I oppose the measure, for the same reasons as Herb Fiddick, whose
comments I quote below.

Thanks,
Rob Fugina
AB0RQ

Quote follows:

My take:  (Herb Fiddick, NZ0F)

I am opposed to the proposal to add a Tyro license class and restructure
the 70 cm amateur band. As an Extra class amateur, educator, and
volunteer examiner, 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 not a sufficient reason for
adding a license class - and other services such as GMRS are already
available that can provide limited area FM communication.

2. Adding a license class is exactly the opposite direction taken by the
FCC over the last two decades, where the aim has been to streamline the
Amateur Radio service. 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. Asking 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 proposal would require restructuring the Technician class
licensee qualifications and question pools, which are already quite full
with the basic knowledge needed by new licensees.

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

d) 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.

5. 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 that the radio configurations for this portion of the service are
incompatible with present amateur practice. While moving to a
narrowbanded FM model is a noble goal, 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 (the proposal
specifies 9 MHz T-R frequency splits, as opposed to 5 MHz as the
standard practice used in the amateur 70 cm band).

d) Some of the technical standards proposed are either obsolete,
redundant, or could lead to unintentional interference. For example 4.58
- minimal modulating frequency - is obsolete given the frequency
stability of current amateur equipment. 4.29 - "OpenAccessCodes" -
appears to limit the Tyro system to only three CTCSS tones, which seems
to weaken CTCSS's capacity to reduce interference.

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