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			"Dee D. Flint"  wrote
 Making the second level license examination equivalent to the current Extra
 examination sounds like it would drive people out of ham radio.  That's
 simply too big a jump to expect people to take in one swallow so to speak
 especially since this would affect current Technicians who entered the
 licensing program under a system with 3 tiers (or more for those who entered
 several years ago).  It would also take away privileges from existing Techs
 in that they are now receive renewable licenses but would not under that
 proposal.
 
 
 
 
 Dee,
 
 I suspect you have not read my complete proposal.  I'll attach a copy
 at the end of this.  After you read it your concerns should be
 addressed.  It is actually very accomodating of current hams of all
 classes.
 
 At the onset, current Novices and Technicians would have several
 options:
 
 1) Within the grace period they could upgrade to General or Extra, and
 such license would be renewable indefinitely.
 2) They could retain their current license and renew indefinitely.
 3) They could take the "Class B" test and gain full access to all
 amateur bands at reduced power.  (This license would expire after 10
 years, so this is eventually an "up or out" choice.)
 4) They could take the "Class A" test and gain full access to all
 amateur bands at full power.
 
 Current General and Advanced would have these options:
 
 1) Retain their current licenses and renew indefinitely.
 2) Within the grace period they could upgrade to Extra.
 3) Take the "Class A" test and gain full access to all amateur bands
 at full power (functionally equivalent to choice 2).
 
 
 
 Before the
 Federal Communications Commission
 Washington, DC  20554
 
 In the Matter of                          )
 )
 Amendment of Part 97 of the Commission's  )  RM-10787
 Amateur Service Rules to eliminate        )
 Morse code testing.                       )
 
 
 To: The Commission
 
 PERSONAL COMMENTS OF HANS BRAKOB, K0HB
 
 
 
 OVERVIEW
 
 These comments are submitted in response to the petition of
 NCVEC which requests elimination of test Element 1 (Morse Code)
 from the Amateur Radio service rules.
 
 I. Discussion:
 
 The instant petition requests the elimination of Element 1
 (5WPM Morse code test) from the required test for General
 and/or Extra Class licenses in the Amateur Radio service.
 
 I find no persuasive argument for continuation of this test,
 and support the petition to discontinue testing new applicants
 with Element 1.
 
 I am concerned, however, that other elements of the qualification
 tests are not adequate to ensure a high level of expertise in
 new applicants to the Amateur Radio service, and propose changes
 in the licensing structure to ensure that all 5 points of
 CFR 47 paragraph 97.1 (Basis and Purpose) are reasonably addressed
 in the qualification process.
 
 II Proposal:
 
 I propose that no new applicants be accepted for the current
 license classes and that after some reasonable grace period, no
 upgrades be available in the current licensing structure.
 
 A. New License Classes:
 
 I propose that new license applications be available
 in two classes, namely "Class B" and "Class A".
 
 The "Class B" license would have an entry-level test (basic
 regulations, safety, operating procedures, basic DC and AC
 electronics).  This class would have full frequency and
 mode privileges, power limited to 50W output.  The license
 would be issued for a period of 10 years, and be non-renewable.
 Holders of this license would be required to have 2 years
 experience as a licensee ("time in grade") before being
 eligible to upgrade to "Class A".
 
 
 The "Class A" license test would be of a difficulty level
 similar to the current Extra class test, and would have
 full privileges at power levels up to 1500W, equivalent to
 current Extra Class license holders.  This license
 would be issued permanently without requirement for
 renewal.
 
 B. Status of current licensees.
 
 Current licenses could be renewed indefinitely, and would
 retain their current operating privileges.
 
 Current Novice, Technician, General, and Advanced class
 licensees could up grade to "Class A" at any time.
 
 Respectfully submitted,
 
 H. Hans Brakob, K0HB
 
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