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ARRL Executive Committee Examines Proposed Vanity Call Sign Changes, Legislative, Regulatory Issues, More

03/25/2010

The ARRL Executive Committee (EC) held its first 2010 meeting Saturday, March 13 in Denver. The EC worked through a lengthy agenda that for the first time had been shared in advance with ARRL members -- the result of an ARRL Board action at its January meeting intended to increase transparency in the governance of the organization.

The EC administers the League’s affairs in between Board meetings. It consists of the President (Kay Craigie, N3KN), five Directors elected annually by the Board, and – without vote – the First Vice President (Rick Roderick, K5UR) and Executive Vice President (David Sumner, K1ZZ). For 2010 the Director members are Tom Frenaye, K1KI (New England), George R. Isely, W9GIG (Central), Brian Mileshosky, N5ZGT (Rocky Mountain), Bob Vallio, W6RGG (Pacific) and Dr David Woolweaver, K5RAV (West Gulf). Also in attendance at the meeting were General Counsel Chris Imlay, W3KD; Vice President Bruce Frahm, K0BJ, and International Affairs Vice President Jay Bellows, K0QB. 

FCC and Regulatory Items

At its 2010 Annual Meeting, the ARRL Board of Directors authorized the EC to develop ARRL positions on the FCC Notice of Proposed Rule Making (NPRM) in WT Docket No 09-209, concerning vanity and club station call signs. The EC developed the following positions and authorized the General Counsel to file comments prior to the March 26 deadline. 

Vanity Call Signs

In order for a vanity call sign to be assigned to an amateur, the call sign must be assignable at the time the application is processed. Even if a licensee is deceased, the call sign is not available if the license is still active in the FCC database. When the FCC receives what it calls “proper documentation of the licensee’s passing” (a signed request for license cancellation accompanied by a copy of a death certificate, an obituary or data from the Social Security Death Index that shows the date of death), it then cancels the license as of the licensee’s date of death. “We propose to amend our rules to codify these procedures by adding a new paragraph to Section 97.21,” the NPRM states; currently, the procedure for canceling a license due to the grantee’s death is outlined on the FCC's Web site, but is not codified in their rules. “We believe that this will make our cancellation process more equitable and transparent, and facilitate the availability of desirable call signs.” 

The FCC calls its rules “ambiguous” concerning call signs that become available for reassignment “as to whether the waiting period runs from the date of death or the date that the Commission cancels the license in light of the licensee’s death.” As such, they are proposing to amend the rules “to clarify that a license that is canceled due to the licensee’s death is deemed to have been canceled as of the date of death, regardless of when the licensing database is updated to reflect the licensee’s death.” In the NPRM, the FCC proposed to modify their processes to ensure that the deceased’s call sign is unavailable to the vanity call sign system for at least 30 days after the staff updates the licensing database to reflect the licensee’s death. 

The ARRL agrees with the FCC proposals with regard to license cancellation procedure for deceased licensees, timing of the availability of a deceased licensee’s call sign, an exception to the two-year waiting period for former holders of a call sign and the definition of “in-law.” The FCC proposes to amend Section 97.3 to define the term “in-law” to include only a parent or stepparent of a licensee’s spouse, a licensee’s spouse’s sibling, the spouse of a licensee’s spouse’s sibling or the spouse of a licensee’s sibling, child or stepchild. 

The ARRL also agrees that a two year waiting period should not commence upon the surrender of a call sign that was erroneously granted to an ineligible applicant; however, there should be a 30 day waiting period after the FCC staff updates the licensing database for the same reasons as in the case when a deceased person’s call sign is made available for reassignment. 

When a vanity call sign application is granted, the call sign currently assigned to the licensee’s station is surrendered and is not available to the vanity call sign system for two years. Occasionally, the FCC said, vanity call sign applications have been granted to applicants who “erroneously or fraudulently indicated that they fell within an exception to the two-year waiting period. Sometimes, after the situation is brought to the applicant's attention, the applicant applies for and is assigned another call sign, thereby surrendering the improperly obtained call sign.” The FCC proposes to amend Section 97.19(c) to clarify that “a new two-year period does not commence when the most recent recipient acknowledges, or the Commission determines, that the recipient was not eligible to be assigned the call sign.” 

The ARRL agrees that there should continue to be an exception to the two year waiting period for an in memoriam club station call sign when a close relative has consented, provided that the deceased licensee was a member of the club. The ARRL notes that there is some potential for dispute to arise with regard to whether a deceased licensee was a club member, but that club membership at the time of death should not be a requirement. 

The ARRL agrees with the FCC proposals with regard to applications to modify a club station license grant, but proposes that the signatures of two officers of the club, neither of whom shall be the new trustee, be required on any application to change a trustee. Calling this an “internal club matter,” the FCC proposes to amend the rules to require that applications requesting a change in trustee include documentation signed by an officer of the club when the application is submitted to the Club Station Call Sign Administrator (CSCSA): “Additionally, we believe that by accepting applications only from the licensee the club station record in ULS shows is the trustee of the club station, the CSCSA can minimize the number of disputed applications that are filed with us.” 

The FCC also proposes to permit Novice class licensees to serve as club station trustees. The Commission noted that there was an historical prohibition against Novice class licensees serving as club station trustees since Novice licenses originally were not renewable. Because such licenses now may be renewed on the same basis as any other Amateur Service license, "we believe that this prohibition is no longer necessary," the NPRM noted. The ARRL noted that while few clubs will want a Novice licensee to be the trustee of their club station because of the cumbersome identification requirements when a club station is operated outside of the trustee’s operating privileges by a control operator with a higher class of license, the ARRL has no objection to the FCC proposal to permit Novices to be trustees. 

To expand the pool of available call signs, the ARRL asks that the FCC permit the issuance of call signs with prefixes NA-NZ, WC, WK, WM, WR and WT and with three letter suffixes. The ARRL also asks the FCC to revisit the issue of special event call signs at a later date to determine whether the public interest would be served by expanding the options for special event call signs beyond the current 1×1 format. 

Club Call Signs

The ARRL does not support the FCC proposal to limit a club to one license grant and one call sign. Clubs often have more than one station, particularly in the case of repeater stations. The FCC proposal would not correct the perceived problem of an individual obtaining multiple vanity call signs as the trustee for a club, because there would be no bar to the creation of multiple clubs. 

Instead, the EC, on behalf of the ARRL, offered the following alternative proposal to address in several ways the shortage of Group A vanity call signs (1×2, 2×1 call signs, and 2×2 call signs beginning with AA-AG and AI-AK that are not sequentially assigned):

  • Except for in memoriam call signs, no new Group A call signs should be issued to club stations. Existing Group A call signs held by clubs would be grandfathered.
  • The pool of available Group A call signs should be expanded by permitting the first character of a two-character Group A call sign suffix to be a numeral as well as a letter (for example, W23A). As the result of modifications to the ITU Radio Regulations adopted in 2003, such call signs are now permitted for amateur stations.
  • To address particular shortages of Group A call signs in offshore areas, prefixes that are assigned to locations without postal addresses and prefixes that are unassigned should be made available in the offshore areas that do have postal addresses.
  • Applicants for Group A vanity call signs should be required to affirm on the application that they are United States citizens.

Regulatory Matters

ReconRobotics: In January 2008, a company called ReconRobotics filed a request with the FCC for a waiver of Part 90 of the Commission’s Rules with respect to the Recon Scout -- a remote-controlled, maneuverable surveillance robot designed for use in areas that may be too hazardous for human entry. A waiver is required to permit licensing of the Recon Scout because the device operates in the 430-448 MHz band, which is allocated to the Federal Government Radiolocation service on a primary basis, as well as the Amateur Radio Service and certain non-federal radiolocation systems on a secondary basis. More than two years later, the FCC granted the waiver request in the form of an Order (WP Docket No 08-63), subject to certain conditions. 

The ARRL had opposed the waiver on the grounds that the device has a significant potential to interfere with amateur stations and that the company is simply trying to avoid redesigning for the domestic market a device that was designed for military use overseas. The EC instructed the General Counsel to file a Petition for Reconsideration by the March 25 deadline. 

Request for Declaratory Ruling: In February 2010 -- after a wait of more than five years -- the FCC denied the ARRL’s Request for Declaratory Ruling concerning state statutes in Florida and New Jersey that make it a felony to make a radio transmission without Commission authorization or to interfere with a licensed public or commercial radio station. While the laws are aimed at pirate broadcasters, the ARRL is concerned that they could be misused against amateurs. The Commission’s denial was based not on the merits of the League’s argument, but on the absence of reports of amateurs being prosecuted or threatened with prosecution under either statute. The FCC invited the ARRL to file a new petition in the event of changed circumstances. The EC concluded that the ARRL should also investigate whether it is desirable to seek amendments to the statutes via state legislation. 

Section 15.103: General Counsel Imlay reported the results of a review of Section 15.103 of the FCC Rules that he, in tandem with the ARRL technical staff, conducted in response to Minute 56 of the January 2010 Board meeting. The report concludes that the exempted devices listed in this section are not sources of interference to amateur reception, and that the rules changes that would constructively address the issue of radio interference in residential areas are in other sections of Part 15. The committee agreed that modifications to Section 15.103 will not be pursued and that the committee will work with the General Counsel and technical staff to identify the sections of Part 15 that are deserving of attention. 

Legislative Matters

At the meeting, Sumner reported to the members that the ARRL Mobile Amateur Radio Policy adopted a year ago and the letter from the President of the National Safety Council affirming that the Council does not support legislative bans or prohibitions on drivers use of two-way radios -- including Amateur Radios -- continue to be very useful tools in addressing distracted driving legislation at both the federal and state levels. The Committee discussed how information about state legislation is shared with the ARRL field organization; the Programs and Services Committee is studying the matter and is expected to offer a recommendation. 

President Craigie noted a flurry of activity by ARRL officials and members in support of moving S 1755 -- which already has passed the Senate -- through the House Committee on Energy and Commerce and to the full House for adoption. 

A House version of S 2881 -- the FCC Commissioners Technical Resource Enhancement Act -- has been introduced as HR 4809. President Craigie has communicated the ARRLs support of this legislation to the committee of jurisdiction in the Senate and will do the same with the House. ARRL members are asked to seek support of the bills by their Senators and Representative. 

International Matters

Sumner updated the EC on the preparations for the ITU World Radiocommunication Conference, currently scheduled for January 23-February 17, 2012 in Geneva, Switzerland (WRC-12). On the IARU Region 2 front, President Craigie reported on preparations for the IARU Region 2 Conference in El Salvador later this year. ARRL members have been invited to offer comments and suggestions on the Region 2 band plan adopted at the previous conference in 2007. On behalf of the Ad Hoc Band Planning Committee, Vice President Frahm reported that 23 comments already had been received. 

The oldest national Amateur Radio Society in the world -- The Wireless Institute of Australia -- will celebrate its centennial this year. International Affairs Vice President Bellows will represent the ARRL at the WIA’s centenary celebration in Canberra at the end of May. Recognizing that the WIA “has from its inception courageously defended and tirelessly advanced the interests of Amateur Radio in Australia,” the EC, on behalf of the ARRL, issued a resolution “wish[ing] great success and good fortune to the Wireless Institute of Australia as it embarks upon its second century of leadership on behalf of Amateur Radio in the Commonwealth of Australia.” 

Organizational Matters

The Committee voted to recommend the following actions to the Board of Directors: 

  • The ARRL EC considered possible revisions to election rules and procedures, including the possibility of offering members the option of voting electronically as an alternative to the traditional paper ballot. The Committee voted to recommend to the Board that the ARRL offer the option of voting electronically beginning in 2011.
  • The adoption of an amendment of Bylaw 18 to permit the Secretary to receive nominating petitions and statements of eligibility from candidates for Director and Vice Director by facsimile or electronic transmission of images, provided that the original documents are received by the Secretary no later than noon Eastern Time on the fourth Friday of August, that is, seven days after the filing deadline.
  • The adoption of an amendment of Bylaw 42, modifying the procedure for review of decisions of the Ethics and Elections Committee by setting a deadline for appeal and authorizing the EC to conduct the review.

The EC discussed and agreed that existing guidelines and procedures concerning the discretion that the ARRL and its officials have in deciding to accept -- or to continue to accept -- the services of a volunteer are sufficient, but that there may be a need to communicate them more effectively to the field organization and especially to Section Managers. 

The following 2010 conventions were approved:

  • Southeastern VHF Society Conference (Operating Specialty Convention), April 23-24: Morehead, Kentucky
  • Washington State, September 25: Spokane Valley, Washington
  • Connecticut State, October 10: Wallingford, Connecticut
  • West Central Florida Section, December 4-5: Palmetto, Florida

The affiliation of the following clubs was approved:

  • Kuemper Catholic High School Amateur Radio & Technology Club in Carroll, Iowa
  • Martinez Amateur Radio Club in Martinez, California
  • Mayland Amateur Radio Club in Bakersville in North Carolina
  • Simpson County Amateur Radio Club in Magee, Mississippi

The EC also recognized 104 recently elected Life Members. Their names will appear in an upcoming issue of QST

According to the ARRL Articles of Association, the EC meets during the intervals between meetings of the Board of Directors. It meets at the call of the President, but no less often than semi-annually. The last meeting of the EC was October 24, 2009. The next meeting of the EC is scheduled for October 23, 2010.



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