RE: DOCKET 98-143

CODE REQUIREMENTS - Ignore the IARU Treaty as Japan does and DO
NOT test for ANY CW proficiency!  But if you determine the CW
requirement is a MUST, the MAXIMUM SPEED for FULL HF access
should be 5 WPM.  Actually, a speed of 1 (yes one!) WPM would be
quite adequate to meet the IARU requirements.  Although I am an
ARRL member, I hold "no stock" in the survey they supposedly took
on CW!  I believe all amateurs (except the minority Extra Class)
support the elimination or reduction of CW testing speeds to gain
HF access.  The IARU will drop the CW requirement in a few years
anyway.  I guess I should mention that I was "Code Tested" at
an FCC Field Office at 13 WPM for 1 minute solid in 1964.  If you
deem that CW testing is still a requirement for HF access, the CW
test should be of the "1 minute Solid Copy" type as opposed to
the multiple-guess variety.

LICENSE CLASSES - While your proposal for (4) classes is much
better than the current class structure,  I believe the ARS could
be further "streamlined" by going to ONLY TWO classes.  
"TECHNICIAN"....a NO CODE class with FULL amateur privileges
above 30 Mhz and a "GENERAL" class ticket which would be 5 WPM
maximum (only if necessary!) and have all the privileges of the
current EXTRA class ticket.  I think this is "real streamlining!

Only two classes!  Only the current NO CODE licenses would be
classified as "TECHNICIAN."  All others (including current
Advanced and Extra) would become the new "GENERAL."  This is
basically a return to the 1950's sans the "Vanity Class" Extra
and the 13/20 WPM. The only amateurs who wouldn't "like" this
are the current Extra's. These folks could maintain their "elite"
status by qualifying for the ARRL CW Proficiency Awards at any CW
speed they like - including LIGHT!

WRITTEN EXAMS - If you absolutely need to maintain more than two
classes of license, the difficulty on the TECHNICAL portion of
the highest class of license should be greatly increased.  The
level of electronics expertise required to pass the current Extra
class exam is meager at best!  Make this exam "full of calculus"
if you like.  I will be upgrading from my Advanced class as soon
as the absurd 20 WPM CW test requirement is dropped.  As things
are now, bonafide RF Design Engineers are "talked down to" and
made to feel "second class" to the Extras who may not be able to
build a "crystal radio" but can "beep real fast." It is high time
the FCC reserves the highest class of license for those who
actually do know "a thing or two" about RADIO! Spreading
sequences as opposed to "tapping two wires together" real fast!

OLD NOVICE BAND SEGMENTS - As you have proposed, give these over
to the MOST POPULAR mode of amateur radio - PHONE OPERATION!  If
you keep the four class structure as proposed,  make sure the
current NOVICE class can operate CW anywhere this mode is
authorized.....DC to light!

ENFORCEMENT - This is the MOST Important issue facing the ARS
today! If in fact, the FCC does not have a "secret agenda" to
"eliminate the ARS from within," enforcement absolutely MUST be
returned to something akin to the FCC practices of the '50's and
'60's!  PLEASE DO NOT EVEN CONSIDER PRIVATIZING THIS FUNCTION!!! 
Things are bad enough as they are!  How would you like to
ELIMINATE the enforcement function?  Follow these two simple
steps! 1) Monitor 14.313 (by day) and 3.901 (by night)
for a period of 1 month. 2) REVOKE the licenses of violators,
CONFISCATE their equipment and give them the choice of a heavy
fine or a prison term.  I believe you would find the rest of the
ARS would immediately begin "self policing" as practiced before! 
Of course, these "actions" would have to appear in print in the
leading amateur "rag" to have greatest effect."  I believe there
are only 50 - 70 "radio criminals" in the entire ARS.  These few
"breed the need" for ANY type of enforcement on HF.  If these few
had no "daily on-the-air presence" the remainder of the amateurs
would quickly adhere to the rules!  The FCC could "at least" be
pro-active in collecting the unpaid NAL's from certain amateurs. 
And other amateurs who have had their licenses previously
suspended for intentional, malicious interference BUT CONTINUE TO
OPERATE AS BEFORE, should have their tickets PERMANENTLY
REVOKED!  Yes, I'm speaking of K4OKA and WB20TK...the two most
famous "outlaws"  of amateur radio.  I'm sure I will not be the
only amateur to mention their callsigns and the word
"enforcement" in the same sentence!  Make an "example" of just
these two and the entire ARS will benefit greatly! (By the way,
it's WB20TK who has the $10,500 UNPAID NAL.)  The fact that these
two are still on the air daily is WORLD-WIDE PROOF THAT THERE IS
NO ENFORCEMENT OF THE U.S. PART 97!  (Even if a NAL is judged,"
you don't really have to pay it!)  These issues of code speeds
and the number of license classes aren't really important at all
when compared to enforcement.  That is unless the FCC "wants" to
see the ARS become something akin to 27 Mhz.  What is the point
of having ANY rules if they can't be enforced?  Do YOU slow down
on the freeway when you see a patrol car?  Why is that????  The
enforcement of the FCC MUST carry "at least" the same amount of
"fear."  The current lack of enforcement is destroying the ARS. 
In the ARS today, every amateur knows "there are NO patrol cars
on the road," and so "I can break any damned rule I please!'  I
realize "beefed up"  enforcement would cost money!  I (for one)
would be willing to pay $l00/year to renew my ticket if I knew
this extra revenue would go towards enforcement!

Other than the comments that I've listed above, I'm in agreement
with Docket # 98-143.  You've opened quite a "can of worms."  I
appreciate being able to provide comments on your proposal.  Just
in case anyone's tabulating....1 am....W8KTH....Advanced
Class.....first licensed as KN3YFU in 1962 at age 11.  Amateur
Radio led me to my vocation - I've worked as an engineer for 27
years in a Fortune 100 firm doing (among other things) EMC/EMI
mitigation and RF Comm Link design.  Good Luck in this massive
undertaking!  I leave you with one final (important) word.
ENFORCEMENT!! !!! !           73!

Keith R. Schreiber