1998 Beiennial regulatory 
Review Aadmt., Part 97 of the 
Commission's Amateur Service
Rules FCC WT Docket 98-143

FCC Commissioners                
Washington, DC                     

John J. Keating, WA2FVL        
1147 Florence Ave                   
Union Beach, N.J. 07735

Dear Commissioners, 

I hold a General Class Lic. and have been a Amateur radio Op.
since 1957.
 
Here are my comments on lic. re-structuring.  Have (3)three
classes of licensing(Which is the goal of the FCC)and they are:

A-Extra @ 20wpm code proficiency, @ one minute solid copy.
B-General @ 13wpm code proficiency, @ one minute solid copy.
C-Technician @ 5wpm code proficiency, @ one minute solid copy.

We don't need the Novice, Tech plus, or the Advanced classes. 
Either meld the Advanced with the Extras, or the Generals in with
the Advanced.  In the 60's the Extra and Advanced where generated
as a Incentive classes.  I see the Advanced class as a overlap of
the General class, and as an unnecessary class license.  I also
agree that the Tech and novice class .... overlap of each other.

So to reach a 3 tier class system, I recommend the above
suggestion.

On the Morse code!  It took me awhile to learn the code, now I do
15 to 20 comfortably.  Its a form of discipline, which is needed
within the Amateur Community.  And as far as the written
requirement I believe in what the FCC sets as the standard of
electronic knowledge, needed.

As for the "Power" restrictions, with the advent of lic.
restructuring, the Tech class, if they get HF privileges, should
be limited to 100 watts CW only, and in the same operating
frequencies as the Novices now have.  And with the Generals and
higher, the standard 1500 watts output.(I remember being rock
bound and 50 watts and I was happy to have that)

As for Disability Waivers/Definitely needs some improvement. 
There has to be, two doctor certificates to indicate the
candidate for a lic. waiver.  And I recommend each state have a 5
member panel to do the testing.  The 5 member panel is unknown to
the lic. candidate, with maybe two alternates.  A minimum of
three test panel members is needed to pass the test and wave the
exemption.

I believe in the (3) member panel VE testing setup.  Therefore I
would be against the Advanced class giving tests.  Please keep
the... member test setup, I just think the door would be opened
to more abuse of testing. 

On enforcement, while there is a need for enforcement, I'm not
aware of the ARRL thinking.  We have OO's (Official Observers). 
They should be given some authority to warn in the name of the
FCC(with some training on this matter, and Certified) and have as
system of "How many citations for infractions, could be
initiated, ie[all OO's, E-mail monthly reports to the FCC and the
ARRL on given citations mailed out, and be registered mail to the
offenders]. When a known amount of citations FCC number is noted
on an individual, then a show cause or hearing before a volunteer
State panel of (3) OO's is required, before entering into a FCC
hearing.(Its a sort of a mediation panel, to give an offending
violator a chance to amend his ways before going to court.

I'm in agreement with "power" in the RF exposure table with pep
input to antenna.

Also in agreement with no one holding a FCC ticket, may apply for
a Reciprocal permit for an Alien Amateur License. 

Also in agreement to phase out RACES station license

All in all, if 3 licenses structure is the GOAL...go with  
 A-extra, B-general, C-tech.
20wpm     13wpm      5wpm

Thanks for giving me the chance to address the Commission, which
the ARRL didn't do for me.

Sincerely yours,

John J. Keating, WA2FYL
1147 Florence Ave 
Union Beach, N.J