Before the
Federal Communications Commission
Washington, D.C. 20554

In the Matter of                        
1998 Biennial Regulatory Review       
Amendment of Part 97 of the Commission's 
Amateur Service Rules                 

WT Docket No. 98-143

COMMENTS ON PROPOSED RULE MAKING

William John Joseph Hoge
20 Ridge Road
Westminster, MD 21157

11 August, 1998

1.  I am a licensed amateur radio operator, W3JJH. and hold a
Technician class license.  I am also an electrical engineer with
over 25 years experience in various facets of the communications
industry.

2,  I believe that the Commission is correct in noting the
decline in the non-hobby use of Morse code as a communication
medium.  Morse code can be useful under certain conditions.  I
use it.  But it is not so useful that it should be used as a
filter to keep otherwise qualified individuals from becoming
licensed operators.  Learning the Morse code should not be a
hazing ritual to be inflicted on new hams.  While the Commission
is bound by international regulations to keep some Morse code
requirement for HF operators, the code level should be set at the
lowest level possible.

3.  I also agree with the proposition that the examinations for
higher classes of licenses should reflect the knowledge required
for the operating modes and procedures unique to those licenses. 
What are the modes of emission which and Amateur Extra licensee
can use which a Technician licensee cannot?  At present there are
none.  All of the modes which can be used on HF can also be used
above 50 MHz.  However, the operating procedures used on the HF
bands are different from those on VHF.

4.  Therefore, I respectful suggest that the 13 word/min and 20
word/min examinations be dropped and that only the 5 word/min
requirement remain for all classes of license with HF operating
privileges.  Further, I suggest that the written examination
elements for such licenses be devoted to HF operating procedures, 
HF propagation, etc., and that such material should be deleted
from any exams given for VHF-and-up licenses.

5.  Finally, I recommend reducing the number of license classes
to three. I recommend retaining the (no code) Technician class as
an entry level license with the same operating privileges as at
present, eliminating the Novice examination element as a
requirement for this license.  I recommend keeping the
General class license with full amateur operating privileges. 
The additional requirements beyond Technician for the General
license would be a 5 word/min and a examination on HF operation
as described above.  I recommend that existing Advanced and
Amateur Extra class operators be grandfathered in as Amateur
Extra class licensees.  These licensees would have no additional
operating privileges, but would be eligible to serve as Volunteer
Examiners and supervisory personnel in the Amateur Auxiliary. 
The additional examination requirements for new Amateur Extra
licensees would deal with examination procedures, advanced
EMI/EMC issues, etc.  I believe that the Commission's proposal
for renewal of existing Novice and Technician Plus licenses with
full CW privileges on the 80-, 40-, 15- , 10-m band is a
reasonable way of handling these licensees.

6.   I thank the Commission for its attention to these issues and
for its consideration of these comments.

Respectfully submitted,

W. J. J. Hoge