June 2, 1999

William E. Kennard, Chairman
Federal Communications Commission
455 12th St. SW
Washington, DC 20024-2101

Re: WT Docket 98-143

Biennial Review and Restructuring the Amateur Radio Service

The American Radio Relay League (ARRL) recently urged the FCC to act "without delay" on Amateur Radio restructuring and has suggested that the Commission adopt the League's restructuring plan as its own in order to speed up the process. While this may be in the best interest of the ARRL, I do not believe it is in the best interest of amateur radio. I ask that you give this process careful consideration before any significant changes are made to the amateur radio service.

After personally reviewing many of the comments and reply comments submitted to the Commission, I believe that the proposal developed by Alan Wormser, Fred Adsit, Michael Dinelli, and Tim Billingsley offers the best compromise. This plan, not the ARRL’s, offers the best guarantee that the Amateur Radio Service will maintain the high technical skills necessary to stay relevant in the next century.

The Novice bands must be allocated to digital modes (not voice, as ARRL suggested), if they are to be "refarmed" at all. The first part of the next century will see rapid advances in digital modes, and expansion of analog voice frequencies would only hinder progress in the Amateur Service. PSK31 has already expanded the number of radio amateurs experimenting with digital communications. Expanding analog voice frequencies does nothing to benefit the basis and purpose of the amateur service.

The Wormser, Adsit, Dinelli, and Billingsley proposal encourages the current Technician Plus licensees to learn digital modes by allowing them all digital and cw privileges. Our plan also reserves HF voice as an incentive to upgrade skills; the ARRL’s proposal does not. The FCC has used the HF voice incentive successfully for over 40 years. Now, it should be continued as a reward for mastering HF digital modes.

The Wormser, Adsit, Dinelli, and Billingsley plan addresses testing procedures, content of exam questions, and how best to accommodate the many handicapped individuals whom contribute so much to the Amateur Service.

The Wormser, Adsit, Dinelli, and Billingsley plan was developed by a small group of individuals, rather than an organization. Nevertheless, it has received attention and support from other amateurs across the nation. In that respect, it is a true "grass roots" plan.

I am a life member of the ARRL however, I can not support their proposal. I am anxious about the outcome of restructuring however, I prefer to have the FCC use its due process rather than to rush to any single proposal. Thank you.

Very truly yours,

Michael J. Dinelli
ARS N9BOR

MJD:cw

cc: Susan Ness, Commissioner

Harold Furchtgott-Roth, Commissioner

Michael Powell, Commissioner

Gloria Tristani, Commissioner

Thomas J. Sugrue, Chief, Wireless Telecommunications Bureau

D’wanna Terry, Chief, Public Safety and Wireless Division