served by making the General Class license an entry-level HF license, with no Morse code requirement and a very stringent written examination. The General Class license should confer all privileges and power levels in the General Class sub-bands as well as in the restructured Novice/Technician Plus HF band segments as suggested below. Since Existing Novice and Technician-Plus licensees have already demonstrated basic proficiency in the International Morse Code, and are already in possession of HF and VHF CW and voice privileges (in the case of the Novice Class license, limited VHF privileges in some bands), Novice and Technician-Plus licensees should become General Class licensees. While this is an increase of HF privileges that existing Novice and Technician-Plus licensees are already in possession of, many of these licensees are already experienced operators and would fit in well on the HF bands noted below. This will serve the advantageous purposes of simplifying the licensing structure, providing a larger available pool of operators capable of handling traffic on medium- and long-distance HF "nets", and increasing the opportunities for participation in the Amateur Radio Service. In accordance with the phasing out of the Novice and Technician-Plus license classes and making those operators General Class licensees, and keeping in mind the diminished need for telegraphy, the existing HF sub-bands could be "refarmed" as follows: 75/80 meter band: 3575-3700 kHz General CW/data 3525-3700 kHz Advanced CW/data 3500-3700 kHz Extra CW/data 3800-4000 kHz General voice 3725-4000 kHz Advanced voice 3700-4000 kHz Extra voice 40 meter band: 7050-7125 kHz General CW/data 7025-7125 kHz Advanced CW/data 7000-7125 kHz Extra CW/data 7200-7300 kHz General voice 7150-7300 kHz Advanced voice 7125-7300 kHz Extra voice 30 meter band: No changes. 20 meter band: 14050-14150 kHz General CW/data 14025-14150 kHz Advanced CW/data 14000-14150 kHz Extra CW/data 14225-14350 kHz General voice 14175-14350 kHz Advanced voice 14150-14350 kHz Extra voice 17 meter band: 18090-18110 kHz General CW/data 18078-18110 kHz Advanced CW/data 18068-18110 kHz Extra CW/data 18140-18168 kHz General voice 18125-18168 kHz Advanced voice 18110-18168 kHz Extra voice 15 meter band: 21050-21150 kHz General CW/data 21025-21150 kHz Advanced CW/data 21000-21150 kHz Extra CW/data 21250-21450 kHz General voice 21175-21450 kHz Advanced voice 21150-21450 kHz Extra voice 12 meter band: 24915-24930 kHz General CW/data 24900-24930 kHz Advanced CW/data 24890-24930 kHz Extra CW/data 24950-24990 kHz General voice 24940-24990 kHz Advanced voice 24930-24990 kHz Extra voice 10-meter band: 28100-28300 kHz General CW/data 28050-28300 kHz Advanced CW/data 28000-28300 kHz Extra CW/data 28400-29700 kHz General voice 28350-29700 kHz Advanced voice 28300-29700 kHz Extra voice Should a codeless entry-level HF class of license fail to meet the Commission's approval, I feel that a minimum requirement of 5 words-per-minute coupled with a stringent written examination would be perfectly sufficient for the entry-level General Class license. These suggestions for the restructuring of the General Class license will not only meet the Commission's goal of simplifying the Amateur Radio Service licensing structure, but will also provide the Amateur Radio Service with a perfectly acceptable entry-level HF license class. They will also ensure that no one loses any operating privileges whatsoever, and will also, as noted above, provide a larger available pool of operators capable of handling traffic on medium- and long-distance HF "nets", and increase the opportunities for participation in the Amateur Radio Service. 3. Advanced Class License I feel that the current Advanced Class license is in need of major changes, which will not only reflect the reduced importance of telegraphy in the communications needs of today and the future, but will also reflect the need for a corresponding increase in technical knowledge. In regard to the CW requirement for the Advanced Class license, I feel that it would be sufficient to require a basic 5 word-per-minute CW requirement. However, commensurate with the increased operating privileges of the Advanced Class license, the written examination should be made much more challenging. While it is felt by many today that the present Advanced Class license examination is the most difficult, the new Advanced Class license should be even more challenging, with greater emphasis on technical subjects, rules and regulations, and especially proper operating practices. The 5 word-per-minute CW requirement and a much more challenging written examination would provide a logical step up from the suggested entry-level HF license. 4. Extra Class License Keeping in mind the need for a simplified, yet logical and orderly licensing progression in the Amateur Radio Service, I feel that the current Amateur Extra Class license is in need of some overhaul also. The CW requirement should be lowered to 12 words-per-minute; this would still provide a more challenging step up from the Advanced Class license suggested above, yet would more accurately reflect the reduced need for telegraphy, and would fit in very well with the idea of simplifying the licensing structure. However, in addition to the 12 word-per-minute CW requirement, the written examination should be made even more challenging than that for the Advanced Class license suggested above, with even greater emphasis on technical subjects, rules and regulations, and proper operating practices. The 12 word-per-minute CW requirement and a highly challenging written examination would not only provide a logical step up from the suggested Advanced Class license, but would also make the Amateur Extra Class license a true pinnacle of achievement for the Amateur Radio Service. Part II - Comments on Volunteer Examiner Structure In regard to the Commission's discussion regarding restructruing of the services of Volunteer Examiner, I am in full agreement with the Commission's opinion that changes are necessary, and feel that the changes proposed by the Commission and the American Radio Relay League are perfectly suited to the needs of the Amateur Radio Service. Allowing Advanced Class operators who are VEs to prepare and administer examinations for a General Class operator license, and allowing General Class operator licensees to prepare and administer examinations for Technician Class operator licenses, will be a great benefit to the Amateur Radio Service by increasing the number of available Volunteer Examiners and thereby has the potential to increase the opportunities for individuals to take the necessary examinations for the Amateur Radio Service. Part III - Conclusion In my opinion, the proposal (with the changes suggested above) of the Commission to simplify the licensing structure of the Amateur Radio Service and the structure of the Volunteer Examiner Corps is merited, and would be of great benefit not only to the Commission in that it would significantly reduce the burden on the FCC, but would also be a great benefit to the Amateur Radio Service by simplifying the licensing structure; by continuing to provide for entry- level HF and VHF licenses; by providing for more stringent written examinations that will more accurately reflect the communications realities of the present day; and will also provide a larger available pool of operators capable of handling traffic on medium- and long-distance HF "nets", and increase the opportunities for participation in the Amateur Radio Service. Signed, Thomas R. Swisher, Jr. WA8PYR