September 1, 1998 John J. Roessler K6BX 392 N. Westwind Dr. El Cajon, Ca. 92020 Phone: 619-447-3630 E-Mail: JRoess@worldnet.att.net To: Commissioners Secretary, Magalie Roman Salas Office of Secretary Federal Communications Commission 1919 M. St N.W Room 222 Washington D. C. 20554 Subject: FCC NPRM Docket 98-143 Biennial Regulatory Review-Amendment of Part 97 of the Commissions Amateur Service Rules Dated 10 August 98. Reference FCC NPRM Docket 98-143 the following comments are submitted: 1. IV Discussion A. 11-12-13 Agree to reducing classes of Amateur licenses from six to four by phasing out Novice and Technician Plus Licenses. However Novices should not be able to operate Morse Code "anywhere in the 80-40-15-10 meter bands". I recommend they be allowed to use the same frequencies as the General and Advanced in the 80-40-15-10 meter bands.A.14 Agree- Allowing Advanced Class and General class to administer tests to examinees in those elements for which they themselves have credit would allow the VEC to use a broader spectrum of Amateurs thus strengthening the VEC Program as a whole. 2. E Telegraphy Examination Requirements. E 24 I believe Morse Code as a whole should always be maintained as a vital part of the Amateur Radio License Structure. Amateur Radio has always been a "pool" for Radio Operators and Electronic Technicians for which the government could draw from in the event of Emergencies. Since we are Communicators and Morse Code is a form of Communications, Morse Code should be retained as a prominent requirement in the Amateur License Structure. However examination questions concerning the newer Digital Technology should be entered in the Examinations consistent with the progression of Digital Technology. Since the 5 word per minute code test currently required for Technician Plus Licensee's would be alleviated from the license structure I feel that a speed of 13 words per minute Morse Code Test is too high for entry into the HF Spectrum. More Amateurs of the Technician Class would upgrade with a requirement for 10 words per minute Morse Code Examination for the General Class License. Advanced Class should be required to pass a 13 word per minute Morse Code Examination. Extra Class should be required to pass a 20 word per minute Morse Code Examination. Morse Code examinations should be conducted in a uniform manner. The Multiple Choice type of Examination should be eliminated. One Minute of Solid Copy should be required for a passing grade; i.e. 50 Characters for General Class-65 Characters for Advanced Class- 100 Characters for Extra Class. E. 25 Concerning the Morse Code Waiver System currently in force. The Examinee should be required to attempt the higher speed Telegraphy Examination prior to being given credit pursuant to a Doctors Certificate. The requirement could be met by the Examinee receiving either a Sending or Receiving Test administered by the VE's. F. Written Examinations. F. 27 The current method whereby VEC's meet annually and determine contents of Examinations is Adequate. Contents of Examinations should remain uniform throughout the VEC. Questions should be taken from the Question Pool agreed upon by the various VEC's. John J. Roessler K6BX