In my humble opinion, as an ARRL member, radio club education chairman for the past 4 years, and an involved parent and church group teacher for youth, I feel that the plan as stated by the FCC has areas that are in contrary to what the Amateur radio service is. If a restructuring of the license classes is in the works, then as in the past, it should be a positive move and not a negative one. The goal should be to a.) Increase the involvement and access to amateur radio. Every amateur that your plan can bring in is another emergency worker, another weather spotter, another public service operator. Much of what was learned in early radio days was pioneered by hams. b.) Keep current with the technology of today. The armed forces no longer uses CW. The Coast Guard no longer uses CW. True CW is an art that is learned, but is it an art that everyone must master to access the HF spectrum.? Why not approve spread spectrum as a valid mode for amateur radio? The ITU says CW is a requirement. A requirement for how long? In Canada the CW requirement is nil. In much of Europe HF access on phone is 5 WPM. Most of the world realizes that CW is outdated and only one form of communication and not THE requirement. Do we require that you are proficient in Packet operations? Is it required to be able to operate ATV? NO, and knowing these is fine, but not required. Use of CW as a mode is fine, but a requirement? Old time hams stuck in their ways call it a LID FILTER. They want to leave their bands alone. They do not want to allow others to use THEIR bands. And they will die saying it. If we do not use the HF bands we lose them. Listen to the operators in the 10M Novice band. You will find Novices, Tech-plus, General, Advanced and Extra class operators. I have yet to hear a bad operator in the band. Listen to 75M. These are mostly extra class operators that can do 25-35 WPM. Are they good operators just because they know high speed CW, not at all. In fact I refuse to let my children listen the the "extras" there because of their operating skills, or lack of. (not to mention the foul language and cursing) The ARRL plan for restructuring is both fair and incentive. It gives the Novice operators and Tech-Plus operators the privileges that operators in many of the other countries enjoy. It opens up the Novice bands to reallocation, but no one loses. A plan where someone loses privileges is just plan wrong. How is that to inspire the youth of today to be involved. Many of these "kids" know more about technology than most adults ever will. The change to No-Code tech did not create the mess that many thought it would. It did bring many out of the CB ranks however and turn them into fine radio operators. I speak as one of them. I have taught Radio Merit Badge Class at the Boy Scout merit badge camp at Camp Airy in Maryland. (Capitol Council, Frederick District) I have taught amateur radio license classes to youth for the Assembly of God Royal Rangers in Naperville, IL at Calvary Church. Many classes for the Fox River Radio League in Illinois. Many of the students were young. Classes from 8 years old to well into their 70's have become hams. They are much better operators than the EXTRAS on 75. CW does not make a good operator. Respect for the rules and each other makes good operators. CW doesn't do it. The rest of the world recognizes that fact. Why don't we? The knowledge of CW is fine. I think a spread spectrum mode would be great. Should we make it a requirement to use the HF bands? Phase Shift keying is a new mode that we are playing with, maybe it should be required to know how to build the discriminator circuit just to be able to use the HF spectrum. By utilizing the ARRL plan you lower the hurdle to be active in HF. The Novices and Plus class can start to proliferate their good operating practices into areas where the operators think that they make the rules. I respectfully request that the FCC look closely at the ARRL restructuring plan. It in incentive and fair to all good operators. Respectfully submitted.....Mike Urso KB9KFE