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ARRL General Bulletin ARLB038 (1998)

ARLB038 ARRL asks ULS changes

ARRL Bulletin 38  ARLB038
From ARRL Headquarters
Newington CT  May 28, 1998
To all radio amateurs

ARLB038 ARRL asks ULS changes

The ARRL has expressed overall support for the FCC's wide-ranging
rulemaking proposal to implement the Universal Licensing System (WT
Docket No. 98-20). But the League also suggested several changes to
the plan.

In comments filed May 21, the League supported deleting the
application process for non-US hams to operate in this country. But
the League says the FCC should impose a one-year time limit on such
operation or at least be consistent with CEPT and CITEL
requirements.  The ARRL took advantage of the opportunity to urge
the FCC to authorize visitors from certain European countries and
the Americas to operate during short visits to the US. The League
also said the new rules should require non-US ops to have their
license document in their possession while operating in the US or
its possessions.

In the same vein, the League's said it would ''object strongly'' if
the FCC stopped issuing license documents to hams. The League said
it's often necessary to prove that one is a licensee. It cited
amateur protections under state and local scanner and antenna laws,
as well as requirements to produce a license for overseas operation.
The FCC's ULS proposal did not suggest eliminating license
documents, but the League said it's heard ''repeated staff
references'' to the notion, and added that the proposed rules
''contain nothing that would continue to obligate the Commission to
issue license documents.''

The League also discouraged the FCC from adopting a proposal to turn
over issuance of club and military recreation licenses to private,
third-party administrators. ''The task is of a minimal nature and
does not justify the creation of a cumbersome,
multiple-administrator system that requires real-time coordination
among the multiple administrators.'' The League said that the
current system works well and should be left in place.

The League suggested changes for the new multiple-service FCC Form
605, slated to replace the venerable Form 610 when the ULS is
adopted. The League said the new form makes it ''inherently more
cumbersome for the amateur licensee to determine which portions of
the Form are to be used and which may be disregarded.'' Certain
items that were not in the old Form 610 ''should be deleted for
amateur applicants,'' the ARRL said. Also, the League urged the FCC
to retain a standard physician's certification for a medical
exemption from the higher-speed Morse Code requirement.

The ARRL questioned the requirement for applicants to supply a
Taxpayer Identification Number (TIN)--typically a Social Security
Number--if they are not participating in the vanity call sign
program, which is subject to a regulatory fee. ''Many radio amateurs
are concerned about disclosing their Social Security numbers without
assurance of the necessity therefor and without assurance of
confidentiality,'' the League's filing said. ''The Notice offers
very little of either.''

The League also said the FCC should not make electronic filing
mandatory as of January 1, 1999, as the FCC's Notice proposes. The
League said electronic filing is not yet available to all applicants
and the requirement ''would certainly disenfranchise some.''

A copy of the League's comments to the FCC is on the ARRLWeb page at


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