Dear Sirs:

With regard to WT Docket No. 98-143,  1998 Biennial Regulatory
Review --Amendment of Part 97 of the Commission's Amateur Service
Rules, I wish to make the following comments:

I am an Amateur Radio Volunteer Examiner. I conduct classes in
introductory radio theory and Morse Code for those interested in
obtaining their Novice and Technician licenses.

In general, I believe that all applicants should be required to
demonstrate a more thorough knowledge of the radio theory than is
currently required in the existing Amateur examinations at all
levels.  I feel that the recent trend has been to relax the level
of real knowledge needed to obtain the various Amateur
Radio licenses.  If the amateur service is to continue to fulfil
its role as a place for the development of "the radio art," this
must not continue.

The Amateur service is somewhat different from other hobby
activities because it requires that its practitioners obtain a
federal license in order to pursue their interests.  Such a
License implies that  ;n exchange for privileges granted,  a
certain return must be made to the Amateur service. Amateurs have
a tradition of both unstinting public service,  particularly in
times of emergency or natural disaster,  and of advancing radio
techniques and knowledge through their understanding of,  and
expericence:en+:ation in  the art of radio communication.

I agree that the current License Class Structure contains
redundant and overlapping licenses and should be simplified. I
believe this can be best accomplished by the re-establishment of
just three (3) classes of Amateur Radio License: Technician,
General, and Advanced. I support the contention that the Novice
License has been supplanted i,y the current Technician Class
license as the entry-level Amateur license.

I feel that because this license class grants privileges on all
bands above 30 MHz,  the question pool should be amended :c 
include more questions pertaining to the characteristics of each
of these VHF  JHF and SHF bands. Questions should be included to
test knowledge of prclpagation, antennas, emission types, RF
safety issues,  repeater operation,  accepted band plans already
in place, satellite operation, packet and other digit<*; modes,
and Amateur Radio's tradition as a "gentleman's" radio servlcc,

I propose an examination consisting of 6(. 1-o 75 questions to
show that the applicant has adequate knowledge in these <ireas.
Because these bands are also the most frequently used during
emergencir!  :>I- local disasters,  I feel that additional
material needs to be introducer! :n address appropriate ways
Amateurs can interact with local authorities to pr,-i`-: de
emergency communications and support.

I feel that the entry-level license class (Jr-anting HF
priveleges should be termed General Class. All current holders of
a Novice or Technician-Plus license should be grandfathered into
the new General class. This license class should require the
applicant to demonstratcz knowledge of the characteristics of
the HF bands from 160 through 10 meters.  (:llrrent Novice CW
bands should be absorbed into the General bands, with no 
b-r>:-riction on power.

Propagation characteristics,  influence of sunspots and other
electro-magnetic phenomena on the HF bands, emission types, 
'Alementary receiver and transmitter theory,  modulation
techniques, elementary antenna theory, RF safety issues,
installation and station operation should (ii.1 be required
material for this
class.

Particular stress should be placed upon being a competent,
courteous operator-. Accepted band plans, and the repeated
emphasis on Amateur radio as a "gentleman's" service should be a
prominent part of the requirements for this license class. An
examination consisting of 30 to 45 questions seems adequate
to test for this knowledge.  Prerequisite for this license would
be the posession of a valid Technician class license  Band limits
for this class would be those of the present General class.

With regard to the requirement for Morse rode proficiency for
operation below 30 MHz,  I was interested to learn that the
international agreements impose no particular speed requirement.
I had been under the impression that a minimum proficiency of 5
words per- minute was required.

Accordingly, I propose a blanket Morse Code requirement of 5
words per minute for all amateur license classes permitting
operation below 30 MHz.  This requirement would be rescinded upon
internaTional agreement at a future World Radiocommunications
Conference. There shoulci be no possibility of obtaining a
waiver for this requirement.  I point out that currently this
level of proficiency is required before obtaining 3  'n:,ii- Jer
for higher speed Morse code requirements.

I offer this suggestion because I agree that the Morse Code is no
longer the primary mode of communication. Other techno-ogies have
have supplanted it. 1 also offer this suggestion because I
believe it will eliminate current abuses in the obtaining of
medical waivers for the high speed Morse Code requirements, which
I believe are widespreatl ind abhorrent.

It should be noted that this in no way limits those who enjoy
Morse Code operation and who wish to pursue this interest. I also
note that I have suggested stricter technical requirements III
,a11  license classes to ensure that operators who take advantage
of relaxed code requirements do not also profit
from relaxed requirements in other areas. ~!ew forms of digital
communication should be part of the focus of this suggest '~'~n
That is not in the interest of a vital Amateur service.


The license class which would confer al; Amateur priveleges on
all bands would be design Licensing, which, in my view, unfairly
depr-ived former Advanced Class operators of band segments which
they had t<zirly earned. This class would be a combination of the
current Advanced and Rx?-rz class requirements in an examination
of from 60 to 75 questions. ThtJ Yorse Code requirement would be
as I have stated above: 5 words per minute

With regard to Volunteer Examination testing, I note that there
are disparities between the various volunteer Xxamination
Coordinators regarding the level of acheivement required of
examiners. In an amendment to their rules effective Ganuary, 
1998,  the ARRL-VEC prohibits its examiners from administering an
examination for any element which the examiner has not passed
him or- her self.

Other VEC's permit thei? examiners to admi:l::,ter Morse Code
tests when their examiners have not passed the element
themselves, but instead hold medical waivers. I feel that this
constitutes an unacceptable state of affairs, and leads to
possible further abuses of the medical waiver option. I feel that
all Volunteer Examination Coordinators must operate from the same
se% of rules,  as set forth by the Commission

I would also suggest that volunteer examine-r-s may give exams
for any elements which they have passed. Thus,  General Class
examiners may test Novice, Tech and Tech Plus. Advanced class may
test for s;eneral and 13 words per minute Morse code.

Regarding abuses within the Amateur service.  : feel that
sufficient resourcs exist within the Amateur service to provide
self enforcement. However, what is lacking is the authority to
act,  and reliable follow up by the Commission on matters brought
to its attention. I ca.Ll upon the Commission to draft a suitable
reporting procedure.

I suggest that among those best able to inirlate action against
amateurs who are operating in violation of the Part 97 rules,
and the general norms of gentlemanly behavior,  are the Volunteer
Examiners. In many cases these same people are also conducting
classes for prospective amateurs.  Other resources such as the
Ama?e:r Auxiliary should also be cul+lvated.
   i

Regardless of the mechanism for observing and reporting, the
Commission must be responsible for supporting the
self-enforcement process. It must convey sufficient authority to
(observers to allow them to pursue abusive operators with the
assurance that their efforts will he acted upon in an appropriate
manner by the Commission.

I strongly object to the naming of the ARRL,  (American Radio
Relay League) as the primary body responsible for the
organization of such observers. The ARRL is representative of
only a small fraction of American camateurs. In my opinion, its
agenda is too self serving tc :ermit of its being used in so
sensitive an area.


I suggest the Commission institute procedures for recruiting
qualified, responsible observers.1 suggest that the Commission, 
and the Commission only, be responsible for adding endorsements
to the licenses of those whom it designates as observers.  I feel
that this responsibility should only be granted to those holding
the highest license class.  Those nominated should be subject
to stringent review, ano should be required to take special
training, as determined by the Commission. No private amateur
organization should be wholly in charge of observing dnd
reporting abuse::  jn the amateur service.

I support the Commission in this matter of restructuring the
Amateur service. Amateurs have a fine reputation for innova+:on
and public service. When ail the new technological services are
rendered .lseiess because of natural disasters or other types of
emergency,  lot :*;I11 still be the ham with a make shift antenna
who will be first on the ai:  'W must act to make sure that
tradition continues.

Respectfully submitted.

Anthony J Brent
WD7G