Date Filed:8/11/98 

I appreciate the FCC seeking input from the Amateur community
on this issue. I believe some simplifying of the Amateur
licensing structure is in order, however, dropping two classes is
too much. There is still a need for an entry-level morse code
test element with appropriate operating privileges. Given that
morse code is prevalent on all HF amateur bands, and is second
only to phone in quantity of QSO's in progress at any time (RTTY
and other digital modes combined run a distant third),  it is
mandatory that morse code be left as an amateur HF license
requirement. Dropping the novice class alone would still leave
the low speed morse element intact. Monitoring of the
"novice sub-bands" will reveal there is still substantial
activity in slow speed morse. People learning morse NEED a slot
of their own, even if in principle only, where they can work on
improving their code speed and operating techniques. Further, 
the novice sub-bands comprise only a very small segment of the
total amateur HF bands. Disposing of them, especially to
phone operation would be a severe dis-service to the amateur
community. Besides taking away the "slow speed havens", giving
this space to phone would only enlarge the already serious
garbage problem we have, particularly on 75 meters.

If any major changes should be made, it might be in the best
interest of amateur radio, and the public in whose interest,
convenience, and necessity we are allowed to operate, if the FCC
would/could encourage more growth in the digital modes. This is
where the technology explosion has taken place, not on voice.
Possible FCC designated digital sub-bands, some of which could be
taken from the phone bands, and more comprehensive test questions
regarding digital modes are two avenues.  I must emphasize at
this point that I am a dyed-in-the-wool CW man, but I recognize
the need for technological growth, and digital is it.

Regarding the tiers of code speeds,  I favor retaining the
present speeds and the class separations afforded by them.
However, I would not oppose some small reductions the higher
speeds (13 to 10, 20 to 18, for instance), if some corresponding
improvement in testing comprehensiveness were added. Frankly, 
answering a few questions, or copying one minute solid of five (a
20 percent copy) barely qualifies as communicating.

I cannot condone the disposition of the reduced power requirement
for beginning operators. This should be in effect for all tech
class operators. Improper handling of high power amps can be both
dangerous to the operator and people around him/her, and
degrading to our already crowded spectrum space.  Some experience
and knowledge is needed before one is qualified to take on the
responsibilities of a high power amp. Further, there is no need
for higher class operators to have to use higher power than
others operating in designated sub-bands.

Finally,  regarding the ARRL's proposals, I believe their ideas
do not represent the majority of amateur operators. The renaming
of our operating classes from the current to "class A, B, C, or
D" is demeaning to the amateur service. Further,  simplifying the
system, while possibly attracting a few more people to amateur
radio, will only dilute the level of technical expertise
therein. The technical quality of the amateur pool must not
suffer in order to increase numbers. That benefits no one, not
ourselves, or our fellow amateurs, nor our governments and the
public whom we so often serve.

Howard F. Holden
WB2AWQ-GROL-GMDSS/O-GMDSS/M-Radiotelegraph 2nd.