Shareware Overload Trio 2/Shareware Overload Trio Volume 2 (Chestnut CD-ROM).ISO/dir24/93_305.zip/93-305.TXT

Text File | 1994-04-14 | 16KB | 377 lines

Posted April 11, 1994

This file contains the Final Report of the ARRL Ad-Hoc Committee
on Preferred Callsigns

Committee Members:
Mr. Steve Mendelsohn, WA2DHF, Chairman
Mr. Frank Butler, W4RH
Mr. Tom Comstock, N5TC
Mr. John Kanode, N4MM
Mr. Brad Wyatt, K6WR

Executive Summary

The Committee was created by President Wilson to recommend a
response to the Board in P.R. Docket 93-305, the Vanity Callsign
proposal.  The charter from President Wilson included a request
that  member input be sought in the limited time before the March
7, 1994, filing deadline.

To accommodate this request Vice Director Rothberg and the
chairman conducted a survey of our respective divisions using
packet radio, mail and a request to newsletter editors to
reproduce the survey form for club input.  Over 730 responses
have been received and tallied.  Numeric results track with
anecdotal results seen in member letters to Headquarters.

The Board family has been especially helpful in forwarding and
recounting comments from the field.  Directors Burden, Comstock,
Gordon, Heyn, Kanode, Lewis, Olson, Wyatt, Vice Directors
Brackob, (monitoring the discussion on CompuServe) Brown, Frahm
and Rothberg have forwarded member response by mail, through
Headquarters and electronically to the Committee.

Executive Vice President Sumner made members aware of the
Committee's work through an editorial and article in February,
1994, QST.  EVP Sumner and VEC Manager Jahnke provided the
Committee with an excellent option paper on electronic submission
of license requests by various means.

Recommendations

1.  Who Should Participate

The Committee recommends that the Board adopt the position that
all amateurs be eligible for participation in the program after
an initial phase in period.

While 7% of the respondents to the survey were against the
program entirely and another 3.5% wanted to limit the program to
General class and above, the majority of comments received
welcome the creation of the program while recognizing that some
method of initial filtering must be used to keep the FCC from
being inundated with applications in the beginning.

2.  The issue of Fees

The fee quoted in the Docket, $7.00 per year collected for the
length of grant of license (10 years), was set by Congress in the
Budget Reconciliation Act of 1993.  To change the amount or type
of fee would require the League to commit its efforts in the
Congress toward changing the fee.

The Committee recommends that the League seek such relief in
favor of a one time administrative processing fee with the
understanding that no amateur licensee should incur a user fee.

There is no periodic processing expense related to this program
after the initial look-up work has occurred.  Labor involved with
renewal of a Preferred Callsign will not differ in any way from
the renewal of a non-preferred callsign, therefor the Committee
believes no additional labor charge should be incurred by the
licensee.

During the course of this proceeding people filed comments with
the Commission asking why those with Preferred Callsigns have to
pay recurring, yearly fees.  The Commission's response may well
be to ask that ALL amateurs pay such user fees.  Without
question, this would be viewed as an undesirable outcome to such
a question.

Additional factors supporting the one-time administrative fee
position include the time value of money and reduction in
administrative workload.

The Government benefits by collecting the entire fee at the
beginning of the process rather than on a yearly basis or at the
end of the license term.  The one-time fee concept would also
greatly reduce the Commission's fee collection workload by not
having to administrate an ongoing fee collection process at
license renewal time.

3.  Holders of previous Preferred Callsigns

The Committee recommends a statement that any callsign held prior
to the start of this program shall be considered a sequential
callsign and exempt from any administrative fee associated with
this program.

4.  Phase-in Periods and Priorities

The Committee recommends a phase-in period to allow the
Commission a reasonable chance to process the expected heavy
initial submission of applications.

Conversations with Commission Information Services staff in
Gettysburg indicate that no additional application processing
manpower will be used to work on Preferred Callsign applications.
The same four people who process all new and renewal form 610s
will be processing the new form 610-V as well.  Therefore, a
phase in period would be wise to prevent severe overload at
Gettysburg.

Phase-in periods may be perceived as "gates".  As each succeeding
gate opens it will admit applications from a new group as well as
any group allowed by a previous gate.

Gate one would allow applications from holders of previous
callsigns who have lost their original call through failure to
renew at the proper time or having moved from one location to
another mandating a change of callsign.  A callsign could be
recovered even if it did not match the applicants current
permanent address.

Included in this group would be those who wish to obtain the
callsign of a direct family member.  The term direct, as used
here, would only include a brother, sister, spouse, son or
daughter of the original licensee.

The Committee recommends that clubs with lapsed club licenses
also be allowed to recoup those callsigns in the first group.

The second gate would include all Extra Class licensees and those
enfranchised by gate one.

The third gate would include all Advanced Class licensees and
those enfranchised in gates one and two.

At this point the system would be thrown open to anyone else
desiring a Preferred Callsign.

5.  Club Applications

Clubs wishing to obtain the callsign of a silent key member could
do so in the second gate period if the trustee of the club were
an extra class licensee.  This should present no problem for most
legitimate clubs.  Similar logic would apply to trustees with
other classes of license.

The Committee believes family members should have first choice of
a silent key's call.  Should no family member desire the call,
the club should have next choice.

It is been the League position that the number of members of a
club be raised to at least 4 for a group to be considered a
"radio club".  This proceeding again emphasizes the need for the
Commission to raise the number of members needed to ensure
legitimacy and prevent fraud.

The League's Part 97 Rewrite Committee suggested raising the
number of members required in Part 97.5(d)(2) from two to four.
The Committee recommends this proceeding be used as an
opportunity to restate that position.

The Committee recommends that, for purposes of defining a
legitimate club in Part 97.5(d)(2), the number of members be
raised from the current 2 to at least 4.

6.  Vacated Callsigns

As proposed in the NPRM, a call is considered "vacated" when its
previous owner has been assigned a Preferred Callsign.  The
Commission would put the vacated call into the available pool
immediately.  The Committee believes this could lead to many
problems.  As an alternative...

The Committee recommends that the vacated callsign not be
reassigned for a two year period.

Incoming QSL bureaus, especially, have noted that many services
count on the user callsign being correct.  An instant
reassignment of a prior held call to a new licensee could cause
multiple problems for volunteer service groups, such as the
bureaus.

Another consideration is "trafficking in callsigns"  The
Committee believes that a two year hold on a vacated callsign
would preclude questionable practices arising in which one
amateur would persuade another to change their call so the first
amateur could acquire the desired call.  This practice could open
up a new area of fraud allowing people to submit questionable
documents showing that amateur B wanted to give up a call so
amateur A could acquire it.

7.  Number of Choices on Form 610-V

The Committee recommends that the number of choices be increased
to 25.

This should reduce processing and correspondence time if the 10
requested callsigns are all unavailable.  The applicant need not
fill in all 25 callsigns, but it would increase the chance of a
positive match if the applicant had 25 choices.

8.  Retirement of Callsigns

A small number of commenters stated the belief that re-issuance
of callsigns of silent keys would be somehow disrespectful.  The
Committee does not share this viewpoint.

While the Committee was sensitive to the fond memory the silent
key's friends might have, the callsign is really the "property"
of the Commission and is part of the condition of grant to the
licensee.  In essence it is "loaned" to the licensee for the term
of the license.  It would, therefore, become eligible for re-
issuance once the renewal grace period had expired.

If an individual passed away just before license renewal time it
would be at least two years before the callsign became available
for re-issue at the end of the renewal grace period.  A more
probable condition would be that the licensee would pass on in
the middle of the license term.  Then the callsign would not
become available for between four and seven years after the
amateur passed on.

Should an individual, club or group think highly of the deceased,
nothing precludes finding an inactive ham and asking the
individual to change callsigns by requesting the silent key's old
callsign through this program.

9.  Out of Area Callsign Issuance

The Committee recommends that within the lower 48 states the
Commission continue issuing callsigns with the number within the
callsign relative to the applicants current permanent address.
This recommendation would be for Preferred Callsigns as well as
sequentially generated callsigns.

A quick historical retrospective is in order at this point.  One
of the original reasons for breaking the continental United
States into ten callsign districts was to help the FCC's Field
Operations Bureau begin to locate an emitter for enforcement
purposes.

Today's state-of-the-art direction finding does not need to know
which callsign district the emitter is located in.  This fact was
part of the rationale the Commission used in eliminating the
requirement for a licensee to sign "portable" when away from the
licensed station location.  Therefore, the Commission doesn't
appear to care whether the a licensee has a district indicator
consonant with the operators station location.

However, anecdotal evidence in letters and on survey forms
indicates that, contrary to the Commission's technological needs,
most amateurs have grown accustomed to the practice of callsign
numbers indicating which area of the country the licensee is in
and would like the tradition continued.  The callsign number
gives the operators on each end of the circuit an immediate
indication of where the other is and "in which direction to turn
the beam."

Therefore, the Committee recommends this tradition of issuing
callsigns with the number within the callsign consonant with the
applicants current permanent address be continued.

10.  Outside of the Continental United States

Amateurs in Alaska, Hawaii, Puerto Rico, the American Virgin
Islands and in the Pacific have shared  their concern with
Directors Wyatt and Butler about amateurs being able to acquire
callsigns from their area without being a current permanent
resident.  This is a valid concern because in some areas, notably
Hawaii, the KH6 callsign block is nearly gone.  Most of it has
been assigned to visitors and those who are now deceased.

While the re-issuance of callsigns of deceased amateurs will ease
the problem, the Committee recommends that outside the
continental 48 states applicants be required to furnish the
Commission with some form of documentation indicating permanent
residency.  Visitors would continue to use the portable
designator, thereby not depleting a callsign pool available only
to permanent residents.

11.  Specific Comments on the NPRM

New 97.19 (c)  Substitute the following:

Each request for a renewal of a operator/primary or club station
license retaining a call sign assigned under the vanity call sign
system shall be made on FCC form 610-V.  The form must be
submitted [eliminate "with the proper fee"] to the address
specified in the Private Radio Services Fee Filing Guide.  To
renew the license without retaining a vanity call sign, the
applicant must use FCC form 610 as specified in Section 97.21.

New 97.19(f)(3)

A call sign that is vacated by the licensee is [add "not"]
available to the vanity call sign system [add "for 2 years
following the expiration of the license"].

Sentence Added to the end of 97.19(g)

A callsign previously held by the applicant, available to the
vanity callsign system but expired, may be requested without
regard to license class group or current permanent residence.

New 97.19(g)(1)

The applicant must request that the call sign held be canceled
and provide a list of up to [change 10 to 25] call signs in order
of preference.  The list will automatically end with the call
sign vacated as the [change "tenth" to "twenty sixth"] choice.

New 97.19(g)(2)

The first available call sign from the applicant's list will be
assigned.  When none of those call signs are available, the call
sign vacated by the applicant will be reassigned [add "and the
administrative fee returned".]

New 97.5(d)(2)

A club station license (FCC Form 660) issued to the person by the
FCC.  A club station license is issued only to the person who is
the license trustee designated by an officer of the club.  The
trustee must hold an FCC-issued Amateur Extra, Advanced, General
or Technician operator license.  The club must be composed of at
least [change "two" to "four"] persons and must have a name, a
document of organization, management and a primary purpose
devoted to amateur service activities consistent with this Part.

12.  Questions Posed in the Discussion Section

In paragraph 5 the Commission asks about alternative ways to file
form 610-V.

The Committee recommends that the same, simple, ASCII format used
in League contest filings be recommended to the Commission IS
group as a starting point for electronic filing

In Paragraph 6 the NPRM requests comments on distribution of
available callsign information.

The Committee recommends that a League computer and modem, or
HIRAM be made available, in the short term, as a distribution
method with the Commission filing at least weekly updates or
sending a disk or disks detailing callsign availability.

Alternately, for-profit data services, such as Compuserve's
Hamnet forum, could be used by the Commission to make current
callsign information available.

13.  Special Event Callsigns

The Committee recommends that 1 X 1 callsigns, such as K2A, be
made available for limited duration special events of national
significance.

There are likely to be few special event stations of national
significance operating at any one time within a single call
district.  Therefore, the issuance of a 1 X 1 callsign should be
possible without measurably adding to the Commission's workload.

14.  Final Comments

The Chairman would like to thank the Directors Butler, Comstock,
Kanode and Wyatt, EVP Sumner and VEC Department Manager Jahnke
for the hard work they did in such a compressed time period.

A statistical treatment of the data used to derive the
Committee's position will be sent as an enclosure to this report.

Respectfully Submitted,

Stephen Mendelsohn, WA2DHF, Chairman