In the reference structure, I totally disagree with the direction
taken by the FCC.

First, your plans to combine the Novice, Technician and
Technician Plus categories into one category entitled "Amateur"
will only cause alot of the now licensed Novice and Technician
Plus licensees to either upgrade to General or higher or to
totally abandon Amateur Radio.   The Novice and Technician Plus
licensees have worked hard and long to get the requisite 5
wpm code.  The ones that can upgrade have and the ones that for
one reason or another cannot have remained at the licensee level,
but have not lost interest in "ham" radio.

As a Technician Plus, I worked very, very hard to achieve the
required 5 wpm morse code.  With a "slight" hearing disability
which makes hearing/catching the nuances of the dit dahs of morse
code it was very hard for me to achieve the 5 wpm needed.  And,
because of such,  I have not upgraded as I once very much wanted
to.   As a Technician Plus, I have avidly pursued several
interests within Amateur Radio including working within the
Amateur Radio Emergency Services and Radio Amateur Emergency
Services within the State of Virginia, I have maintained a
position within several clubs,  and I do a monthly newsletter.

Your upcoming proposed changes will lump my hard work in with
others who have no real interest in "ham" radio... those who are
now Technicians with no code!  Does your proposal have the
desired effect of making me want to upgrade to a higher level
with a 13 wpm morse code requirement? No! Because of my
disability with hearing the nuances of morse code, all your
proposal "ham" altogether.  And, I believe that I am not the only
one who will feel this way.

Instead of encouraging "hams" to upgrade, your proposal
discourages them. If Technicians wanted to upgrade, and under the
rules now, they could only do so by passing the 5 wpm code,  what
makes you think they will upgrade when you are making the rules
harder by asking for 13 wpm?  Most of the Technicians now do not
upgrade and with the requirement being 13 wpm to upgrade, even
less will upgrade.

I agree,  that there do need to be some changes.  I would like to
see the your proposed changes to incorporate the following:

1.  To incorporate the now Novice and Technician Plus Class
licensees into one category entitled Technician;  keeping the 5
wpm morse code requirement.

2.  To incorporate the now Technician (no code) Class into a
category entitled Amateur and keeping them as no code licensees.

Morse code is hard to learn at the 5 wpm requirement as it now
stands.  Very few no coders (Technicians) decide to upgrade into
Novice and Technician Plus as your findings point out.  Thus,  it
stands to reason,  that when putting the code to a 13 wpm 
requirement there will be even fewer who will want to upgrade.  
Thus limiting the number of coded hams.  But, while you are
limiting the number of coded hams, you will be adding several
times more noncoded hams.  This will put an overwhelming
stressful burden on the frequencies now available to the
non-coded hams.  To relieve this stress, perhaps changing the
he non-coded hams.  To relieve this stress, perhaps changing the
frequency allocations as they now stand would help.  Perhaps the
frequency allocations could be changed in the following manner:

   1.  The newly created Amateur Class level(as stated above)
should definitely have more frequency allocated to them, perhaps
the old Technician Plus allocations.

   2.  The newly created Technician Class level should be granted
the frequency allocations of the General class.

   3.  The General Class level should be granted the frequency
allocations of the Advanced class.

   4.  The Advance Class level could share or be granted part of
the Extra Class level frequency allocations as they now stand.

All in all, I agree that the Amateur Radio community as a whole
needs to see a change.  But your proposal as it now stands will
condemn the Amateur Radio community instead of allowing it more
growth from new licensees or from upgrading licensees.  Please
take the above submitted changes into consideration when making
your decision.

Thank you.

Bonnie V.  Smith, N4QPB
Technician Plus
Amateur Radio Licensee