I am opposed to the proposal to add a "Tyro" license class and restructure
the 70 cm amateur band. As an Advanced-class amateur, a (retired) educator,
a (retired) electrical engineer, and an active "old Fart", I believe that
the assumptions of the proposal are flawed and that its implementation
would not benefit Amateur Radio as planned:

1. Augmentation of CERT capabilities is a very poor reason for adding
   a license class, especially since other services such as GMRS and
   even FRS are already available that can provide limited-area FM
   communication.

2. The proposal fails to discuss how the increased costs of implementing
   the various structures required for the Tyro service will be covered.

3. Implementing a license class that requires no technical knowledge of
   radio does not support the purpose of Amateur Radio as outlined in
   CFR47-97.1, "Basis and Purpose"

4. Implementing arbitrary technical standards weakens the Amateur Service.

  a) Channelization of a portion of the 70 cm band limits other uses
     of the spectrum.

  b) Imposing 2.5 kHz "narrowband" FM as the only acceptable modulation
     means the radio configurations for this portion of the service will
     be incompatible with present amateur practice; standards should
     remain consistent across a service as much as is feasible.

  c) The Tyro service frequencies are segregated from conventional
     practice by frequency and by repeater frequency split, another
     inconsistency with present amateur practice.

  d) Some of the technical standards proposed are either obsolete,
     redundant, or could lead to unintentional interference.

  e) No mention is made of the cost of building and maintaining an
     infrastructure of repeaters and other equipment that are dedicated
     to Tyro operators.

  f) Segregating Tyro operators from amateur operations using existing
     frequencies and modes reduces opportunities for mainstreaming and
     learning, critical for developing both social and technical skills
     necessary for growth in Amateur Radio.

5. Tasking Technician-class licensees to be test proctors and/or mentors
   is not in alignment with the current volunteer examinination system
   structure:

  a) Currently, volunteer examiners must be General-class or higher and
     at least of 18 years of age. No such restriction is in place for
     Technician-class licensees.

  b) The use of an online testing system will dilute accountability
     and open the door to exam fraud if not properly administered.
     The additional costs and responsibilities associated with such
     a system are not discussed in the proposal.

  c) While many Technician-class licensees are well-qualified to act
     as mentors in radio, not all may be. While the same argument can
     be made for all amateur license classes, however, it is more
     likely that a greater fraction of General- and Extra-class
     licensees will possess the additional knowledge and skills needed
     to serve in this capacity.