84 Woosamonsa Road
Pennington, NJ 08534
29 August 1998


FCC Secretary
Magalie Roman Salas
Office of the Secretary
Federal Communications Commission
1919 "M" STREET N.W., ROOM 222
WASHINGTON, D.C. 20554

To the FCC Commissioners:

In the matter of the 1998 biennial Regulatory Review-Amendment of
Part 97 of the Commissions's Amateur Service Rules, FCC WT docket
98-143:

I have been a ham since 1972. have held an extra Class license
since 1978 and have been a volunteer Examiner with the ARRL 
since 1985.   I have taught innumerable ham classes to students
from 7 to 88 years of age in this area since 1975 and I am 70
years old.  I spend at least 50% of my air time using code.

With respect to the code requirements, I favor lowering the code
requirements for General Class to about 5 to 10 wpm, perhaps a
compromise at 7 wpm.  I favor lowering the Extra class code test
at 12 or 13 wpm.  As a VE, I feel that the code tests should
emphasize comprehension (the "real world") rather than perfection
and thus would like to see the tests continue to be the multiple
choice type that I have been using for many years.

With respect to frequency privileges, I would like to see an
expansion of the frequencies available for SSB at the expense of
CW frequencies, many of the latter being vastly underused.  I
would like to see some expansion of space, SSB and CW, for the
expected additional numbers of new Extra Class operators, perhaps
another 5 or 10 kHz in each band edge.

With respect to doctors' certifications to excuse those with
disabilities from higher speed CW exams, as a VE I have not seen
many of these in 13 years, but probably 30-50% of those I have
seen seem to show that the doctor had no idea of what were
acceptable disabilities, but merely took the patient's word that
he was having trouble passing the code test.  On the other hand,
I don't feel that a few slipping through the system will really
make much difference, especially when we are talking about
lowering (eliminating?) the CW requirements.

With respect to the written exams, I feel that they should be
kept quite broad in scope.  Maybe I don't use some of the more
"up-to-date" technologies today, but who knows what my interests
may be next year.  in terms of the exams themselves, as a VE I
would not like to go to any essay-type exams when it comes to
having to correct them.

With respect to phasing out the Novice Class, in practice that
has already almost happened.  I don't remember when we gave the
last Novice Exam.

With respect to allowing Advanced Class operators to administer
General Class exams, it really is of little help to most of us. 
If we accept walk-ins, we have to have an all-extra Class VE team
in case we get someone coming in for the Extra Class exam.

sincerely,

Don Wright/AA2F

cc: ARRL