| |
DL8ABO > ARRL 29.02.00 03:31l 3622 Lines 153404 Bytes #-9395 (180) @ EU
BID : T2ADB0NHM001
Read: GUEST
Subj: (F)ederal (C)ommunications (C)ommission FCC
Path: OE1XAB<OE3XSR<OK0PPR<OK0PKL<DB0MAK<DB0SON<DB0SIF<DB0NHM
Sent: 000228/2317z @:DB0NHM.#NDS.DEU.EU [Northeim JO51AR OP:DJ3JW] bcm1.42j $:T
From: DL8ABO @ DB0NHM.#NDS.DEU.EU (Mirko-AB0DL)
To: ARRL @ EU
********************************************************
NOTICE
********************************************************
This document was converted from
WordPerfect or Word to ASCII Text format.
Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.
All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.
Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.
If you need the complete document, download the
WordPerfect version or Adobe Acrobat version, if available.
*****************************************************************
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of ) WT Docket No. 98-143
)
1998 Biennial Regulatory Review -- ) RM-9148
Amendment of Part 97 of the Commission's ) RM-9150
Amateur Service Rules. ) RM-9196
)
)
REPORT AND ORDER
Adopted: December 22, 1999 Released: December 30, 1999
By the Commission:
TABLE OF CONTENTS
Paragraph
INTRODUCTION AND EXECUTIVE SUMMARY . . . . . . . . . . . . . . .1
BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . .4
DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . .7
License Structure . . . . . . . . . . . . . . . . . . . . .7
Number of License Classes. . . . . . . . . . . . . . .9
Telegraphy Examination Requirements. . . . . . . . . 22
Written Examinations . . . . . . . . . . . . . . . . 40
Disposition of the Designated Novice Bands . . . . . 53
Greater Volunteer Examiner Opportunities. . . . . . . . . 57
RACES Station Licenses. . . . . . . . . . . . . . . . . . 61
Privatization of Certain Enforcement Procedures . . . . . 64
Other Issues. . . . . . . . . . . . . . . . . . . . . . . 67
CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . 69
PROCEDURAL MATTERS . . . . . . . . . . . . . . . . . . . . . . 70
ORDERING CLAUSES . . . . . . . . . . . . . . . . . . . . . . . 72 I. INTRODUCTION AND EXECUTIVE SUMMARY
1. In the Notice in this proceeding, we examined the Amateur Radio Service Rules in an effort to
streamline our licensing processes and eliminate unnecessary and duplicative rules. We initiated this
proceeding as part of our 1998 biennial review of regulations pursuant to Section 11 of the
Communications Act of 1934, as amended (Communications Act), because we believe it is appropriate to
review all of our regulations.
2. By this Report and Order, we adopt rules that simplify the Amateur Radio Service operator
license structure, streamline the number of examination elements and, reduce the emphasis on telegraphy
that underlies the current license structure to the greatest extent possible, consistent with the international
Radio Regulations (Radio Regulations). Moreover, we believe that these changes will: (a) allow current
Amateur Radio Service licensees to contribute more to the advancement of the radio art; (b) reduce the
administrative costs that we incur in regulating this service and streamline our licensing processes; (c)
eliminate unnecessary requirements that may discourage or limit individuals from becoming trained
operators, technicians, and electronic experts; and (d) promote efficient use of spectrum allocated to the
Amateur Radio Service.
3. The major rule changes we adopt today are as follows:
. Reduction of the number of operator license classes from six to three.
. Reduction of the number of telegraphy examination elements from three to one.
. Reduction of the number of written examination elements from five to three.
. Authorization of Advanced Class amateur radio operators to prepare and administer
examinations for the General Class amateur radio operator license.
. Elimination of Radio Amateur Civil Emergency Service (RACES) station licenses.
II. BACKGROUND
4. The Amateur Radio Service is composed of three different services -- the amateur service, the
amateur-satellite service, and the Radio Amateur Civil Emergency Service (RACES). The amateur
service is available to be used by persons who are interested in radio technique solely with a personal aim
and without pecuniary interest. It presents an opportunity for individuals to self-train, intercommunicate,
and carry out technical investigations. Amateur radio operators engage in voluntary, noncommercial
communications with other amateur radio operators located in the United States and in foreign countries.
Millions of amateur radio operators throughout the world communicate with each other directly by
exchanging voice, teleprinting, telegraphy, digital packet, facsimile, and television messages. Amateur
radio operators also routinely provide essential communications links and facilitate relief actions on a
purely voluntary basis when a disaster occurs or is likely to occur. The amateur service rules are designed
to allow licensees in this service to provide emergency communications, advance radio technology, improve
operator skills, enhance international goodwill, and expand the number of trained operators, technicians,
and electronic experts.
5. The amateur service is one of the radio communication services authorized by the Radio
Regulations and was one of the first non-government communication services. Regulation of the amateur
service in the United States dates from the early 1900's as a result of the U.S. Navy's concern about
interference to its stations and its desire to be able to order amateur radio stations off the air in the event of
war. As part of this regulation, proficiency in Morse code was mandated to ensure that amateur radio
operators could recognize and avoid interference with government and commercial stations as well as
maritime distress messages, and to ensure that the U.S. Navy could communicate government orders to
amateur radio operators. This mandated telegraphy proficiency was continued by the Federal Radio
Commission and then by the Federal Communications Commission. Telegraphy proficiency remains
one of the examination elements that, by international treaty, an examinee must pass to obtain an amateur
service operator license that authorizes operating privileges in the portion of the radio spectrum below 30
MHz.
6. On August 10, 1998, we released the Notice and sought comment regarding rule amendments
that could simplify the amateur service license structure, streamline our licensing processes, and eliminate
unnecessary and duplicative rules. In particular, we proposed to simplify the amateur service license
structure to a four-class license structure by grandfathering the Novice Class operator license and by
combining the Technician and Technician Plus classes of amateur radio operator licenses. We also
proposed to authorize Advanced Class operators to prepare and administer examinations for the General
Class operator license and to eliminate RACES station licenses by not renewing them. This initiative to
streamline the rules for the amateur service was in addition to those initiatives adopted as part of the
Universal Licensing System (ULS) proceeding. The Electronic Comment Filing System shows that we
received over 2,250 timely filed comments and reply comments in response to the Notice.
III. DISCUSSION
A. License Structure
7. The last major restructuring of the Amateur Radio Service rules took place in 1989. In that
proceeding, the Commission eliminated unnecessary rules and simplified complex terminology. The classes
of operator licenses and examination requirements to obtain these licenses, however, were not changed. In
view of advances in communication techniques that have occurred since the last comprehensive evaluation
of the amateur service license structure, in the Notice we indicated our belief that this is an opportune time
to consider additional ways to streamline and simplify the amateur service rules by conforming them to
contemporary technological advances in the art of radio communication. In sum, the keystone of our
proposals was the simplification of the amateur service license structure and the streamlining of our
licensing processes.
8. In the Notice, we proposed changes to, or sought comment on, three primary issues regarding
the amateur service license structure. Specifically, we first stated that we thought six classes of operator
licenses were unnecessary and we sought comment on other alternatives, for example, a four-class license
structure as described in the Notice. We also sought comment generally on whether we could reduce the
number of license classes while still encouraging amateur radio operators to advance their skills in
meaningful ways. We stated that reducing the number of classes of operator licenses would lessen
preparation and administration tasks by Volunteer Examiners (VEs) and would ease the Commission's
administrative burdens associated with this service. Second, we sought comment on all aspects of the
Morse code standards used in our telegraphy examinations, including whether we should continue to have a
standard that requires three different telegraphy examinations or whether this standard should be reduced to
one or two telegraphy examinations, and, if so, what the required speeds should be. Lastly we sought
comment on whether the written examination requirements should be modified to provide VEs and
Volunteer-Examiner Coordinators (VECs) additional flexibility in determining the specific contents of
written examinations.
1. Number of License Classes
9. Background. Three of the six current amateur radio operator license classes, i.e., the Novice,
Technician, and Amateur Extra Class, were established in 1951. At that time, telegraphy was a common
mode of radio communication in commercial, military, and marine services and applications. The
telegraphy examination requirement was removed as a requirement to qualify for the Technician Class
operator license in 1990. The Technician Plus Class operator license was established in 1994 to
distinguish between Technician Class operators who had or had not passed at least a 5 words per minute
(wpm) telegraphy examination. The present license structure is a six-step ladder structure, i.e., an
individual advances to a higher class of operator license by passing examinations that demonstrate
increased telegraphy proficiency and/or more technical expertise than his or her present license requires.
The class for which each examinee is qualified is determined by the degree of skill and knowledge in
operating a station that the examinee demonstrates at the time of examination. Upon passing the necessary
examination(s), the licensee receives greater frequency privileges than the previous license authorized.
The current operator frequency privileges, the structure of the license classes, and the requirements for
obtaining an amateur operator license were developed in accordance with the expressed desires of the
amateur community to provide an incentive, i.e., additional frequency privileges, to motivate amateur radio
operators to advance their communication and technical skills.
10. Prior to the elimination of the telegraphy examination requirement for the Technician Class
operator license in 1990, the Novice Class operator license was the entry point into the amateur service for
most individuals. To qualify for a Novice Class operator license, an applicant must pass, or receive credit
for, at least a 5 wpm telegraphy examination and a single written examination element. Currently, most
individuals choose the Technician Class operator license as the entry point into the amateur service. To
qualify for a Technician Class operator license, an applicant must pass two written examination elements.
A Technician Class operator may be the control operator of a station transmitting any emission allowed in
any of seventeen frequency bands above 50 MHz. Holders of the Technician Plus Class license have
passed the two written examination elements required for the Technician Class operator license plus an
additional 5 wpm or faster telegraphy examination element, thereby earning the additional privileges of the
Novice Class operator licensee in four HF or shortwave bands between 3 MHz and 30 MHz. To qualify
for a General Class operator license, an applicant must pass three written examination elements and at least
a 13 wpm telegraphy examination element. The General Class operator license authorizes all privileges of
the Technician Class operator license and additional privileges in all of the MF and HF bands. To qualify
for an Advanced Class operator license, an applicant must pass four written examination elements and at
least a 13 wpm telegraphy examination element. The privileges of an Advanced Class operator license
include the privileges of the General Class operator license and, additionally, it authorizes stations authority
to transmit on 275 kHz of additional spectrum in the HF bands. To qualify for an Amateur Extra Class
operator license, an applicant must pass five written examination elements and at least a 20 wpm
telegraphy examination element. The frequency privileges of an Amateur Extra Class operator license
include authorization to transmit on an additional 175 kHz in the HF bands.
11. While we continue to believe that there should be a structure of license classes sufficient to
encourage amateur radio operators to advance their skills in meaningful ways, in the Notice we observed
that six classes of operator licenses might be unnecessary. Reducing the number of classes of operator
licenses would relieve the VEs from the task of preparing and administering unnecessary examinations, and
it also would ease the Commission's burden associated with its oversight of the amateur service licensing
system. In the Notice, we stated there appears to be an unnecessary overlap between the Novice,
Technician, and Technician Plus operator license classes. We proposed to phase out the Novice Class
operator license, with current Novice Class operator licensees being grandfathered. We also proposed to
phase out the Technician Plus Class by renewing Technician Plus Class operator licenses as Technician
Class operator licenses. We noted that when a Technician Class licensee modifies his or her license to
change the operator class from Technician Class to Technician Plus Class, the VEs must prepare and
administer a 5 wpm telegraphy examination, and the Commission is burdened with processing the resulting
applications and revising the database. The result of this license modification is that the Commission
incurs the administrative costs of keeping a separate classification of Technician Class licensees who have
passed a 5 wpm telegraphy examination. With the exception of holders of FCC-issued Technician Class
operator licenses granted before March 21, 1987, Technician Class operators can qualify for a General
Class operator license by passing written examination Element 3(B), which presently consists of thirty
questions on the additional privileges of a General Class operator license and the appropriate telegraphy
examination.
12. Decision. After review of the record, we conclude that the amateur service community
generally supports streamlining and simplification of its license structure. We also conclude, based on the
record of this proceeding, that we are able to adopt a streamlined and simplified amateur service license
structure that will: (a) comply with the Communications Act and the Radio Regulations; (b) meet the
goals underlying this proceeding, and (c) reduce the resources the Commission expends on administration
of the amateur service without adversely affecting the overall effectiveness of the licensing system.
13. We conclude that the public interest will best be served by reducing the number of operator
license classes from six to three and that the three classes of operator licenses in the simplified amateur
service license structure should be the Technician, General, and Amateur Extra Class operator licenses.
We believe this three-class license structure will provide an incentive for licensees to continue the
educational opportunities offered by amateur radio as The American Radio Relay League, Inc. (ARRL)
requests, will continue to provide an incentive for amateur radio operators to advance their communication
and technical skills, and will significantly streamline our licensing processes for this service. Additionally,
we believe that a three-class license structure provides a sufficient number of license classes so that the
fundamental purposes underlying the amateur service rules will not be compromised. We also find that a
single amateur radio operator license and a two- or four-class operator license structure is not supported
by the majority of comments in this proceeding. In addition, we conclude that a two-class license structure
would not contain a sufficient number of license classes to provide an incentive for licensees to advance
their skills in meaningful ways. Further, we conclude that a five-class operator license structure would not
significantly streamline and simplify the present amateur service licensing system.
14. We also are adopting the suggestion of the National Conference of VECs (NCVECs) that we
not issue new Advanced Class operator licenses and grandfather licensees holding this class. We observe
that the primary difference between the Advanced Class operator license and the Amateur Extra Class
operator license is not the difficulty of the Amateur Extra Class written examination but, rather, the 20
wpm telegraphy examination which, as we explain below, we are eliminating as a requirement to obtain the
Amateur Extra Class operator license. We also agree with NCVEC that the difference in authorized
frequency privileges between the Advanced Class operator license and the Amateur Extra Class operator
license is minimal and does not alone warrant maintaining two separate license classes in the future.
Additionally, we expect that many current Advanced Class licensees will upgrade their operator licenses to
the Amateur Extra Class operator license, thereby resulting in a reduction in the number of Advanced Class
licensees. In order to assure that Technician Plus Class licensees do not lose privileges, we have revised
Section 97.301(e) of our Rules to reflect that any Technician Class licensee who satisfies the telegraphy
requirement in the Radio Regulations will maintain the privileges which the Technician Plus Class operator
license presently authorizes.
15. We are not adopting the ARRL suggestion that we automatically upgrade Novice and
Technician Plus Class licenses to the General Class, or the suggestion of others that we automatically
upgrade Advance Class licenses to the Amateur Extra Class operator license. We note that the privileges
of a General Class licensee in the MF and HF bands are significantly different than a Novice Class
licensee. We also note that grandfathering Novice and Advanced Class licensees is consistent with both
the ARRL's overall request that no change in the license structure be made that would reduce the privileges
of any existing licensee, and other commenter's requests that licensees not receive additional privileges
without passing the required examination elements. We believe that both of these concerns are
reasonable and that they are satisfied by grandfathering licensees. Similarly, we will not grant the request
of commenters that we upgrade the operator privileges of individuals who held a Class A operator license
prior to 1951 to Amateur Extra Class operator privileges. As we have stated, the Amateur Extra Class
operator license was a new class of operator license in 1951 and no licensee was converted or
grandfathered to Amateur Extra Class. Consequently, we are not persuaded that a different approach is
warranted in light of our actions in this proceeding.
16. In support of these conclusions, we note that the majority of comments we received in response
to the Notice strongly agree that this is an opportune time to streamline and simplify the amateur service
license structure and that re-evaluation is appropriate. For example, Kenwood Communications
Corporation (Kenwood) states that the license structure of the amateur service is in need of updating.
Quarter Century Wireless Association, Inc. (QCWA) and Kenwood agree that fewer than the present six
license classes would serve the amateur service equally well, if not better, and would be more in keeping
with amateur licensing trends in many other countries. The ARRL also stated that fewer license classes
are preferable and that the current licensing structure has been perceived by many radio amateurs as overly
complex, cumbersome, and somewhat outdated. The ARRL also states that "while this proceeding is a
timely and needed opportunity for simplification of what is now an overly complex licensing structure for
the Amateur Radio Service, the result must continue to provide an incentive for licensees to continue to
pursue the educational opportunities offered by amateur radio." Other commenters have observed that
revitalization and realignment of the amateur service licensing structure is absolutely necessary to ensure
that this service will be capable of meeting its public service and technical training objectives in the
future. In contrast, twenty-two percent of the member-respondents in an ARRL survey and other
commenters in this proceeding oppose any change in license classifications or the requirements necessary to
obtain an amateur radio license.
17. We disagree with the ARRL, however, that simplification of the license structure only should
be undertaken as part of a comprehensive restructure of the licensing process and operating privileges.
We believe that in light of ongoing discussions concerning implementation of new and more modern
communications technologies within the amateur service community, we should accord the amateur service
community an opportunity to complete such discussions and possibly reach a consensus regarding
implementation of new technologies before we undertake a comprehensive restructuring of the amateur
service operating privileges and frequencies. For example, the ARRL recently announced it has a newly-
formed committee that will study the implementation of modern technologies into the amateur service.
We also did not propose to change the name of any current operator license class or create additional
permits such as a "Basic Amateur Permit" because such changes would result in our expending
considerable resources modifying the amateur service database, issuing new license documents, and/or
reprinting scores of licenses; a result which is counter to the goals of this proceeding.
18. With respect to our proposal to phase out the Novice Class operator license, several
commenters assert that the Novice Class license as an entry avenue to amateur radio does not serve much
of a purpose. They further assert that retaining the Novice Class operator license only creates a
paperwork burden for the VECs and the Commission. Furthermore, these commenters agree that this
class license should be eliminated, provided that present Novice Class licensees are grandfathered. Other
commenters state, however, that there is still a place for the Novice Class operator license in the Amateur
Radio Service license structure. For example, the Western Illinois Amateur Radio Club, Inc. states that
the Novice Class license still is the most viable entry path among early- and pre-teen examinees, based
upon its experience offering an annual introductory class to the amateur radio service. It requests,
therefore, that we do not close off entry into the Novice Class license.
19. We have considered the record in this proceeding and conclude that we should adopt our
proposal to phase out the Novice Class operator license while grandfathering current Novice Class
licensees. While the Novice Class operator license might be considered a viable entry path for some
individuals, we note that, as a practical matter, very few individuals choose to enter the amateur service
as Novice Class operators. Based on our review of the amateur service licensing data, it appears that the
majority of individuals choose to enter the amateur service with the no-code Technician Class operator
license. We also note that an individual who qualifies for a Technician Class operator license and then
passes a telegraphy examination qualifies for privileges that include those of a Novice Class operator
license. The only difference between an individual who qualifies for a Novice Class license first and then a
Technician Class license (thereby becoming a Technician Plus Class licensee), and an individual who
passes the examinations in reverse order, is the order in which the examination elements are taken. We
conclude, therefore, there is an overlap between the Novice Class and Technician Plus Class operator
licenses. Thus, we also conclude that the Novice Class license can be phased out without significantly
increasing the difficulty to enter the amateur service.
20. With regard to our proposal to renew Technician Plus Class operator licenses as Technician
Class operator licenses, we note that Technician Plus Class licensees personally hold documentation that
they have passed a 5 wpm telegraphy examination. For this reason, we see no need to maintain a separate
classification of these licensees. Rather, if documentation is needed to verify whether a licensee has passed
a telegraphy examination, we may request the documentation from that licensee or the VECs. We will,
therefore, adopt our proposal to renew Technician Plus Class licenses as Technician Class licenses.
21. By adopting our proposals concerning the Novice Class and Technician Plus Class operator
licenses, we have reduced the number of operator license classes from six to four. The majority of
commenters, however, state that they support a three-class license structure consisting of the Technician,
General, and Amateur Extra Class operator licenses or another three-class operator license structure, or
the four-class license structure we proposed in the Notice. A three-class structure consisting of the
Technician, General, and Amateur Extra Class operator licenses is supported, among others, by the
NCVECs and the Quarter Century Wireless Association (QCWA). In this regard, NCVEC states that
there is very little difference in frequency privileges between the Advanced Class and Amateur Extra Class
operator licenses and that the Advanced and Amateur Extra operator license classes should be streamlined
by grandfathering the Advanced Class operator license. The study conducted by the ARRL showed that
21% of the ARRL members responding also supported a three-class license structure. The ARRL,
however, supports a reduction in the number of license classes from six to four, and states that in its
study, 22% of the respondents supported a four-class license structure. We conclude, based on the
record, that there is strong support within the amateur service community for a simplified operator license
structure consisting of either three or four classes of operator licenses. Given our decision to reduce the
telegraphy examination requirement to the minimum requirement that meets the Radio Regulations, we
believe that the three-class operator license structure is preferable because this structure has substantial
support within the amateur service community and satisfies our goal of streamlining and simplifying the
amateur service licensing system to the greatest extent possible.
2. Telegraphy Examination Requirements
22. Background. In the early days of radio, communication by radiotelegraphy was the primary
means used to exchange messages between radio operators at all radio stations, including amateur radio
stations. Proficiency in telegraphy using the Morse code was mandated to ensure that operators of amateur
radio stations would not cause interference to Government and commercial stations and that amateur radio
stations would be able to stay clear of maritime distress messages. Currently, in the Amateur Radio
Service license examination system, three telegraphy examination elements are prepared and administered
by a team of three VEs to applicants seeking to obtain an amateur radio operator license from the
Commission. In a telegraphy examination, the VEs generally ask an examinee to either transcribe a
prepared telegraphy message or answer a series of questions based on the message. On the basis of the
examinee's transcription or answers, the VEs determine whether the examinee has adequate skills in sending
and receiving text in the international Morse code to pass the telegraphy examination. Our rules delineate
three levels of skill in telegraphy, based upon the rate at which an examinee correctly receives a telegraphy
message: 5, 13, and 20 wpm. Today, as opposed to the early days of radio, radiotelegraphy is just one of
numerous diverse modes of radiocommunication.
23. In the Notice we sought comment on all aspects of the Morse code standards used in our
examinations. We asked whether, in view of the technologies that amateur radio operators use to
communicate today, the three telegraphy proficiency levels remain relevant to contemporary
communications practices. We also asked whether we should continue to have three different telegraphy
examination standards or whether the telegraphy standard should be reduced to one or two telegraphy
examination elements -- and, if so, what the required speed(s) should be. With regard to the
administration of the telegraphy examination element, we asked in the Notice whether we should consider
specifying the method of examining for Morse code proficiency instead of allowing VEs to determine how
to test for code speed if we were to reduce the required Morse code examination elements.
24. The Notice also sought comment on the ARRL's requests, contained in RM-9196, that the
examinee be required to attempt the higher-speed telegraphy examination before examination credit is given
pursuant to a doctor's certification, and that VECs be authorized to request medical information from the
certifying physician pertaining to the examinee's disability. We tentatively concluded that neither of these
proposals is an appropriate means to address potential abuses of the physician's certification requirement.
In addition, we noted that these issues remain relevant only if we were to retain the higher telegraphy speed
requirements, because if the requirements were to be eliminated, there would no longer be a need for an
examination credit based on an applicant's disability.
25. Decision. We have considered the comments on this issue and conclude that the public
interest will best be served by reducing the telegraphy examination requirement to the minimum
requirement that we have found that meets the Radio Regulations and that has been accepted as proving
that the control operator of a station can ensure the proper operation of that station. To achieve this result,
we will amend Section 97.501 of our Rules to eliminate the requirement that an individual demonstrate 13
wpm and 20 wpm proficiency in telegraphy before qualifying for any amateur radio operator license. In
reaching this decision, we note that one of the fundamental purposes underlying our Part 97 rules is to
accommodate the amateur radio operator's proven ability to contribute to the advancement of the radio
art. We believe that an individual's ability to demonstrate increased Morse code proficiency is not
necessarily indicative of that individual's ability to contribute to the advancement of the radio art. As a
result, we find that such a license qualification rule is not in furtherance of the purpose of the amateur
service and we do not believe that it continues to serve a regulatory purpose. Consistent with our decision
to eliminate 13 wpm and 20 wpm Morse code proficiency as licensing requirements, we also are
streamlining Section 97.503(b) of our Rules to reduce the number of telegraphy examination elements from
three to one -- specifically, a 5 wpm telegraphy examination. We also conclude that, due to the Radio
Regulations, we can not grant the request of the ARRL that we authorize privilege on all amateur service
bands below 30 MHz to Technician Class licensees who have not passed a telegraphy examination. While
we do not disagree with the ARRL's belief that the best way to learn telegraphy is to use it on-the-air, and
that actual use of telegraphy to communicate is proof of the ability to send and receive telegraphic texts,
the Radio Regulations provide that the telegraphy requirement may be waived only for an operator of a
station transmitting exclusively on frequencies above 30 MHz. In this regard, we also note, as the ARRL
states, that the Radio Regulations remain an obligation of the Commission that can not be waived.
26. When considering the issue of telegraphy as an examination requirement to obtain an amateur
radio operator license, we begin with a number of general principles. First, the Radio Regulations contain
certain requirements that an applicant for an amateur radio license must satisfy. With regard to the
telegraphy requirement specifically, the Radio Regulations require that persons seeking a license to operate
an amateur radio station must prove that they have the ability to send correctly by hand and to receive
correctly by ear texts in Morse code telegraphy signals. The Radio Regulations also provide that this
requirement may be waived only for an operator of a station transmitting exclusively on frequencies above
30 MHz. In order to comply with the Radio Regulations, our rules require that every class of amateur
radio operator license that authorizes privileges below 30 MHz has, as one of the examination elements that
an applicant is required to pass or otherwise receive credit for, a telegraphy examination element. The
other principles that we consider relevant to examination requirements are that those requirements pertain
to the privileges the operator license authorizes and that they constitute the minimum requirements
necessary to demonstrate that the control operator of a station can ensure the proper operation of that
station.
27. Few issues coming before us present such a clear dichotomy of viewpoints as does the issue of
the appropriate telegraphy examination requirements for an individual to qualify for an amateur radio
license. Many of the comments we have received, including comments from groups of amateur radio
operators and individual amateur radio operators, support reducing the emphasis on telegraphy proficiency
as a license qualification requirement. Other comments contend that any significant reduction of
telegraphy examination requirements will be detrimental to the amateur service while providing no long
term benefits. In fact, some commenters suggest that a reservoir of operators proficient at the higher
Morse code speeds is a public interest benefit and should be encouraged through our Rules.
28. As mentioned above, in the Notice, we asked whether, in the context of the amateur radio
operator licensing system and in view of the technologies that amateur radio operators use to communicate
today, three telegraphy proficiency levels remain relevant to today's communications practices. We also
asked whether we should add elements to the written examination to ensure a working knowledge of the
newer digital technologies, were we to reduce the required Morse code elements. Some commenters state
that the current licensing structure overemphasizes the importance of manual telegraphy. Similarly, the
ARRL states, "... the current examination structure places a strong emphasis on demonstrating Morse code
proficiency, while not requiring demonstrated proficiency in more technically advanced communications
techniques". Further, the ARRL states that "telegraphy should not be overemphasized to the exclusion of
other operating modes [in the examination system]". Mr. Samuels notes that communications has
divided into many different modes, and each one has its own technology and technical requirements.
NCVECs and others agree with our assessment that the role of Morse code is decreasing in modern
communications. Kenwood states that licensing of persons because they are proficient in Morse code is
inconsistent with encouraging those interested in modern telecommunications to join the ranks of amateurs
and become skilled in the technical sciences. Another commenter states that potential recruits to the
Amateur Radio Service consider the telegraphy requirement archaic and quickly lose interest in becoming
amateur radio operators. Many individual commenters also agree that Morse code proficiency is not
relevant to modern communications practices and technologies. Other commenters state that the Morse
code requirement exists only as a roadblock to prevent current and possible amateur operators from
obtaining worldwide frequency privileges or have been used to control access to the HF amateur radio
bands. Mr. Robert H. Stephens states that although he passed the 5 wpm examination, he uses
telegraphy less than five percent of the time.
29. On the other hand, several commenters equate passing a telegraphy examination to the type of
on-the-air operator a licensee will be, proof of skill level, or emergency communication capabilities.
Kenwood, however, states that Morse code telecommunications is not a skill used often in emergency
communications or disaster relief any longer. Other comments express a personal preference for
exchanging messages with other amateur radio stations using telegraphy. While Kenwood agrees with
these observations, it states, however, they are not a sufficient justification for keeping Morse code
proficiency as a licensing requirement. Courage HANDI-HAM System agrees that while Morse code is
fun to use and retains a following in the amateur community, it is no longer essential to HF
communications.
30. Based on our review of the record, we are not persuaded by the arguments of those
commenters opposing reduction or elimination of the emphasis on telegraphy proficiency as a license
requirement in the amateur service. To the extent that these commenters put forth arguments premised on
personal preference or concerns regarding on-the-air etiquette amongst amateur radio operators, we
reiterate pronouncements made in the Codeless Technician Decision. In that decision, the Commission
stated that passing a telegraphy examination, for regulatory purposes, is no more and no less than proof of
the examinee's ability to send and receive text in Morse code at some specified rate. Additionally, it
addressed the issue of personal preference for telegraphy and claims that passing a Morse code examination
would make for a better operator by stating:
We do not concur with the comments alleging that the passing of a
telegraphy examination is an indication of the examinee's good character,
high intelligence, cooperative demeanor, or willingness to comply with our
rules. These traits are also found in individuals who have not passed a
telegraphy examination rather that being exclusive to those who have
passed such a test. With respect to comments that make claims for the
superiority of telegraphy over other types of communications, we do not
consider these arguments as germane to this proceeding. The Notice did
not propose to discontinue the authorization of telegraphy CW emission
types on any amateur service frequency. The amateur service in the
future, as it has in the past, can provide to those who personally desire to
do so the opportunity to communicate by telegraphy.
We are persuaded that because the amateur service is fundamentally a technical service, the emphasis on
Morse code proficiency as a licensing requirement does not comport with the basis and purpose of the
service. We note, moreover, that the design of modern communications systems, including personal
communication services, satellite, fiber optic, and high definition television systems, are based on digital
communication technologies. We also note that no communication system has been designed in many years
that depends on hand-keyed telegraphy or the ability to receive messages in Morse code by ear. In contrast,
modern communication systems are designed to be automated systems. Given the changes that have
occurred in communications in the last fifty years, we believe that reducing the emphasis on telegraphy
proficiency as a licensing requirement will allow the amateur service to, as it has in the past, attract
technically inclined persons, particularly the youth of our country, and encourage them to learn and to
prepare themselves in the areas where the United States needs expertise.
31. We also find unconvincing the argument that telegraphy proficiency is one way to keep
amateur radio operators ready to be of service in an emergency. In this regard, we note that most
emergency communication today is performed using either voice, data, or video modes. We also note that
most amateur radio operators who choose to provide emergency communication do so, according to the
amateur radio press, using voice or digital modes of communication, in part, because information can be
exchanged much faster using these other modes of communication. Further, we note that in traditional
emergency services, such as police, fire, and rescue, there is no requirement that emergency service
personnel hold amateur radio licenses or any other license that requires telegraphy proficiency. We
conclude, therefore, that telegraphy proficiency is not a significant factor in determining an individual's
ability to provide or be prepared to provide emergency communications.
32. The Notice also asked whether we should continue to have three different telegraphy
examination standards or whether the telegraphy standard should be reduced to one or two telegraphy
examination elements -- and, if so, what the required speed(s) should be. Numerous commenters support a
reduction in the number of telegraphy elements from three to one. These commenters disagree, however,
regarding what the required telegraphy speed should be. Some commenters state that the only telegraphy
speed should be 5 wpm. Other commenters express a preference for a speed of seven wpm, or the
lowest speed allowed by international agreement. Mr. Holton E. Harris states, however, that reducing
the Morse code element to a single 5 wpm examination trivializes it to the point that there is no longer a
meaningful examination requirement and, thus, it might as well be eliminated.
33. Some commenters support retaining the present 5, 13, and 20 wpm telegraphy examination
requirements or increasing the telegraphy requirements for obtaining a FCC-issued amateur service
license. Other commenters suggest that we revise the telegraphy examination requirements so that they
sunset if the Radio Regulations are revised in year 2001 to eliminate the requirement that an amateur radio
operator demonstrate the ability to send by hand and receive by ear texts in the Morse code. Another
option advanced in the comments is to reduce the number of telegraphy examination elements from three to
two. The American Radio Relay League suggests that we substitute a 12 wpm telegraphy examination for
both the 20 wpm telegraphy examination currently required for the Amateur Extra Class operator license
and the 13 wpm telegraphy examination currently required for the Advanced Class operator licenses. It
also suggests that we reduce the telegraphy requirement for a General Class operator license to 5 wpm,
and requests that we authorize privilege below 30 MHz to Technician Class licensees who have not passed
a telegraphy examination. Numerous other comments agree that the telegraphy requirement for the
General Class operator license should be only a 5 wpm telegraphy examination, while others suggest
other proficiency requirements for telegraphy examination elements.
34. We have considered the comments on this issue and conclude that the required speed for the
telegraphy examination element should be 5 wpm. In this connection, we note that this is the minimum
telegraphy speed that has been required for the Novice Class operator license since 1951, and is the
minimum telegraphy proficiency that must be demonstrated by a Technician Class licensee to be authorized
HF privileges. Because both of these classes of operator licenses authorizes HF privileges, 5 wpm is a
speed that the Commission has found sufficient to meet the requirement of the Radio Regulations, and the
slowest telegraphy speed in the amateur service examination system. We believe that, consistent with our
decision to reduce the number of telegraphy elements from three to one, we also should use the least
burdensome requirement, the 5 wpm requirement, as the standard for that element.
35. Likewise, we will not revise the rules so that the telegraphy examination requirement
automatically sunsets if the Radio Regulations are revised to eliminate a mandatory telegraphy proficiency
requirement. In this regard, we do not believe that it would be prudent, at this time, to premise the
resolution of this issue on decisions to be made at the next World Radio Conference (WRC), particularly
given that it is uncertain whether the WRC will actually address this issue. We also note that the
International Amateur Radio Union Administrative Council has stated that it opposes changing the Radio
Regulations to reduce the minimum international qualifications for an amateur radio license, making the
potential changes to this Radio Regulation even more uncertain.
36. The Notice also requested comment on whether we should consider specifying the method of
examining for Morse code proficiency instead of allowing VEs to determine how to test for code speed
were we to reduce the required Morse code examination elements. Currently, VEs have the option of
determining the most appropriate method, including changing the method on a case-by-case basis, to allow
an applicant to demonstrate his or her telegraphy skills. Some commenters express the view that we should
limit the methods available to VEs for examining for Morse code proficiency to either one minute of solid
copy or a fill-in-the-blank examination, and that these methods are adequate. Other commenters contend
that there should be a single testing method available to VEs: require an applicant to correctly copy one
minute of the code message in order for the applicant to pass the telegraphy examination. Mr. Ray
Adams states, however, that requiring one minute of solid copy would be unworkable for the VECs because
it would result in a tremendous backlog of detail in large examination sessions and controversies when the
VEs interpret handwriting differently from what the applicant actually intended or claimed the handwriting
response to be. Other commenters suggest that the VEs should be limited to three methods: one minute
of solid copy or a ten-question written examination of either multiple-choice or fill-in-the-blank.
37. The NCVECs states that the current arrangement for the preparation and administration for
Morse code examinations as provided for in the Commission's rules is adequate and there is no need to
change or add to them. Ms. Anne K. Fanelli and others state that VEs should continue to be allowed to
determine how to test for telegraphy proficiency. Mr. West states that the test structure should be left up
to the individual VE teams. The ARRL, however, suggests that the method VEs must use to determine
whether an applicant passes a telegraphy examination should be specified in the Rules to ensure
examination uniformity and fairness to all examination candidates. Specifically, the ARRL proposes
that the Rules be amended to require that VEs be limited to using either a ten-question fill-in-the-blank
examination or one minute of solid copy to determine whether an applicant has passed a telegraphy
examination.
38. We have considered the comments on this issue and have decided not to adopt rule
amendments that inadvertently could limit VEs' flexibility in administering telegraphy examinations. In this
regard, we note that rule changes that specify the method VEs must use to administer telegraphy
examinations would serve to limit the flexibility VEs currently have. We are persuaded by the NCVECs
that the current rules applicable to the preparation and administration for Morse code examinations are
adequate and there is no need to change or add to these rules. We are not persuaded that rigid examination
uniformity results in fairness to all examination candidates, and we note that, even if we were to adopt the
changes requested by the ARRL and others, the uniformity they seek would not necessarily result because
VEs are required to modify examination procedures to accommodate individuals with disabilities.
39. With regard to ARRL's requests that we change telegraphy examination procedures and
impose other requirements on applicants before examination credit is given pursuant to a Physician's
Certification of Disability, we noted that these issues only remained relevant if we retained the higher
telegraphy speeds requirement. In that we have decided not to retain the higher telegraphy speeds
requirements, no person now will be required by our Rules to demonstrate telegraphy proficiency at higher
telegraphy speeds. In this regard, we agree that by reducing the telegraphy requirement to a single 5 wpm
telegraphy examination, the need to grant credit based on a Physician's Certification of Disability would
be eliminated. We also agree with Courage Handi-Ham System that reducing the emphasis on
telegraphy proficiency may encourage some individuals with disabilities to participate in the amateur
service and that provisions must remain in place for accommodating individuals with severe disabilities.
In this regard, we note that no changes to this rule were proposed in the Notice; furthermore, no actions
taken herein will limit or eliminate such accommodations.
3. Written Examinations
40. Background. Currently, a written examination is prepared and administered to each applicant
for each class of amateur radio operator license. The purpose of the written examination is to allow the
applicant to demonstrate that he or she possesses the operational and technical qualifications required to
perform properly the duties of an amateur service operator licensee, i.e., that he or she is qualified to be an
amateur service licensee. The written examination questions are drawn from a uniform national database
of multiple-choice questions and answers approved by the NCVECs using an algorithm that is specified in
the Rules. This database is periodically updated to provide access to current examination questions.
The database is arranged into five examination elements, each of which contains questions applicable to the
privileges of one of the six classes of amateur radio operator licenses. To qualify for an amateur radio
operator license, an applicant must pass or receive credit for one or more written examination elements and,
if required, a telegraphy examination element. The components of the written examinations were carried
over into the VE system from the examination used previously when the Commission prepared and
administered amateur radio operator examinations.
41. In the Notice, we sought comment on all aspects of the written examinations that an individual
is required to pass in order to become an amateur radio operator or to obtain a higher class of amateur
radio operator license. We noted that the topics tested in the written examinations are the topics the
Commission used when it prepared and administered amateur radio operator examinations over fifteen
years ago. In light of this fact, we sought comment on whether these topics still adequately cover the
significant categories of information relevant to determining whether an applicant has the qualifications to
become an amateur service licensee. Specifically, we asked whether we should add elements to the
written examination elements to ensure a working knowledge of the newer digital technologies which, in
part, are replacing the Morse code. In addition, we asked whether the required number of questions from
each general topic should continue to be established by rule, noting that the written examinations have been
prepared and administered under the VE system for over a decade. We also sought comment on:
whether the written examination requirements should be modified to provide VEs and VECs additional
flexibility in determining the specific contents of written examinations, the specifics of what such flexibility
should entail, and the advantages and disadvantages of providing such flexibility.
42. Decision. The comments we received regarding the written examinations required to obtain an
amateur radio operator license have convinced us that the current written examination elements are not
adequately demonstrating whether an individual is qualified to be an amateur service licensee. In this
regard, we note that almost all of the comments suggest that some type of change to the current system is
needed. We believe that the changes suggested by the NCVECs and Ray Adams, among others, will result
in an examination system that is more relevant, that is simpler for examinees and licensees to understand,
and that takes advantage of the ability that the VECs consistently have shown since 1986 to maintain the
question pools. We, therefore, will amend Section 97.503(b) of our Rules to require that the Technician
Class and General Class written examination elements consist of thirty five questions each, and that the
Amateur Extra Class written examination element consist of fifty technically oriented questions, including
questions about administering amateur radio operator license examinations. Additionally, we believe that
these changes will eliminate rules that are unnecessary and will provide VEs and VECs additional
flexibility as the majority of commenters have requested. Moreover, these changes will streamline further
our administration of the amateur service. We also agree that the Question Pool Committee of the
NCVECs has a better ability to insure that the question pools reflect current technology than we do by
specifying general topics in our Rules. Accordingly, we will revise the number of questions in written
examination element question sets, and we will revise Section 97.503(c) of our Rules to remove the general
topics and algorithm specified therein. We agree that the Question Pool Committee of the NCVECs is
capable of both specifying topics and organizing questions by topic, if this function is necessary, as part of
its maintenance of the question pools for amateur radio operator examinations. We note that allowing the
Question Pool Committee of the NCVECs this flexibility will allow material included on amateur radio
operator examinations to reflect technological advances in a much more timely fashion than can be
accomplished by the rulemaking process. In the event that individual incidents of abuse of this flexibility
are brought to our attention, we note that Section 97.519(d) of our Rules provides a mechanism whereby
we can address such abuses.
43. The majority of comments on this issue strongly agree that the written examination elements
are in need of updating or changing. Additionally, some comments point out that the number of written
examination elements can be reduced to better correlate with the reduced number of license classes we are
adopting. Others suggest standards we should use in determining what the written examination elements
should cover. We agree that the rule specifying the written examination elements is in need of updating
and should be streamlined to reduce the number of written examination elements. Accordingly, we are
revising Section 97.503(b) of our Rules to reduce the number of written examination elements from five to
three and aligning these elements so that they correspond to the remaining classes of amateur radio operator
licenses. We also are revising Section 97.503(c) of our Rules to provide VEs and VECs additional
flexibility in determining the specific content of written examinations. Finally, we are revising Section
97.505(a) of our Rules to align the Rule for element credit with the new written examination elements. We
will discuss below these changes to the rules in the context of each of the topics on which we requested
comment.
44. In response to our request for comment regarding the relevance of the general topics in Section
97.503(c) of our Rules to determine whether an applicant is qualified to become an amateur service
licensee, two commenters say that the current topics are not relevant. In this connection, NCVECs, for
example, states that the topics currently specified in Section 97.503(c) fail to take into account changes in
operating habits, technology, and transmitting equipment that have occurred over the past fifteen years, and
that this rule section results in VEs administering examinations that contain questions on topics that are not
appropriate to the class of license for which the examination is being administered. For example,
NCVECs and Ray Adams state that it is not necessary for licensees to understand electronics and other
technical subjects in order to properly operate commercially manufactured equipment. To make the
examinations a valid means of determining whether an applicant is qualified to be an amateur service
licensee, Kenwood says the written examination requirements should be revised to eliminate questions that
call for memorization of operating trivia and, instead, should focus on technical theory that a licensee in a
technical avocation should be expected to know. Revising written examinations in this way, Kenwood
says, would further the technical art of telecommunications. QCWA, however, believes that, with the
exception of advanced technologies, the examinations are adequate, and it recommends that questions on
advanced technologies be included in future examinations. Myron W. Manker states that some written
examination element topics appear to be somewhat duplicative. The ARRL believes that some topics can
be consolidated, but does not propose specific changes to the ten topics contained in Section 97.503(c) of
our Rules.
45. Other commenters suggest that revisions to the written examinations are needed to add new
topics or change the emphasis among existing topics. Some commenters suggest that the written
examinations test on law, operating practice, and theory applicable to particular amateur service
bands. The Marlboro Youth Repeater Association states that the written examination question pools
should include more questions on boolean logic, computer programming, and modern digital techniques,
while Ms. Anne K. Fanelli states that a greater emphasis should be placed on station design, trouble-
shooting skills, and maintenance.
46. In response to our request for comments as to whether we should add elements to the written
examination to ensure a working knowledge of the newer digital technologies which, in part, are replacing
the Morse code, the commenters agree that such a change is desirable. Several commenters state that
questions on new digital technologies should be added because these technologies will be used in the near
future.
47. Regarding whether the number of required questions from each general topic either should be
changed or should not continue to be established by rule, the comments generally express the view that
changes are warranted. For example, a number of commenters suggest that the written examination
elements contain a different number of questions and topics for each class of amateur radio operator license
than is presently required by our Rules. Several commenters believe that the passing grade of 74% is
too low and that many of the questions currently in the written examination question pools are very
simplistic. NCVECs, however, states that the number of required questions from each general topic need
not continue to be established by rule. Rather, it suggests that we eliminate Section 97.503(c) of our Rules
and that the VEC Question Pool Committee should determine the topics and questions that are appropriate
as part of the process of reviewing and revising the various question pools. ARRL, on the other hand,
states that the topics specified in Section 97.503 of our Rules provide the only element of standardization in
the examination process and believes that some version of the syllabus must remain in our Rules. ARRL
agrees, however, that the number of questions per topic on an examination element needs to be changed to
emphasize different topics for different classes of licenses.
48. Mr. Fiebig suggests that we increase the number of questions in the question pool, possibly
even double them, that the number of questions on each examination be increased, and that the passing
score be increased. NCVEC and West suggest that the Technician Class written examination consist of
fifty VHF oriented questions, the General Class written examination consist of fifty questions taken from
the present written examination Element 3B, and the Amateur Extra Class written examination contain 100
technically oriented questions, including questions about administering amateur radio operator license
examinations. Mr. Russ Ward, on behalf of the Nashville Volunteer Exam Team, states that the current
written examination system is fine with no fixing needed. He suggests, however, that we require all written
examination elements to contain fifty questions as a gesture for improving the quality of amateur radio
operators. ARRL suggests thirty five questions for both the Technician and General Class operator
license written examinations, and forty and fifty questions for the Advanced and Amateur Extra Class
operator license written examinations, respectively. Mr. Ray Adams states that increasing the revised
written examination elements to more than fifty questions would be a major transition problem for more
than one VEC, including his own VEC.
49. The comments we received addressing the issue of whether the written examination
requirements should be modified to provide VEs and VECs additional flexibility in determining the specific
contents of written examinations supported providing VEs and VECs this flexibility. For example, Ray
Adams suggests that the Question Pool Committee of the NCVEC could, and would, keep the question
pools more in line with current technology than has been accomplished by the "mini syllabus" in Section
97.503(c) of our Rules. The ARRL states that the Commission already offers the VECs significant
flexibility in preparing and maintaining question pools, and states, moreover, that the element standards
contained in Section 97.503 of our Rules are not burdensome. Several commenters point out, however,
that revisions to the written examination elements might have a significant impact on publishers of amateur
radio study guides. They request, therefore, that if we make any changes to existing written examination
elements, we make them in such a way that we do not make obsolete study guides that have been published
but not sold.
50. We believe that the general standard suggested by the ARRL -- i.e., testing should be related
to privileges, should place greater emphasis on operating practices and current technologies, and should
support and encourage experimentation -- is a reasonable standard for the Question Pool Committee of
the NCVECs to use in reorganizing the current question pools and revising the written examination
elements. In addition, we agree with Kenwood that the written examinations should test minimum
qualifications for a licensee to ensure that the licensee has the basic understanding of various levels of
amateur radio operating activities and radio technical theory. In this regard, Kenwood states that the
Technician Class operator license examination should primarily relate to simple electronic theory and
proper operation of equipment, that the General Class operator license examination should cover
intermediate electronic theory and operating techniques, and that the Amateur Extra Class operator license
examination should relate to advanced electronic theory and advanced communications systems. Mr.
Pitman states that the VHF (i.e., Technician) Class operator license written examination should test only on
FCC rules and operating procedures relevant to VHF and UHF.
51. With regard to specific changes to the number of questions on the written examination
elements, we adopt the changes suggested by NCVEC. We, therefore, will amend Section 97.503(b) of our
Rules to require that the Technician Class and General Class written examination elements consist of thirty
five questions each, and that the Amateur Extra Class written examination element consist of fifty
technically oriented questions, including questions about administering amateur radio operator license
examinations. The comments from QCWA, NCVEC, and West suggesting that we combine the present
written examination Elements 4A and 4B to create the new written examination Element 4 for the Amateur
Extra Class license, appears to be a simple and straightforward method the Question Pool Committee
should consider for creating this new element. West's suggestion that we combine the present written
examination Elements 2 and 3A to create a new written examination Element 2 for the Technician Class
license, and Ray Adams' suggestion that we combine the present written examination Elements 3A and
3B to create a new written examination Element 3 for the General Class operator license, while slightly
inconsistent, also are options the Question Pool Committee could consider. Moreover, these suggestions
appear to satisfy publishers' concerns that we make changes to the written examination elements in such a
way that we not make obsolete study guides that have been published but not sold. We also will
redesignate the written examination elements as written examination Elements 2, 3, and 4.
52. In addition, we are revising Section 97.505 of our Rules to conform it with our revisions to
Sections 97.501 and 97.503 of our Rules. This revision is a necessary and logical outgrowth of our
proposal to revise the license structure and the written and telegraphy examination elements. Currently, an
examinee receives examination credit from the VEs for each examination element specified for the class of
license that the examinee holds. Because the revised examination system will be comprised of three written
examination elements and one telegraphy examination element, instead of the present five written
examination elements and three telegraphy examination elements, we believe that adjustments to the
element credit rule are necessary. We are amending the rules so that licensees who previously have passed
a telegraphy examination will not have to pass another telegraphy examination to advance to the highest
class of operator license. Additionally, licensees who have passed all the written examination element
components of a revised written examination element(s) will continue to receive credit for the revised
element(s). However, licensees who, in the past, passed a written examination element that no longer
exists or has been subsumed in a more comprehensive examination element, will have to pass the new
element. In this regard, we note that licensees who are required to pass a written examination element that,
in part, may include material they have been tested on previously, such as Advanced Class licensees
upgrading to the Amateur Extra Class operator license, receives the offsetting benefit that they can upgrade
their license class without having to pass a higher speed telegraphy examination.
4. Disposition of the Designated Novice Band
53. Background. When the Novice Class operator license was established in 1951, limited
frequency segments in the HF portion of the radio spectrum were established for Novice Class operators so
that they could improve their telegraphy skills by practicing telegraphy on-the-air. This on-the-air use of
telegraphy was necessary, in part, because the Novice Class operator license was a one-year, once-in-a-
lifetime, non-renewable license. At the end of the year, the licensee was required either to upgrade his or
her license or discontinue operations. Specific frequency segments for Novice Class operators have been a
part of the amateur service license structure since 1951. These frequency segments are available to other
class licensees but, with the exception of the 10-meter frequency segment, only at reduced power. In the
Notice, we requested comment on whether it would be appropriate to delete the frequency limitations on
Novice Class operators and the power limitations on other classes of operators using the Novice
frequencies if we were to discontinue licensing new Novice Class operators.
54. Decision. We have considered the comments on this issue and have decided that because we
are grandfathering Novice Class operator licenses, rather than automatically upgrading them to General
Class operator license as requested by the ARRL, we will not adopt any rule changes at this time that
would change operating privileges for any licensee within the frequency segments currently authorized
Novice Class operators. We also note that the comments are divided as to what the future use of these
frequency segments should be. For example, Mr. Vernon H. Ferris states that the Novice bands should be
eliminated and suggests that the HF band segments be aligned with band plans presently used in Canada,
Europe, and other parts of the world. Other commenters state that Novice Class operators should be
allowed to operate Morse code with 200 watts output anywhere within the 80-, 40-,15-, and 10-meter
bands, and the current Novice subbands should be reallocated only to narrowband operations (Morse and
digital modes). Mr. Fiebig suggests eliminating the current Novice frequency allocations as such and,
instead, divide them between low power voice and low power Morse code and digital emission types, while
maintaining the current power limitations. Mr. James N. Hess states that we should preserve power
limitations on all classes of operators in the present Novice Class HF frequency segments.
55. Mr. James A. Wades states that any increase in voice allocations at the expense of Morse code
and digital allocations poses the risk of stunting the growth of new digital communications modes. The
ARRL, however, requests that the Novice Class telegraphy subbands should be used to expand the
frequency segments available for telephony. California Central Coast DX Club states that the Novice
bands should be returned to general usage for General Class and higher class licensees. Mr. Umina
states that the Novice bands should remain unchanged; however, Novice Class licensees should be
authorized additional privileges in four of the HF amateur service bands.
56. We note, as an initial matter, that frequency segments available to Novice Class control
operators also are available to Technician Plus Class operators for telegraphy and to General, Advanced,
and Amateur Extra Class licensees for the transmission of RTTY and data emission types. Therefore,
we believe that our Rules already provide the use that California Central Coast DX Club requests. As for
the suggestion of others that we eliminate the Novice bands, we will not adopt this suggestion because the
remaining comments convince us that there is no consensus within the amateur service community
regarding rule changes we should make concerning these frequency segments. We also note that
reallocation of these frequencies segments could have an effect on implementation of modern technologies
into the amateur service and that we have previously decided that we should accord the amateur service
community an opportunity to complete such discussions and possibly reach a consensus regarding
implementation of new technologies before a comprehensive restructuring of the amateur service operating
privileges and frequencies is undertaken.
B. Greater Volunteer Examiner Opportunities
57. Background. The basis for the Volunteer Examiner program is set forth in Section 4 of the
Communications Act. Under this Section, any individual who holds an amateur station operator license
of a higher class is permitted to prepare or administer any examination for an amateur station operator
license of a lower class, provided the examiner is accredited by the VEC coordinating the examination
session and meets other requirements. Currently, only an Amateur Extra Class licensee can administer
an examination for a General Class operator license. In the Notice, we proposed to authorize Advanced
Class licensees to prepare and administer examinations for the General Class operator license, as requested
by the ARRL. We stated that this proposal would benefit potential amateur service licensees by having
additional volunteer examiners available for the examinations.
58. Decision. We conclude that the public interest will best be served by allowing Advanced
Class licensees who are certified VEs to prepare and administer examinations for the General Class
operator license. In this connection, we note that in all cases, Advanced Class VEs would be preparing and
administering elements for which they themselves have received credit and, therefore, allowing Advanced
Class VEs to prepare and administer General Class operator license examinations is consistent with the
Communications Act.
59. The comments we received generally supported our proposal. For example, NCVECs and
ARRL agree that Advanced Class licensees who are VEs should be permitted to prepare and administer
examinations for a General Class operator license and that allowing these VEs to perform these functions
would help in areas where VEs are needed but are in short supply. Mr. William Reed also agrees,
stating that having more VEs would reduce the "burnout factor" and could possibly increase the number of
examination opportunities. Some commenters, however, do not support our proposal. For example, Mr.
David L. Heller says there should be no shortage of VEs to administer General Class operator license
examinations because about 10% of all amateur service licensees (i.e., approximately 72,000 licensees) are
Amateur Extra Class licensees. He suggests that instead of authorizing Advanced Class licensees to
prepare and administer examinations for the General Class operator license, we should permit the VECs on
a special accommodation basis to accredit additional VEs to administer examination in isolated instances
where a shortage of VEs might occur. Mr. Umina opposes allowing Advanced Class licensees to
administer General Class license examinations on the basis that this change would raise some security
issues with regard to examination material. Mr. Dale Gagnon states that expanding VEs to include
licensees with lower class operating licenses places a burden on VE organizations to match up the
examiners with the examinees during the examination sessions. This burden, he says, can lead to
complexity in administering the tests and increased possibility for error. Mr. Edward J. Zupan suggests
that we eliminate the VE system altogether.
60. We do not agree with Mr. Heller's suggestion that we permit VECs on a special
accommodation basis to accredit additional VEs because there is no objective way of determining what
would constitute a special accommodation basis. In addition, we are concerned that such an approach
would impose additional burdens on the both the VECs and the Commission, a result which we do not
believe would be in the public interest or consistent with the underlying goals of this proceeding. We also
do not agree that allowing Advanced Class VEs to administer General Class license examinations would
raise security issues with regard to examination material or would increase the complexity of matching VEs
with examinees at examination sessions. We note that Advanced Class VEs currently may prepare and
administer examinations for the Novice and Technician Class operator licenses and that there have been no
significant issues surrounding examination material security of which we are aware. Thus, we have no
reason to believe that Advanced Class VEs administering General Class operator license examinations
would be any less careful than would Amateur Extra Class VEs in protecting the integrity of the
examinations. Additionally, we note that one of the functions of the VEC is to screen application forms to
ensure that examinations were administered only by properly accredited VEs. We do not believe that
allowing Advanced Class licensees to administer General Class operator license examinations increases the
burdens on VECs as presently they perform this screening function. Thus, we adopt the proposal as set
forth in the Notice.
C. RACES Station Licenses
61. Background. The RACES, as it was envisioned when it was authorized in 1952, was to be a
temporary service designed to afford radio communication for civil defense purposes. Under our Rules,
we permit two types of stations to operate as part of the RACES: (a) a licensed RACES station, and (b)
any amateur station that has been properly registered with a civil defense organization. Thus, we
observed that to engage in RACES communications, it is not necessary to have a RACES station license
with a separate and distinct call sign. For that reason, we proposed to amend our Part 97 Rules to phase
out RACES station licenses by not renewing them. We observed that by eliminating the RACES station
licenses, we would be taking steps which (a) would eliminate licensing duplication because emergency
communications that are now transmitted by RACES stations also may be transmitted by primary, club, or
military recreation stations, and (b) would conserve our financial resources. We also observed that no
new RACES station licenses have been granted since July 14, 1980. In addition, we proposed to
continue the status quo by not issuing any new RACES station licenses.
62. Decision. Most of the comments specifically addressing this issue support our proposal to
phase out RACES station licenses. In contrast, the elimination of RACES station licenses is opposed by
Mr. William R. Slye, Jr. He states that in an emergency situation, it is beneficial to have a continuity of
call signs so that a certain call sign is associated with a particular Emergency Operations Center or other
emergency facility. He also believes that issuing RACES licenses is not overly burdensome to the
Commission because current automation in licensing is available at the Commission. Taking a neutral
position, Mr. Martin D. Wade suggests that before we take any further action regarding RACES station
licenses, we should further study the RACES program and its place in Part 97 of our Rules.
63. After review of the record, we conclude that we should eliminate RACES station licenses
because RACES station licenses are unnecessary for amateur stations and amateur service licenses to
provide emergency communications. Additionally, these licenses duplicate the communications that we
have authorized primary, club, or military recreation stations to transmit, and not issuing RACES station
licenses would conserve our financial resources because, currently, such issuance is not an automated
process.
D. Privatization of Certain Enforcement Procedures
64. Background. Pursuant to the Communications Act, the Commission has authority, for
purposes of monitoring violations of any provision of the Communications Act, to accept and employ the
voluntary and uncompensated services of any individual licensed by the Commission to operate an amateur
station. The functions of individuals who provide such uncompensated services, commonly called the
Amateur Auxiliary, are limited to the detection of improper amateur radio transmissions, the conveyance to
Commission personnel of information which is essential to the enforcement of the Communications Act
relating to the amateur radio services, and other functions. In the Notice, we sought comment on other
ideas for improving our enforcement processes as they relate to amateur radio. We suggested, for
example, that one possibility might be to encourage or require persons bringing complaints of interference
to the Commission to include a draft order to show cause to initiate a revocation or cease and desist hearing
proceeding. We also requested additional comments and suggestions on how we could better utilize the
services of the Amateur Auxiliary, consistent with its statutory basis.
65. Decision. After review of the record, we conclude that we will adopt the suggestion of the
ARRL to withhold any additional action on amateur radio service enforcement based on the increased
amateur radio service compliance efforts recently undertaken by the Commission. In this regard, we
note that the commenters are divided over the need and our ability to improve our enforcement processes as
they relate to amateur radio. The ARRL states that in a 1998 survey it commissioned, it found the most
important issue for both ARRL members and non-members was strict enforcement of FCC rules governing
on-the-air conduct. It requests, however, that we withhold any further action on amateur radio service
enforcement based on the increased amateur radio service compliance efforts recently undertaken by the
Commission. The ARRL states that it is satisfied with the current policies of the Commission and the
encouraging attitude of our Compliance and Information Bureau. Other commenters believe that official
observers should be given authority to warn in the name of the FCC.
66. In contrast, Mr. Jay W. Underdown fears that privatization of Commission enforcement
procedures could make a legalized vigilante group. Mr. Philip Galasso states that enforcement should
remain the exclusive province of the Commission. Mr. Ray Soifer states that compliance activities
performed by the amateur service community will only be effective if official intervention by duly
constituted regulatory authority occurs when necessary. We conclude that our decision is reasonable in
as much as the amateur service community itself has responded very favorably to our increased compliance
efforts directed to on-the-air conduct and compliance with our rules applicable to administering operator
license examinations.
E. Other Issues
1. Out-of-Scope Proposals and Comments
67. Some commenters suggest substantive changes to the amateur service rules in addition to those
proposed in the Notice. For example, Northern California Packet Association requests that we revise
Section 97.303(e) of our Rules to delete the requirement that amateur stations receive permission from an
AMTS station to operate in the 219-220 MHz segment if the amateur station is within 80 kilometers of an
AMTS coast station. Likewise, Southern California Remote Repeater and Remote Base Association
requests that we require mandatory coordination of repeater stations operating in the VHF and UHF
amateur service bands, a request others oppose. Other comments suggest that we mandate retesting of
licensees as a condition of renewal of an amateur service license, that we amend Section 97.305 of our
Rules to revise the authorized emission types in many medium frequency, high frequency, and VHF
amateur service bands, or that the control operator privileges be amended when the station transmitting is
a club station. These requests are beyond the scope of this proceeding because either they are the subject
of another rulemaking proceeding or they involve rule sections which we did not propose to amend and
are not a logical outgrowth of the rules originally proposed to be amended. Other requests, such as
instituting license fees to pay for the workload and enforcement actions that the Commission has to
support, would require statutory changes to the Communications Act and are solely within the provence
of Congress. Therefore, we neither intend, nor are we able to address these out-of-scope issues in this
Report and Order.
2. Editorial Matters
68. We also are making minor amendments to various rule sections to eliminate duplicative
language and conform them with this or other Commission decisions. Specifically, we are revising Section
97.13(c) of our Rules to correct the name of OET Bulletin Number 65. We also are revising Sections
97.307(f)(10) and 97.313(c)(2) of our Rules to clarify that only Technician Class control operators who
have satisfied the Radio Regulations telegraphy requirement are authorized to transmit a phone emission
below 30 MHz. We consider these revisions to be non-substantive in nature. IV. CONCLUSION
69. Consequently, in view of the foregoing, we are amending our rules to: (a) reduce the number
of amateur radio operator license classes from six to three, (b) reduce the number of written examination
elements from five to three and the number of telegraphy examination elements from three to one, (c)
authorize Advanced Class amateur radio operators to prepare and administer examinations for the General
Class amateur radio operator license, and (d) eliminate RACES station licenses. The amended rules which
are appended hereto will simplify and streamline the regulations that govern the Amateur Radio Service.
V. PROCEDURAL MATTERS
Regulatory Flexibility Act
70. The Regulatory Flexibility Act (RFA) requires that an agency prepare a regulatory
flexibility analysis for notice-and-comment rulemaking proceedings, unless the agency certifies that "the
rule will not, if promulgated, have a significant economic impact on a substantial number of small
entities." In the Notice, the Commission certified that the proposed rule amendments, if promulgated,
would not have a significant economic impact on a substantial number of small business entities, as defined
in Section 601(3) of the Regulatory Flexibility Act because the rule amendments do not apply to small
business entities. Rather, the rules apply to individuals who are interested in radio technique solely with
a personal aim and without pecuniary interest . No comments were received concerning this certification.
The Commission now affirms this certification with respect to the rules adopted in this Report and Order.
Accordingly, the Commission certifies, pursuant to Section 605(b) of the RFA, that the rule adopted herein
will not have a significant economic impact on a substantial number of small entities, as defined in the
RFA.
71. Alternate formats of this Report and Order (computer diskette, large print, audio recordings
and Braille) are available to persons with disabilities by contacting Martha Contee at (202) 418-0260, TTY
(202) 418-2555, or by e-mail at <mcontee@fcc.gov>. This Report and Order also is available at the
Commission's internet site at: <http//www.fcc.gov/wtb/amateur>.
VI. ORDERING CLAUSES
72. IT IS ORDERED that effective April 15, 2000, pursuant to Sections 4(i) and (j), 303(r), and
403 of the Communications Act of 1934, as amended, 47 U.S.C. 154(i) and (j), 303(r) and 403, Part 97
of the Commission's Rules, 47 C.F.R. Part 97, IS AMENDED as set forth in Appendix B.
73. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and (j) and 303(r) of the
Communications Act of 1934, as amended, 47 U.S.C. 154(i); (j), 303(r) that the petition for rulemaking
filed by the ARRL, RM-9196, on September 23, 1997, IS DISMISSED as moot.
74. IT IS FURTHER ORDERED that the Consumer Information Bureau, Reference Information
Center, SHALL SEND a copy of this Report and Order, including the Regulatory Flexibility Certification,
to the Chief Counsel for Advocacy of the Small Business Administration.
75. IT IS FURTHER ORDERED that this proceeding IS TERMINATED.
Further Information
76. For further information, contact William T. Cross or Bert Weintraub, Policy and Rules
Branch, Public Safety and Private Wireless Division, Wireless Telecommunications Bureau, at (202) 418-
0680 voice or Wireless Telecommunications Bureau TTY at (202) 418-7233.
FEDERAL COMMUNICATIONS COMMISSION
Magalie Roman Salas
Secretary
Attachments: Appendix A
Appendix B APPENDIX A
Comments
STAN GANTZ
BRITT HAY
LEROY KLOSE III
LEROY KLOSE III
JON ERICSON
WILLIAM E. DISMORE
STEVEN JAMES ROBESON
LEROY KLOSE III
LEROY KLOSE III
DAVID BROOKS
PAUL J. ANTONIEWICZ
JAN A. TARSALA
SHELLEY L. PENDLETON
JAMES REYNOLDS
PAUL J. ANTONIEWICZ
ARLEY A. GARWIN ET AL
JOHNNY COLLINS
REX PICKETT, P.E., KA7NQK
RAY SOIFER
DONALD N. TRAMMELL JR.
KENNETH R. BUSER
WILLIAM DUMAS
GARY RANEY
JET PROPULSION LABORATORY AMATEUR
RADIO CLUB
KENNETH S. CANNADAY
PAUL R. SIGNORELLI
STEVE SNYDER
JERRY WAYNE ALEXANDER JR
DAVID D. MEACHAM, W6EMD
WILLIAM S. HOWELL
GARY W. ROBERTSON
MICHAEL BINDER
JOHN W. SPENCE
MICHAEL HODGE
G E STOCKTON
JAMES R REID, KH7M
JAMES R REID, KH7M
JAMES C. MARCINIAK N1RUI
JACOB LAUSER KK7GP
JAMES C. OWEN, III
JOHN R. MORIARITY
GEORGE F. ALLGOOD
WILLIAM J. RISCH
WILLIAM J. RISCH
DON C. FAITH III
CHARLES CROUCHET
WALTER W. WOODY
ROGER HIGHTOWER
ROBERT G. PARKS
ALLAN E. HOBRON
JERRY HAIGWOOD
MICHAEL RIOUX
J. B. EDMONDS
FLOYD JACOBS
FLOYD SOO
ANDY MENG
JEFFREY A. JOHNS
ROY J. WITT
JOSEPH P. FREEMAN N0ODA
NICHOLAS ROY SMITH
RICHARD W. DZICK
ROGER G. HARTEL
DONALD B MORGAN
ALAN M. TANNER
JAMES C. WORTHINGTON
CHARLES THOMAS NIMS, KC7VJE
RICHARD T. MACDONALD
THOMAS E. POWER JR.
KENNETH O. KIRBY
KENNETH L. LILES
ARTHUR T. NICKEL
THOMAS F. LEWIS
NUMEROUS
VERNON D. COLE
JONATHAN MINER
JAYSON TATLOCK
DENNIS BRISCOE
MILO VALENCIC
MARTIN SHARPE
CINDY TATLOCK
CARLOS OZORES
DAVID SMITH
JOHN BELL
FCC
LARRY R FRAVEL
DAVID TOWNSEND
TIM CAHILL
STEVE CHILDRESS WB6CSZ
MONT O'LEARY, K0YCN
SHAUN C. STEWART
WIRELESS TELECOMMUNICATIONS BUREAU
DARREN REAM
LAWRENCE E MELBY II, KA5TXL
LAWRENCE E MELBY II
RICHARD L. TANNEHILL
TONY STIPICH
JOHN ABBOTT, K6YB
JORGE VILLOCH
KENDALL LEE KURTH
NUMEROUS
CARY MANGUM
ROSS L. REHART
LARRY R FRAVEL
PHILLIP C. HEWLETT
JIMMY L. HOLBROOK
JERRY BUSTIN
DAVE MYERS
JOHN J. KEATING
LEWIS BELL
JOHN EARY
MINNETONKA MINNESOTA AMATEUR
RADIO CLUB
NORMAN B. KEON
SCOTT ADAM MOORE
NUMEROUS
THOMAS M. DAVIS
ART NICKEL
DALE & TANYA TONGUE
GORDON WEST
NUMEROUS
WESTERN ILLINOIS AMATEUR RADIO CLUB
PHILIP C. HAZLETT
JOHN MICHAEL MARCH W4FJJ
BRUCE JOHNSON
CQ COMMUNICATIONS, INC.
INLAND EMPIRE COUNCIL OF AMATEUR
RADIO ORGANIZATIONS ROY W.
ANDERSON, JR--W1CRD
ROBERT E. GREEN
DOMENECK MURANO
RAYMOND M. STAHL
JERALD SCHNOR
BILL KRAFT
MICHAEL J SPARLING
JIM LEININGER
RADIO CLUB OF TACOMA, WASHINGTON
CLAIRE A. DOUCETTE
JAMES EDWIN BOLTON
DAVID S. FORSMAN
WALTER C. TICE
JAMES H. ISOM
LEE CALLACI
J. L. PRICE
TIM LONG
NUMEROUS
VIRGASUN A. SORDILLIA
BENNET G. DAVENPORT
ROBERT E. HILTON
HARRY A. HODGES
JIMMIE M. SMITH
VERN A. WEISS
R.C. WILLIAMS
CHUCK HOELZEN KC7BNC
ALAN DIXON
NUMEROUS
NUMEROUS
K3ABV
JAMES B. DIDRIKSEN
ALFRED J. HARRISON
WILLIAM E. WYCKOFF
WILLIAM H. ECKELS
TIMOTHY J. FIEBIG
RICHARD S. WILSON
RICHARD E. DAILEY
PHILIP E. GALASSO
RICHARD E. DAILEY
BRYAN F. SICKELS
STEVE H. COLEMAN
JOSEPH S. SARKIS
DAVID A. HENEBRY
GORDON L. LELAND
GEORGE A. BONADIO
THOMAS R. GLAZE
EDWARD J. ZUPON
CECIL A. PALMER
ANNE K. FANELLI
JAMES A. WADES
GILFORD FULLER
JAN A. TARSALA
GERALD ORTMAN
DANIEL DAVID
JIM RINEHART
GREG POLLARD
NOEL GUICE
GREG WASIK
CW LUBAHN
KEN HALE
NEW USER
MUSSLER, MICHAEL, E.
DAVENPORT, RANDY E.
CALIFORNIA CENTRAL COAST
WILLIAM W. THOMPSON
WILLIAM W. THOMPSON
SARA LOUISE K. WOOD
CLARENCE A. TILLERY
MICHAEL A. BOUCHARD
JACK G. VALDOVINOS
MICHAEL W. GAYNON
ERIC S. JOHANSSON
WILLIAM R. MEYERS
THOMAS N. BERBARI
THOMAS E. PARSONS
MICHAEL F. TAYLOR
KENNETH C. NELSON
ROBERT G. FORTMAN
RICHARD G. MEYER
EDWARD A. CONDER
LARRY C. GUNTER
MAUREEN M. HAMM
BOLIN COMMUNICATIONS
MICHAEL MURRAY
JOSEPH SPERONI
HENRY POKORNY
GEORGE DODSON
OLER GENE MAY
JO ANN LYTTON
JEFF SCHMIDT
C. A. SIMSEN
PAUL THEKAN
HENRY CLARK
BOB VERNALL
CHRISTOPHER JASPER
NUMEROUS
NUMEROUS
BRIAN J KEEGAN
AMERICAN RADIO RELAY LEAGUE,
INCORPORATED
JAMES A. PIERCE, K8CAP
PETER B. BROIDA
RICHARD D. KLATZCO JR. N9TQA
RICHARD D. KLATZCO JR. N9TQA
SOUTHERN CALIFORNIA REPEATER AND
REMOTE BASE ASSOCIATION
LESLIE E. SCHMARDER, WA2AEA
COURTNEY B. DUNCAN, ET AL. AMERICAN
RADIO RELAY LEAGUE
KENWOOD COMMUNICATIONS
CORPORATION
WILLIAM M. BROWNFIELD
GREGORY A. DEAN, N9NWO
PAUL J MORRIS KB2ZNW
MICHAEL C. BELLINGER
LEIGH BASSETT, W3NLB
LEIGH BASSETT, W3NLB
LAWRENCE N. BOUCHARD
RICHARD A. DAVIDSON
JAMES MICHAEL WILCOX
GLENN E. LEWIS, SR.
ROBERT E. RIGHTMIRE
NO CODE INTERNATIONAL
LEONARD O. GOEGLEIN
KENNETH S. CANNADAY
GEORGE H. GOLDSTONE
TERRY C. WHITESIDE
STEPHEN M. MANDICH
STANLEY J. BRIGGS
SHEPHERD, JAMES F.
GEOFFREY G. BILLIN
ELIZABETH L. DOANE
ARTHUR, CHARLES P.
WILLIAM T. SAMPSON
SYLVIA K. THOMPSON
KENNETH A. PILETIC
WILLIAM T. SAMPSON
WILEY, MICHAEL J.
WILLIAM L. YESTER
THOMAS R. BREEDEN
THOMAS J. COLEMAN
RICHARD WILKERSON
MAUREEN G. KOCHEN
DONALD L. VILLAGE
DONALD L. FLENNER
CARL R. STEVENSON
BRUCE E. THOMPSON
RICHARD F. DOWNES
JOHN H. HENDERSON
THOMAS E. KUEHL
MCCOLMAN JOHN C.
GERALD F. WARNER
CARL LAVINIKEVICH
BRADLEY J. KNAPP
VERNON H. FERRIS
RAYMOND K. ADAMS
MARVIN C. REEVES
LARRY W. WHEELER
JAY W. UNDERDOWN
HOLTON E. HARRIS
DANIEL S. LEVINE
MALCOLM P. KEOWN
THOMAS N. DINEEN
FORBES JAMES M
DONALD K. PORTER
DONALD J. DUMAN
DENNIS L. GREEN
RONALD L. MAYER
JOHN J. KEATING
JOEL R. STANLEY
GARY N. BABCOOK
FRAMK A. PITMAN
DAVID L. HELLER
GINNINE TAMBINI
BAVOY D PEARSE
W. DAVID GERNS
ROGER L. RONEK
ROBERT E. WOOD
PERCY WHITMORE
JOHN W. WAGNER
JACK E. LOUDEN
HOMER G. WYATT
ALAN R. NELLES
THOMAS C. HAND
MARTY REYNOLDS
MARTY REYNOLDS
BARNETT CARWILE JACKSON, JR.
YVES A. FEDER
MICHAEL WILEY
LARRY LAMBERT
JAMES N. HESS
JAMES H. ISOM
DAVID R. HAAG
BILL SPRINGER
MICHAEL WILEY
WM H MILLARD
JIM WILLIAMS
HRQWORKS, JR.
JOHN M. C. COVINGTON, III
GREG A. GORE
DONNIE BROWN
DANNY MILLER
C.J. GOODWIN
BRUNO DULUCA
MARY BARBER
MARK THOMAS
PIUNEN PULA
GORDON WEST
DALE GAGNON
ART MCBRIDE
WM L SERRA
TOM BARBER
H. T. BROWN
DAVID L. WILSON, W4DLW
WM A. REID
WILLIAM T. CULBERTSON
WILLIAM P. OVERSTREET
LEO ZUCKER
WALT ER EVANYK W8KSW
JOSEPH F. CALLAGHAN
JOHN STUART KA6QMN
BARRY E BUTZ N8PPF
BARRY BETTMAN, K6ST
HARLON DALE DURHAM
DOUGLAS W. SHERMAN
WILLIAM D. RICKER
WILLIAM A. RUSSIN
WILLIAM A. RUSSIN
STANLEY J. BRIGGS
ROBERT REED W2CE
RALPH B. WINCHELL
DON MERZ
STEVE LUND, K6UM
MARK A. TOWNSEND
PHILIP L. SMITH
PHILIP L. SMITH
JOSEPH D. MOELL
ALAN K. UNANGST
NUMEROUS
NUMEROUS
NUMEROUS
JEROME DOERRIE
BYRON T. BURNS
BJORN LIENCRES
JOHN MCCAULEY
TONI B. ROWE
CRAIG MAHLER
DONKO MIRKO
MARK KAHRS
JIM LEMARR
GARY BURKE
GARY BURKE
JIM MYERS
DON BURNS
ROBERT E. TAYLOR [KC7DJE]
VIA ROBERT SQUIRE, N6AFB
HEART OF AMERICA RADIO CLUB W0RR
JAY CRASWELL W0VNE EX:WB0VNE ROY W.
ANDERSON, JR--W1CRD
PHILIP M. KANE
MURRAY STATE UNIVERSITY AMATEUR
RADIO CLUB
ROY L. VAN RIPER - W7VR
NO CODE INTERNATIONAL,
C/O CARL R. STEVENSON -
WA6VSE
CHARLES E. CARTER (AA0RI)
AARON L. DONALDSON KB9DWU
KAUAI AMATEUR RADIO CLUB
ELMORE NIMROD SCOTT, JR.
YOUNG, JR., WILLIAM A.
YOUNG, JR., WILLIAM A.
LEE W. LUMPKIN, KB8WEV
DAVID B. DEFEBO WB9BWP
CLARK R MANKIN, KA7RRB
HARRINGTON MICHAEL J.
ROBERT SQUIRE, N6AFB
RICHARD P. MARKEY JR.
RALEIGH L. WERT W8QOI
RALEIGH L. WERT W8QOI
JOHN A. CARROLL AB1Z
VINCENT J. BIANCOMANO
TALBERT DELBERT S.
JOHN E. GRIMES ET AL.
STEVEN JAMES ROBESON
JAMES T. SCHLIESTETT
STEVEN K. WHITEHEAD
STANLEY L. VANDIVER
PATRICIA A. FANNING
LAURENCE W. HEDLUND
HENRY S. KNOLL JR.
DELORES W. ROBERTS
DELORES W. ROBERTS
YOUNG, WILLIAM A.
YOUNG, WILLIAM A.
TALBERT DORTHA J.
NASHVILLE VOLUNTEER EXAM TEAM
JAMES P. MICCOLIS
JAMES P. MICCOLIS
FLOYD D. FITZGERALD
RICHARD A. WILLIAMS
WILLIAM JAY SADLER
RONALD K. ANGSTADT
RONALD J. NOTARIUS
RONALD G. SEMERENA
MICHAEL D. FANNING
LUKE HAMATY, KK4LH
DENNIS G. FRANKLIN
HANLON, JAMES T.
VANCE H LEPIERRE
RICHARD L. FOWLER
KEVIN L. ANDERSON
JOHN J. MCDONOUGH
DOROTHY M. UEBELE
DANIEL J. RAYMOND
ALICIA T. FANNING
HERBERT J. ULRICH
HENRY P. MITCHELL
DONALD H. BRANDES
DONALD B. CHESTER
ANTHONY G. GEORGE
WILLIAM W. FREDE
WALTER A. HILTON
W6SGJ
RICHARD RANDOLPH
PAUL W. SCHLECK
PATRICK E. BROWN
MICHAEL C. SCOTT
LEONARD J. UMINA
GEORGE S. UEBELE
BOYD MILTON REAR
BOBBY R. FANNING
ALLAN B. CULBERT
ALLAN B. CULBERT
PAUL B. WILLIAMS
MARK A. DOWNING
ANDREW E. HOWARD
WILLIAM A. RUTH
TIMOTHY J. ISOM
TIMOTHY J. ISOM
MARSHALL G. EMM
JAMES HEATH JR.
GLORIA J. SHARP
GLENN F. VANBLARICUM, JR. W6KNB
ERIC G. HILBERT
EDWARD H. SCOTT
DAVID G. PARKER
ALAN J ATKINSON
SARAH E. HOWARD
RICHARD L. RIEN
RICHARD BECKETT
MARSHAL L. SHAW
DUANE HENDERSON
RAY J. VAUGHAN
KYLE, ARTHUR J.
JOSEPH SPERONI
JOHN W. FARLER
JOHN D. PETERS
DIANNE WILKMAN
DAVID E. GREER
DAVID B POPKIN
CAROL M. SMITH
BRIAN P. BURKE
BLOWSKY JOHN J
ALAN M. TANNER
PAUL A. TURNER
G. D. BRENTLEY
CLYDE R. SMITH
SCOTT D. AND ANNE H. PRATHER
RUNESTONE AMATEUR RADIO CLUB
NATE BUSHNELL
LEWIS , ROY E
JOEL E. SMITH
JIM OBERHOFER
GENE SPINELLI
BERT E. SMITH
REX A. BADGER
GEORGE J. SANTA CRUZ, PH.D.
D. W. STANLEY
B. J. PITTMAN
STEVEN QUICK
LAWS PETER C
ADREA OWNBEY
ADINA OWNBEY
W. DAVID GERNS, SR., K1LD
RAY SOIFER
LESLIE K. SCOFIELD, W4SCO
CARL R. STEVENSON, WA6VSE
CHARLES FOSS
ALFRED D. TIPSWORD W6GER
THOMAS A. FRANK, KA2CDK
SAMUEL K. RANDALL K5WII
RALPH E. STENERSON, JR.
MARTY DRIFT
JOE PREWITT
PETER WANG
GERALD C SPEIDEL N0AOJ
GEORGE L. KATZENBERGER
GEORGE L. KATZENBERGER
ABBEY P. ALPERN, N3WKO
ROBERT K. STEPHENS
ERNEST W. HOWARD, JR.
ERNEST W. HOWARD, JR.
JOHN M. DAMRON, W9MD
BRUCE N. GAVIN
ALAN RICHARD STANLEY
ROBERT M. GINKOWSKI
ROBERT M. GINKOWSKI
PHILLIP A. ROGERSON
DANIEL H. ARNEY JR.
ALAN SLUTSKY KA4FJV
HRQUARKS, JR
WHITSON B. WOODARD
SPENCER F. RITCHIE
MICHAEL P. DEIGNAN
MICHAEL P. DEIGNAN
JAMES E. BROWN
DUNCAN R. HUMPHREY
CRAIG W. CARPENTER
STEPHEN J. GRAVES
STAN GANTZ, W5GZ
RODNEY V. ZEIGLER
RICHARD A. ABBOTT
REBECCA L. GRAVES
PHILIP A. RUSSELL
PERRY W. OGLETREE
HENRY S. KNOLL JR
FREDERICK C. TOTH
BRITT HAY, KB6SS
RUSSELL P. VLCEK
RUSSELL E. FURRY
ROYAL E. BERGLEE
RONNIE A. BOLTON
MICHAEL E. POMPA
LAKEY W. TOLBERT
KLOSE III, LEROY
KAREN TRULLINGER
JOHN P. DONNELLY
JAMES R. GRAVEAS
GRAF BUCKENMAIER
GERALD C SPEIDEL
DOUGLAS A. SLATE
AL NYLEN - W6NGW
MATHIAS MENRATH
JOHN COLOCOUSIS
JAMES R. GRAVES
GEORGE R. ISELY
EDWIN M. DOTTEN
DAVID L. WILSON
ARVID M. MONSON
JOHN TRULLINGER
DONALD E. OSBORNE
NUMEROUS
STEVEN SHERMAN
ROBERT A. KILE
JOSEPH M. DEES
HARRY L. HELMS
GARY W. BIVINS
DOUG MCBOURNIE
DAVID B POPKIN
BRUCE E. STOCK
JOHN A BYLIN
STAN ANTROBUS
ROBERT SOUTER
ROBERT MERCER
R. W. RUSSELL
LEE A. HODGES
KEVIN G. SHEA
JAMES R. SOHL
DERREN L. BAY
BRYAN F. WEST
ANDREW NOURSE
RICHARD RUBIN
VERNALL, BOB
JOHN D. HAYS
GARY SIGGINS
DENNIS MAJOR
DAVID MOISAN
BRUCE PERENS
ROBERT REED
PAUL STAGNO
JERRY ELLIS
JERRY ELLIS
JERRY ELLIS
JERRY ELLIS
JEFF BAUMAN
TOM HANSEN
TIM STAKER
STAN MOORE
GARY SCOTT
GIL ELDER
BRITT HAY
HEATHER MELISSA HAMPTON, KE6HEY
REGINA L. BURNS / PATRICK C. BURNS
RHINEHART J. HUTTELMAYER
CHARLES E. QUENTEL,III
RICHARD MCGUIRE BURKE
RICHARD F. HALTERMON
CHARLES M. MONTANESE
ROBERT J. CROCKETT
HERBERT A. RIDEOUT
RICHARD D. REDMAN
MARLIN D. HOSTVET
STEVEN N. KIDDER
RODNEY O. GIBSON
ROBERT ROSENWALD
ROBERT N. PARKER
PHILIP H. GAGNON
NICHOLAS D. ZORN
MERLE R. CROWLEY
DONALD J. BACKYS
ALFRED F. SIEBEL
MARTIN M. HORUAB
LISA M. HILBERT
JOSEPH J. TOWNS
WILLIAM R. SLYE
WILLIAM B. LILL
THOMAS W. AYRES
PAUL W. FRITSCH
MYRON W. MANKER
JOHN D. HENSLEY
FRANK E. BROOKS
ROBERT W. DOWNS
DEAN W. MANLEY
THOMAS L. LONG
LEO O. ROBERTS
JOSEPH BERTANI
JAMES T. KENNY
JACK D. SHULTS
EDWIN R. LAPPI
DENNIS W. BERG
CONRAD L. REIN
M. KENT MILLER
GARY F. GRANT
WALTER SCHIVO
JOHN M. MARKS
JAMES R. SOHL
J. R. CHNAPKO
MIKE DORROUGH
JOHN A. KING
EDWIN C. DOW
DENNIS HILL
JAMES COOK
ERNEST W. HOWARD, JR.
JOHN M. DAMRON, W9MD
WILLIAM A. THOMPSON
JOHN J. HUDAK
AL PARKER
RONALD W. RUSSELL
GEORGE H. SHANDS
GARLAND MEREDITH
DENNIS V. MINNER
WILLIAM J.KRAFT
STEVEN L. KARTY
NUMEROUS
MILLARD QUALLS
LARRY W PARKER
JOSEPH SPENCER
CARTER B. HART
BRUCE D. BLAIN
BRUCE D. BLAIN
FRANCIS STONE
NEAL FELDMAN
JOHN W. HUNT
BILL YELK
JOSEPH M. HUK, JR., P.E.
JOHN B. MITCHELL, K4IQ
HAROLD J. PRICE, III
ALFRED A. LAUN, III
VICTOR M. MAGANA
KRAUS II JOHN F.
COONS, DONALD D.
DONALD F. LYNCH, JR., MD
WILLIAM CHRISTIAN
HARLEY GABRIELSON
DALE D. MARSHALL
PATRICK RALSTON
OWEN G. ROBBINS
NORMAN W. CRANE
JOHN FORREST
DOUGLAS LYON
RONALD C. PHILLIPS, AH6HN
HUTCHINSON BEN H.
DENNIS W. AHEIMER
GUY A. MATZINGER
DAVID W. FREEMAN
RAYMOND J. LAINE
RICHARD F. DREW
PHILIP, J. KROTH
JAMES E. ANDERA
HARVEY S. RUBIN
TIMOTHY WALKER
JOHN H. ARTHUR
JAMES E. SCOTT
JAMES R. REID
BRUCE K SIMON
PETER HILLMAN
FREDERICK M. SPINNER W0FMS
ROBERT YOUNG
NEIL F. DUNN
FRANK SPICER
BRUCE PERENS
ALBERT A. GEMOETS
JEFFREY R. BAKER
JAMES E. FIELDEN
ALFRED J MEUNIER
VALERIE GILBERT
NUMEROUS
PETER G. SMITH
LOUIS J. PURDY
HAROLD C. TODD
MICHAEL HELM
HANS BRAKOB
JAMES COOK
CLIFFORD G SIMONSEN - AD6BS
VINCENT J. BIANCOMANO
ROSENTHAL, JAMES M.
ROSENTHAL, JAMES M.
WILLIAM W. SPURRIER
GERALD R. SKINNER
JIMMY L. HOLBROOK
JIMMY L. HOLBROOK
CONNIE I. MURPHY
WILLIAM A. CLARK
DULLY JAMES R.
JAMES LAWRENCE MCALHANEY
DIM WARMERDAM
RICHARD WILKERSON, WD6FDD
FRED A. DURAN, JR., W4NKI PAUL
AKIMOV
LANCE SMITH
JULIAN M. FROST, N3JF
ROBERT S. MCCAFFREY
RICHARD J. BERNHARD
STEVEN W. WESTFALL
PAULINE TANNEHILL
MICHAEL E. WARREN
MICHAEL UMBARGER
DAVID A. WATROUS
NUMEROUS
JAMES H. SCOTT
LYLE D. BRADT
HERBERT R. KING, JR. (K4YDE -EXTRA)
PUERTO RICO AMATEUR RADIO
LEAGUE, INC.
QUARTER CENTURY WIRELESS ASSN., INC.
WALTER W. WILKMAN JR.
RICKY RAY THARRINGTON
ROBERT E. SCHWEITZER
WILLIAM J. BUCKLEY
VINCENT R. SOSNOWSKI
CHARLES J. SCHNERING
EVAN G. SCARBOROUGH
ROBERT G. DENNISON
HENRY S. DEITCHMAN
BARTELS, MARTIN R.
SHERWOOD M. KIDDER
NORMAN E. WOODWARD
CHARLOTTE L. BERRY
DOUGLAS M. CASAMER
STEPHEN M. BUTLER
WESTON D. CLEMENT
LELAND L. FELLOWS
DONALD VAN SICKLE
ROBERT E. JOHNSON
ROBERT W. RETTIE
JOHN W. KLINGELE
JOHN M. BREWER
EMILY P. HANSCOM
CHRISTOPHER KENT
RUSSELL E. MOORE
KEITH M. GAWLIK
WOODIE THOMPSON
WILLIAM R. SLYE
THOMAS W. SMITH
TERRY G. GRINER
HANS E. RICHTER
GERALD J. SABEL
FRANCIS R. STEC
WILLIAM J. KANE
CHARLES A. EARP
WAYNE MATHERNE
DUANE ANDERSON
TIMMY S. NAAMI
STEPHEN M. AUG
JOHN J. ELENGO
MAX E. NORMAN
PABLO A. HAHN
PATRICIA A. INABNIT KF6GAX
MARK PERSONS
ROBERT ADAMS
JOHN HARTMAN
KEVIN MANKE
TIMOTHY J. METRO
M. J. INABNIT KE6SLS
JOSEPH T. MOTAK SR.
THOMAS J. WRENSCH
MULLER, THOMAS G.
KENNETH M. BOURNE
ROBERT W. RETTIE
RAYMOND J. LAINE
JOSE L. MAISONET
JOHN A. STANDORF
MICHAEL D. RHEW
JOSEPH E SALOKA
JAMES M. CORDES
J. MARK VENABLE
NUMEROUS
NUMEROUS
NUMEROUS
NUMEROUS
DAVID A. YOUNG
DAVID A. YOUNG
SCOTT BULLOCK
DAVID M. BURK
B.PETER TREML
ROBERT KONIS
RICHARD CADY
GLINN LANIER
MIKE MORROW
CHRISTOPHER C. CAMPBELL
COLLIER, KENNETH J.
HARVEY L. PANKRETZ
BRADLEY A. FARRELL
THOMAS J. O'CONNOR
WILLIAM S. BERGER
FRANK S. HAGERMAN
MR. ROBERT P. BRODERICK JR.
THOMAS R. WALTER
JULIUS C. MORRIS
DAVID I. STRAHAN
PETER J. STADNYK
MARY LEE MORRIS
JOHN E. LEONARD
PAUL J. KIESEL
JOHN W. SAYLOR
CAROL L. MAHER
MARK ERBAUGH
JOHN R. KANE
PAUL TAYLOR
JAMES SMITH
GENE ADAIR
JAMES W. TITTSLER
RICHARD W. DZICK
MICHAEL BIELECKI
PAUL A. CLOSIUS
MARTIN F SCHICK
NUMEROUS
PETER ECONOMOS
GALEN STUTZMAN
SUSAN A MOTAK
RAY S. RISING
TOM MOSHER
NORTHERN CALIFORNIA PACKET ASSN.
QCWA MARCONI CHAPTER 138 VINCENT
A. CARLINI
VINCENT A. CARLINI
EUGENE E. ANDERSON
HARDY K. LANDSKOV
RICHARD J. O'HARA
RICHARD MONJURE
TODD J. LITTLE
ROGER W KURTTI
ROGER W KURTTI
JUDD O. SHEETS
STEVE HELLER
TOM S. JONES
WILLIAM DEMATTIES
TIMOTHY V. HARPER
NAME OF APPLICANT
BURT ROOKE, N7OW
NATHAN BARGMANN
RANDALL ZABEL
JIM MONAHAN
MICHAEL G. MICHAELEDES
MITCHELL B. GEMBALA
JAMES M. LUCAS JR.
RICHARD WURTZINGER
RICHARD E. REEVES
LAWRENCE J. ROLL
JOHN W. BURDETTE
DREXEL C. HEATER
EVANS ERNEST R.
JAMES G. COKER & PAULA H.COKER
GERALD T. WHITE
LOPEZ, ROBERT
PAUL MUHLEMANN, JR. KC5CTG
TIMOTHY J. METRO
DAVID B. LARUS, KQ6NS
STEPHEN H. PIERCE
MATTHEW T. RUPERT
GROVER YARBROUGH
GEORGE J. WHALEN
LOUIS H. ALBERT
JAMES W. THOMAS
NUMEROUS
THOMAS LIEBOLD
ROBERT TRIPI
AMERICAN RADIO RELAY LEAGUE
CHUCK PARE' RANDANT
RICHARD MONTGOMERY
ROBERT L. SHRADER
LINDSEY R. BLOCK
THOMAS B. KNIGHT
RICHARD N. BETZ
MICHAEL E. LOWE
MICHAEL E. LOWE
WILLIAM A. BURNS
LARRY L. ALMAN
JOHN R. SPROAT
ALVIN H. SMITH
A. W. WESTMONT
ALAN H. SMITH
TOM GRAMLICK
WAYNE GREEN
LOU POKROCOS N2QNX
CHUCK BROADWELL
KEITH J. HAYDEN
RONALD G DURIE
ALBERT REID
ROCHESTER AMATEUR RADIO
ASSOCIATION, INC.
DENNIS G. EKSTEN, W9SS
PATRICIA A. LUNDBURG
ROBERT ALFRED MOORE
MIROSLAV S. SKORIC
MCGLENSEY MARTIN J
ARMENDARIZ, TONY M
REGINOLD MITCHERDO
ROBERT B. EDWARDS
THOMAS R. SCOTT
RONALD S. FRICK
ALVIN A. GUIDRY
JOSEPH A. MAURI
ADOLPH MOGAVERO
WAYNE MATHERNE
LESTER V. LANZ
JOHNSON PARKER
DAVID C. SWANN
DONALD W. LONG
BRIAN ANDERSON
SAM P. JEWELL
JERRY SHADRICK KB0OXT
PATRICK EUGENE HAMEL
JEFFREY LYNN ARNOLD
LOU RASO
THOMAS J. O'CONNOR
GARY P. STANDORF
DAVID F. MANGELS
DENNIS D POWERS
TONY A. JORDAN
R. D. PINNER
JEFF KANE
FRANS JANSON
ROLAND EVERETT LANGFORD
FRANK S. ALVERNAS
MICHAEL L. WILLIAMS
WOODIE D. THOMPSON
BRADFORD G. MARBLE
FRANK A. ELDREDGE
WILLIAM P. LEAHY
DENNIS HENDERSON
VIRGIL L. GOCHEE
RODGER P. MUNDY
DUANE R. DANN
CHRIS EDWARDS
W.C. GOODALL
T.L. COKER
GARY CASTO
PATRICK FASANELLO
L. WILLIAM SOMRAK
ANONYMOUS
PAUL MICHAELSON
MICHAEL MASSIMI
NUMEROUS
JAY A. RANNEY
JAMES FISHER
RAY OVERMAN
JOHN KEENAN
WINSTON COUNTY AMATEUR RADIO CLUB
BRADFORD C. ASHLEY MD
EATON A. GORELANGTON
SOUTHWEST IOWA AMATEUR RADIO
ASSOCIATION
LLEWELLYN-D-MERRILL
KENNETH V. HUDELSON
VIN L. WILSON ET AL.
HAROLD E. NAYLOR
MIROSLAV SKORIC
JAMES ARCARO
STEWART E. PEARSON
LARRY M. PFISTER
JOHN CERZA
STUART B. SANDERS
CHARLES R EDMONSON JR. KA1MIA
ROBERT A. ALLSHOUSE, SR.
MARK T. VANDEWETTERING BONNIE J.
FEVERGEON
JOSEPH L. LOCASTRO
STUART A ROWLAND
TIM BILLINGSLEY
KEVIN BARTLES
TIM JOHNSTON
REIN NEEM
KINGS POINT AMATEUR RADIO CLUB
FREDERICK W. BONAVITA
PHILIP A. COVINGTON
WILLIAM F. HARRELL
G. W. BLANKENSHIP
MICHAEL E. FUSCO
KENICHI YAMAMOTO
FRED BREIDBART
DANIEL A HILL
GEORGE SMITH
MIKE SELWYN
TERRY N. HERBSTER
TERRY C. HALLADEY
DAVID W.ARRINGTON
GREGG A. SWENSON
JAMES W. HOLT
ROBERT F. HUTCHINSON
MICHAEL T. CLAIRMONT
STEPHEN J. MAROULIS
THOMAS M. LIEBERT
HENRY R. LEGGETTE
VINCENT E. KREUTZ
RICHARD J. KELLEY
MICHAEL R. BORER
DANIEL M. LYNCH
WILLIAM H. SOHL
STEPHEN W. POPE
DAVID R. TUCKER
LEARD F. VAUGHN
CRAIG S. KIDDER
THOMAS P. KING
DAN M. WINBORG
STEVE LETENDRE
WILLIE E. DIX
GARY MITCHELL
JOHN G. RILEY
RICHARD L. TANNEHILL, P.E.
NORM BEAVERS
ROBERT MOORE
JOHN R. KEMP
MICHAEL A. THOMAS KE4LAU
HORACE E. CRANE, JR.
EDWARD E MITCHELL
DANIEL A. BRASHER
WILLIAM M. WILKS
MR. VAL E. ROSE
MARK B. DITTMAR
LLOYE J. SHEARS
LARRY D. SUMNER
ROBERT B. BOSE
RON RUGG
HERMAN A. FABERT, JR.
NICKOLAUS E. LEGGETT
STEPHEN H. LARRABEE
PATRICK W. TICE
COURAGE HANDI-HAM SYSTEM
LAURENCE F. STAHL
RICHARD E. DIXON
JOHN S. HOWLAND
ARTHUR A. ELLIS
J. W. DREHER
JEFF L SHEPARD
ROBT BURNS
MARK MOTIS
CHARLES E. THOMPSON
KEN MYERS
DANIEL L. THOMPSON
LARRY R. FRAVEL
CHRIS MAUKONEN
WILLIAM MAIN
NATIONAL CONFERENCE OF VECS
WILLIAM M. GOSSET
WERNER H. SCHMIDT
GEORGE A. TRANOS
DUANE L. SEIBOLD
J. KENT WASSUNG
RALPH B. AIKEN
LEE SECHLER
WILLIAM KRAELING
THOMAS W. PONDER
JOHN G. MCCARTHY
M. PAT CRAWFORD
JOHN COOKSON
JOSEPH A. STAPLES
DANIEL L. ROUNDA
DAVID W. BOWKER
HAROLD E. SMITH
MICHAEL D. FIELDER
ROBERT E. NELSON
NUMEROUS
WILLIAM J. SARTORIUS
GLENN M. PAXTON
HENRY POKORNY
BETHANN MONOLOPOUS
STEVEN J. MEYERS
JOHN R. CARLTON
DONNA MOTAK
GARY R. OAKES, M.D., FAAFP WD4ICI
RICHARD A. URUCHORTU
LOUISE ROBERT PASTOR
GEORGE R. RICHARDSON
DAVID R. BOLENBAUGH
DANIEL J. KITCHENER
WILLIAM H. COTTRILL
BRANDON S SHOEMAKE
WILLIAM USTASZESKI
DENNIS LEE BIEBER
WILBUR L. NEWCOMB
GARY L. CAMPBELL
GEORGE F. GRADY
DONALD S. SEITZ
KARL H. PAQUEE
JOSEPH GLASS
RALPH P. MILLER W3FXE
WILLIAM H. SIMMONS
ROBERT K. STEPHENS
CHUCK EDMONSON JR.
PAUL MONOLOPOLUS
DAVID A. CORNELL
NUMEROUS
JOHN F. MELKA
BURT L. JONES
TUCK MILLER
JAMES MOTAK
CLAY REDDEN
JIM LISTON
D HOKANSON
PUBLIC SAFETY & PRIVATE WIRELESS
DIVISION
TERRY, D'WANA R.
EDWARD P. HUTCHINSON
DAVIS, FREDERICK W.
DANNY L. RICHMOND
WILLIAM S. LANZER
DANNY L. RICHMOND
DANNY L. RICHMOND
DANNY L. RICHMOND
DANNY L. RICHMOND
DANNY L. RICHMOND
JAMES T. KINSEY
DOUGLAS R. BARD WA2JRQ
FRANK HIDI
RICHARD F. MULVIHILL
HARVEY L. ZION JR.
NUMEROUS
RICHARD RUBIN
JACK H. EDDY
WILLIAM E. HOLMES
RICHARD M. PRESTON
THOMAS A. DICHIARA, JR.
LEO PETERS
JOHN CHARLES SWIFT
RONALD D. MURDOCK
NUMEROUS
D. SCOTT EABY
KIM CANNON
CHARLES M. ALLESSI W6IEG
WALTER F. WERNSING
WILLIE L. GRIMSLEY
CLIFFORD B. BRAGG
MARTIN D. WADE
MICHAEL L. MARTIN KE6EIC
J R KENNEDY
JOSEPH W. FAHRENHOLTZ
RONALD M. LAPEDIS
ROBERT A. RAYMOND
KEVIN W. HERRON
MASTER PUBLISHING, INC.
ROBERT T. WENTWORTH
CHARLES GLAISYER
SCOTT R. BULLOCK LARRY L. HALL
N7FLG
SEAN M. WARNER
JOHN C. BEAKLEY
JOHN J BELL
LEIGH M. SHEARS W6DWC
ROBERT A. MATTEUCCI
STEVEN WESLEY LANE
DELMAR J CRICKMORE
ROBERT V HINESLEY
JONATHAN KAUFMAN
FRANCIS O. MEEKS
BRYAN W. NEVILLE
LEMOYNE J SIZEK
JAY K. JEFFRIES
W.J. HANSON
MICHAEL J. BOROWIEC
PATRICIA M. LOVARCO
EDWARD J. PLESNAR
DANIEL R. SWANNER
PATRICK SPENCER
WILLIAM G. WATT
DAVID A. GUNTER
NEIL H. ADAMS
FRANK O. LONG
RONALD TAGG
RAY, HAMOVITZ
ROY DAVIDSON
JAMES TOBOLA
CLAUDE C. HELD II, WA9KCU
GREGORY F MCGINNIS KC6UIX
ALEX HAYNES
ROBERT P. DEVEGA, JR.
ROBERT W. MORROW JR.
BRUCE MCPHERSON
MOSHE C. SATT
LUCAS J KUNTZ
MASON LANDAU
GEORGE H. MARTENS
STEVEN J. BARNEY
DAVID JOHN HARDT
EDSEL RAGLE
JOHN G. MERRILL, JR.
NUMEROUS
MURRAY H. MERNER
HAROLD THOMPSON
CHARLES KITCHIN
ROBERT S. ROSS
HARRY SNYDER
TROY C. CREED, KA8BMM
THOMAS CHARLES GIESEL
RONALD F. HENRY
NUMEROUS
SCOTT BULLOCK
ROY E. LEWIS JR. ( KE4SLL )
ROY E. LEWIS JR. ( KE4SLL )
ROY E. LEWIS JR. ( KE4SLL )
CRAIG R. TRACTENBERG
MICHAEL SHERWOOD
JON E. VALENTINE
WALTER E. MINTO
DAVID H. BELL
V. L. WILSON
JOSEPH J GREBE
MARSHALL L. WATTEL
ROBERT RICHARDSON
MICHAEL DURKET
MARK T. CENAC
JOSHUA TEMPLIN KB9ENE
STEVEN J SCHNEIDER
ELDRIDGE G. WILLEY
RICHARD MUTH
SUN CITY CENTER AMATEUR RADIO
CLUB
JAMES N. QUISENBERRY
ROGER ELDON HAMMOND
WILLIAM H. SKINNER
GAYLORD D. ALLISON
FREDERICK WALTERS
JIMMY D. NICHOLS
STEVE M. STEWART
JERROLD W. LIPPS
KELLY, JAMES L.
JAMES F. RANNEY
K. ALAN ROBBINS
LARRY E. WHITE
GAIL D. GRINER
JOE OVERSTREET
JOE OVERSTREET
DONALD LAMPKIN
WILLIAM ASPIN
FRANK L. GLASS
ROBERT PEURA
GENE GENTINO
J.T. BURIK
ARTHUR HARRIS, N2AH
THOMAS W. CAPELLO
RICHARD RYBCZYNSKI
MICHAEL J. CALDARE
NORMAN L. BERGER
EDWIN L. CLINGER
DANIEL J. BENDER
RONNY G. MERKEL
TROY C. CREED
RANDY GARRETT
DAVID C NAATZ
BARRY ISSEKS
JERROLD W. LIPPS
JERROLD W. LIPPS
BRAD WILCOX
THOMAS P. JOHNSON
HAROLD A. WALLS
RICHARD MERHAR
BYRON V. CALOZ
DAVID GREGORY BRINK
RALPH CARSON
JACK MALONE
BILL H. FRY
JOSE VELEZ
FREDERICK E. PATTON
CHARLES B. KITCHIN
JOSEPH T. MOTAK
JON CAERY
KEVIN L. POORMAN
J.A. AMICARELLA
MARTIN A. MERWIN
PAUL L. COFER
GEORGE BOARD
PAUL KRUZEL
DAVID G. FINLEY, N1IRZ
ROBBIE D. ROBINETTE
J. GERARD ROBIDOUX
NICHOLAS W. SAYER
HENRY CHAMBERLAIN
PETER L. OSTAPCHUK
CHARLES J. DEVETT
JAMES G. FERRELL
RANDALL E. MCKAY
WALTER L. EWALD
MICHAEL CLARKE
DOUGLAS CHANCO
JON W. BANNING
JERRY LANDRY
EDWARD J. COLLINS / KB2ZYU
MARK LAWRENCE, MAXFIELD
JOHN COSTANTINO ROCCA
ROBERT HAROLD GARFAT
GEORGE W. BROWN JR.
ROBERT S. TWIGGS
M PAUL PATTERSON
RANDALL R. WING
NUMEROUS
RAYMOND W STOMMEL
WILBUR O. STONE
WALTON R. HOOD
KENNETH W SKINNER / KC5VUS
CHARLES W. LEVINE
NORMAN SEIFERT
CHARLES OLIVER
WILLIAM KROPA
CRAIG MILLER
CRAIG MILLER
MARY SZUMERA
DENNIS E. SPIESS W2DEN
TIMOTHY J. SLATTERY
JAMES A. GOODRICH
SCOTT WILKERSON
JONES, RICK D.
WARREN T. REESE
RAY L. DRISKELL
FERNANANDO ARIES
ROSS C. GOODALL
ROSS C. GOODALL
JOHN R. ROBERTS
DON DEJARNETTE
RICHARD G. GUTKNECHT, NZ2I
LOU MEYER
THOMAS G. RAMPTON
ROBERT G. WILL
ALAN L HANN
JOSEPH J. CWIKLINSKI
MICHAEL C. CHILDERS
MICHAEL C. CHILDERS
RONALD E. WILLIAMS
JOHN W. MCCUTCHEON
WILLIAM H. JOLLY
HARLAN H. BENOY
JOHN B. BREWER
VINCE RODERICK
LAIRD WILCOX
JOE GAMBINO
ED MURPHY
WILLIAM L. UPHAM JR.
NUMEROUS
BOB RETT
GLENN E. NEWCOME
RONALD D. BOUVIER & JACQUELINE B.
BOUVIER
FRANKLIN STOGSILL
MICHAEL LOUIS MCCAULEY
MICHAEL LOUIS MCCAULEY
ELLSWORTH O. JOHNSON
CHARLES E. BLANCHARD
CHARLES E. BLANCHARD
TIMOTHY J. SLATTERY
SAMUEL H. BEVERAGE
IRWIN S. GOLDSTEIN
DELWYN W. M. CHING
SAMUEL H. BEVERAGE
RONALD D. BOUVIER
FRANKLIN STOGSILL
ARTHUR B. EKBLAD
TOMMY F. MCCRAW
LARRY L. DIDIER
TOMMY F. MCCRAW
STEPHEN WELLS
ROB CAVANAUGH
PAUL M. SOBON
TIMOTHY J, SLATTERY
VERNON H. FIX
JOSEPH MACK
DAVID JONES
NCV
JIM PHILIP
ED GRIFFIN
JIM PHILLIPS KB6OKH
ELLSWORTH O. JOHNSON
BRIAN WESTPHAL
IRWIN S. GOLDSTEIN
DELWYN W.M. CHING
ROB CAVANAUGH
PAUL M. SOBON
JOSEPH MACK
ED GRIFFITH
DAVID JONES
PHILIP P. BERRUTI
BRADLEY J. KNAPP
ROBERT W. TAUXE
JACK A. HOLZER
JACK A. HOLZER
JIM PHILLIPS
JIM PHILLIPS
PHILIP R. BERRUTI
BRADLEY J KNAPP
DAVID VAN DER WEELE,
CHARLES J. SCHNERING
MICHAEL J. METZDORF
DAVID VAN DER WEELE
PETER N. ZIEGLER
MICHELLE COMPTON
BARBARA J. RIGEL
DENNIS L. BARTOU
NATIONAL CONFERENCE OF VE
SERENA M. RIGEL
DENNIS R. BARTOU
JAMES N. RIGEL
DAVID N. RIGEL
CHRIS MAUKONEN
RAYMOND MACH
NATIONAL CONFERENCE OF VEC
PEARL MACH
DAN WALKER
MICHAEL J. METZDORF
MICHELLE COMPTON
BARBARA J. RIGEL
SERENA M. RIGEL
JAMES N. RIGEL
DAVID N. RIGEL
CHRIS MAUKONEN
RAYMOND MACH
PEARL MACH
DONALD K. VANZUILEN
JACKIE M. ALBRIGHT
GEVES S. KENNY ET AL.
HERBERT W. HATTON
ROBERT MCCRACKEN
ROBERT MCCRACKEN
PAUL T. ATKINS
JOHN A. PROLOS
DAVID E. LILLY
PATRICK SMITH
DAVE WRIGHT
IAN CARISI
DONALD K. VANZUILEN
NUMEROUS
JOHN A. PROIOS
PATRICK SMITH
DAVE WRIGHT
CHRISTOPHER G. MERRING
RICHARD G. GUTKNECHT
MARGARET A. GOODMAN
MICHAEL W. GOODMAN
DANIEL QUINTILIANI
HILARY F. JOHNSON
ALBERT H. REDLES
JOSEPH W. BLANK
D. WORTH CARSON
THOMAS L. FLOYD
D WORTH CARSON
TOMMY GOODMAN
ALBERT REDLES
TOM CABANSKI
JAMES LUMLEY
JAMES LUMLEY
TOM CABANSKI
TOM CABANSKI
RICHARD G. GUTKNECHT, NZ2I
ED GRIFFITH
CHRISTOPHER G. MERRING
MARGARET A. GOODMAN
MICHAEL W. GOODMAN
DANIEL QUINTILIANI
HILARY F. JOHNSON
NUMEROUS
JOSEPH W BLANK
TOMMY GOODMAN
TERRY H. SMITH N5SMZ
DENNIS A. ARRICHIELLO
LUTHER W. LIPFIRD
LUTHER W. LIPFIRD
JAMES G. ROBERTS
ROSS C. GOODALL
MICHAEL D. IHRY
HOWARD JACOBSON
HARRY F. WETZEL
DUANE C. BALLOU
DUANE C. BALLOU
HARRY F. WETZEL
BRIAN A. ROBERTS
TERRY H. SMITH
JAMES O. BAKER
JAMES C. OBERG
DWIGHT STEWART
JAMES C. OBERG
BURTON E. EATON
STEVE MCNUTT
RANDALL ADAMS
GEORGE RAUSCH
DWIGHT STEWART
STEVE MCNUTT
OSCAR ALONSO
OSCAR ALONSO
DAN WALKER
BOB BECKER
BOB BECKER
GARY TRIPP
JAMES O. BAKER JR.
NUMEROUS
NUMEROUS
MICHAEL D. IHRY
HOWARD JACOBSON
CHRISTINE A. FATHAUER KC5SXC
LEWIS W. SPRINGER N5OUW
ERIC B. A. KIHL W1CPQ
MARK E. LIGNOUL KG5BD
JAMES R. SMITH (N5JXC)
CHRISTINE A. FATHAUER
LEWIS W. SPRINGER
RICHARD C. EMERY
JAMES H. OSBORNE
MARK E. LIGNOUL
DONALD F. NEARY
BOBBIE J. BROWN
ANDRE H. MARTEL
JAMES R. SMITH
JACKIE P. SOHL
ERIC B.A. KIHL
RALPH CELONE
BRIAN MANNON
DONALD KELLY
BRIAN MANNON - KC8JXH
DOUG MAY
NUMEROUS
RALPH CELONE
DOUG MAY
PAUL J. ANTONIEWICZ
PAUL J. ANTONIEWICZ
ROBERT H. MCCOOL
THOMAS F. LEWIS
RALPH P. SCHORN
JAMES A. LOGAN
MICHAEL GRATE
MICHAEL GRATE
TERENCE RYBAK
MICHAEL GRATE
TERENCE RYBAK
GILBERT, DAVIS
TED D. NELKE
RIKU KALINEN
STEPHEN HILL
RONALD TAGG
RONALD TAGG
JOE SPINOSA
JUDY TAGG
JUDY TAGG
RIKU KALINEN, K2LWO
JOE SPINOSA - W6JOE
ROBERT H. MCCOOL
THOMAS F. LEWIS
TED D. NELKE
ISBELL, JAMES A. (WA5HLE FORMERLY
WA6LGT)
CHRISTOPHER D. RUMBAUGH
FRANCIS M. SAUCIUNAS
MARLBORO YOUTH REPEATER
BARRY D. CHALCROFT
VINCENT T. CHERRY
CHRISTOPHER DONALD RUMBAUGH KD6FIB
STACY W. HAGERTY
JOANNE M. PYLANT
STANLEY E. SIMS
ROYAL M. TYSDAL
RALPH P. SCHORN
JAMES A. ISBELL
STACY W HAGERTY
RUSSELL FALLON
STEPHEN HILL
RICHARD HYDE
JACK H. SIMS
DON BROSSEAU
JOEL WISOTSKY
ROB DEVLIN
FRANCIS M. SAUCIUNAS
BARRY D. CHALCROFT
NUMEROUS
RUSSELL FALLON
RICHARD HYDE
JACK H. SIMS
DON BROSSEAU
FREDERICK A. PYLANT
THOMAS OLIN YEAGER
RONALD G. PENKALA
LESTER F. ELLIOTT
GREGORY L. HANSON
LAWRENCE L. RHODES
THEODORE K. TOUW
HAROLD G. GOODER
EDWARD E. BEATTY
DREW W. TRAVERS
JOE P. KENMORE
JAMES H. BROWN
JAMES K. LEWIS
RALPH MILNES
RALPH EBENER
JOHN BARBERA
DALE R. REED
PAUL HARRIS
JOHN G. BECK
DON VEAZEY
DON MCDADE
JOHN KEEL
JOHN BELL
UTC, THE TELECOMMUNICATION
STEPHEN G. BAKER
LELAND W. AURICK
HOWARD L. BITSKO
EARL C. MORRISON
RUTH L. SIMPSON
RICHARD SLEMONS
MICHAEL SERAFIN
LARRY E. COHEN
JOHN G. SALLEY
JAMES J. BILKE
BRUCE W. MOYER
ARTHUR ROGERS
JIM PHILLIPS
JIM PHILLIPS
MAX D. CODY
ARRL
CHRISTOPHER J. HEIBERG
MICHAEL C. MCCARTY
WILLIAM B. PALMER
LEROY M. JENNINGS
ROSS C. GOODALL
HENRY A. TREFTZ
FRANK SALLADAY
W.G. SIMPSON
ROBERT J. CROUTHAMEL
KEVIN PATRICK GIBSON
ROBERT J. CROUTHAMEL
LESTER F. ELLIOTT
LESTER F. ELLIOTT
JAMES G. WILCOX
MARTY TRESSELL
JOHN K. WILSON
CLIFFORD IKEDA
JOHN KIRCKOF
BRIAN DEGNAN
JOHN KIRCKOF
ROBERT NEFF
JULIO BRITO
LARRY HORN
RICH KELLY
LARRY HORN
RICH KELLY
RICH KELLY
RALPH J. ESCHBORN
JAMES EWING HICKS
RONALD J. FINGER
CHARLES P. WHIPP
JEFF D. MORRISON
JEFF D. MORRISON
LINDA L. TOWNE
RANDY KROFICK
PAUL S. TOWNE
RICK FOSTER
JAMES HEID
NUMEROUS
VINCENT R. SOSNOWSKI
LLOYD M. MITCHELL
JOSE A. CABALLERO
RAYMOND T. TUERO
DAVID W. LANGLEY
JAMES R. MARTIN
JAMES R. MARTIN
DARWIN R. BRUCE
KENNETH WERNER
JOSEPH YAKOSKI
MIKE PHILLIPPE
JIM LUMLEY
JIM LUMLEY
NUMEROUS
ALBERT R. GIANDOMENICO
WILLIAM K. HARGREAVES
CHESTER ARTHUR THAYER
VALENTINE CHRISTIAN
TIMOTHY L. WILLIAMS
CALVIN R. KUTEMEIER
ROBERT K. MULLEINS
JACK G. HOLLENBECK
BEVERLY A. CARLSON
JACK G. HOLLENBECK
ROBERT L. WIESTER
LARRY A. CHAMPION
BRUCE E. RICHARDS
TERRY A. JOHNSON
LEONARD J. UMINA
GEORGE H. MORTON
DAVID C. JOHNSON
JO D. COCKMON, JR.
VOLNEY V. BROWN
RUSSELL SHIVELY
GARY MCCONVILLE
VALENS PLUMMER
LAWRENCE BRUCE
CHRIS GAUTHIER
GARY MCCONVILLE
JOSEPH BRANDT
JO D. COCKMON
JEFF GALINAT
JAMES SUMNER
RICK RACKOW
DON MIRADE
ALEX CLARK
NANCY FORD
NUMEROUS
NUMEROUS
MICHAEL E. MILLER
KENNETH W. SCHULZ
THOMAS P. WALLACE
KENNETH W. SCHULZ
WALLY G. WESTOBY
ROBERT E. DILLON
JACK L. PEARSON
ROGER L. GUTKA
NUMEROUS
CHARLES E. ATCHLEY
RAYMOND H. KNUTH
KENNETH P. ECKEL
ARTHUR P. HARRIS
VAN ROBERT HEATH
VAN ROBERT HEATH
DALE PENDLETON
ADAM M. FARSON
MICHAEL B. ASHENFELTER CHARLES
A. SHOEMAKER MICHAEL J. DINELLI
LINCOLN E. ENGWALL
CLARENCE J. ZICKUHR
ROBERT R. BEATTIE
MICHAEL S. RUNDLE
MARTIN P. BURDINE
EDWARD A. SCHOBER
DANIEL L. DONOVAN
BLAKE ASHENFELTER
STEPHANIE STEELE
RALPH E. HERZLER
LOUIS J. SALERNO
JOHN J. ROESSLER
RAYMOND J. LANE
NORMA L. STEELE
MICHAEL E. URSO
DANIEL H. SEALY
MAKING WAVES (WD6 EJN)
DAVID H. HYATT
JOHN L. NIMMO
JOHN J. DUNN
BRYCE A. CARR
HARVEY GOOD
JO SANFORD
STEVE HAY
CLIFFORD R. THACKER
STEVEN DRU TWEEDIE
RUSSELL M. LOCKETT
ROBERT E. WILLIAMS
MICHAEL C. SALAPKA
MARIE V.H. LOCKETT
DENNIS L. BRUNNING
DANIEL O. GARRISON
JERRY W. P. WILSON
ROBERT J. ROEHRIG
DANIEL R. ROBERTS
JEROME GROKOWSKY
CLYDE A. BULLARD
CARL R. SWANSON
THOMAS RANDALL
JACK S. GRAFF
DARWIN OGDEN
R.C. KELLY
JOHN FITCH
NUMEROUS
FREDERICK V. ADSIT
AARON H. SCHECTMAN
WILLIAM N. REUTER
TODD M. LIVERMORE
OTHONIEL GONZALEZ
KENT G. ANDERSON
KENNETH J. MEYER
JOHN W. BUNKER
TOM BITZER
NUMEROUS
SANTIAGO GUERRICABEITIA
RAYMOND ALBERT DAVIS
FRANK L. CHRISTOPHER
WILLIAM P. CHAMPLIN
CHARLES M. FRANCER
MICHAEL C. MCCARTY
MICHAEL C. MCCARTY
MICHAEL C. MCCARTY
MICHAEL C. MCCARTY
SHEILA R. SHELTON
RICHARD E. BOKERN
KENNETH W. CEXTON
DAVID W. SPEARING
WILLIAM STERLING
GARRY H. RITCHIE
JOHN J. KEATING
KEATON SHELTON
RAY SCHLESIER
RICHARD MOLLE
JAMES D. COLT
DENNIS DOONAN
MICHAEL MAUN
JAMES D. COLT
J.T. MELTON
W.J. COWEN
GLENN SHAW
DON WRIGHT
ALEX FUNKE
SANG LEE
GEORGE A. MORANIAN
CHARLES M. FRANCER
GREGORY PIETRUCHA
TIMOTHY L. ROACH
NORMAN W. CRAMER
CLIFTON W. GANTT
GEORGE BAUSTERT
DONALD R. CLAIR
JOHN V. EVANS
JACK A. JONES
BRYCE A. CARR
ERIK SKYTEN
NUMEROUS
MICHAEL L. HILLYARD
HANS J. HEIMBURGER
G. DONALD TOMILSON
DANIEL J. GINGRAS
SEAN H. GINGRAS
LAWRENCE POSEY
GABRIEL T. LAU
PAUL J. HINTZ
DIANE M. DORE
ALAN R. BUGOS
RICHARD WARD
NUMEROUS
JESSE M. GIAMMARINO
CHRISTOPHER SALINAS
STEPHEN A. JENKINS
ROGER R. SCHROEDER
STEVEN S. ZINGMAN
BRIAN LEE ROBERTS
ROGER R. SCHROEDER
WILLIAM T. SMITH
WILLIAM T. SHORT
WESLEY D. HARPER
JONATHAN C. DAHM
CRAIG B. JOHNSON
RICHARD LEFFLER
JOHN BURGMASTER
GREGORY E. LYON
KEN HUTCHINSON
JOSEPH C. FUHR
DENNIS E. BAHR
DAVID W. MCKIM
LLOYD COLSTON
CLAYTON SMITH
CHRIS SALINAS
KEVIN PROCTOR
GORDON VICTOR
RICHARD WARD
RICHARD COTA
HOYT HUGG
GARY HOSS
C.H. MAY
NEEDHAM R. WILLIAMSON
LEONARD J. TIMBERMAN
GUNNAR C. CARLSON
TERRY W. TANNER
FREDDIE FERRELL
TIM MOORE
RICHARD R. PLOURDE
TIMOTHY L. ROACH
JOHN J. ELENGO
CARL L. MORGAN
PAUL R. KNAPP
PERRY GWINN
LON STUART
NUMEROUS
WILLIAM M. KLYKYLO
MARGIE A. TETMEYER
EDWARD H. TETMEYER
TROY D. HIGHTOWER
BENNETT Z. KOBB
VINCENT FISCUS
JOHN W. MARTIN
JIM LEININGER
DALE DUQUETTE
NUMEROUS
CYNTHIA C. LOWERY
PATRICK STICKLER
RICARDO E. PAGAN
CARL D. CECIL
BENNIE E. BOX
GREG FIELDS
GINGER BOX
MARGART P. MULLALY-QUIJAS
MICHAEL A. COVINGTON
RICHARD S. CARROLL
CHARLES R. SCHULTZ
THOMAS R. SWISHER
THOMAS H. GEWECKE
RONALD G. PARSONS
EUGENE N. JENKINS
JOANNE M. PYLANT
DAVID M. CARNEY
CARL J. QUIJAS
CARL J. DENBOW
GERALD W. BOYD
PHILIP CORLIS
JOHN V. EVANS
JOE D. JORDAN
BILL C. CLARK
DAVID E. KALB
KAREN AVEY
GUY AVEY
NUMEROUS
AARC C/O OLIVER D. GRAMLI
NORMAN T. FRIEDRICH
FREDERICK A. PYLANT
GERALD R. WHEELER
WILLIAM D. PRICE
JAMES E. BROMLEY
GLENN E. LOWERY
TERRENCE NORMAN
OLIVER S. TWIST
NURSES UNLIMITED
RICKY SCOTT
BRETT MILLS
ALEXANDER HOWARD HAYNES
STEPHEN J. SCHRACK
STEPHEN A. SMITH
ANTHONY J. BRENT
ROY W. ANDERSON
ALAN J. WORMSER
CECIL A. MOORE
ALAN J. WORMSER
GARY P. SMITH
RODNEY PENLEY
RONNIE SEESE
RODNEY PENLEY
RICK ABBOTT
CHRIS SEESE
ADAM ADKINS
RON SEESE
NUMEROUS
DONALD W. RASMUSSEN
KENNETH E. MILLER
SHON R. EDWARDS
ROBERT A. WITTE
ROBERT A. WITTE
JOSHUA R. KELLY
ROBERT VARONE
NUMEROUS
ROLAND EVERETT LANGFORD
RICHARD F. HALTERMON
WILLIS L. GRAVNING
ROBERT M. GARFIELD
ROBERT E. BIEKERT
JAMES O. PILOTTE
ANTHONY J. BRENT
JUDITH L. MOORE
PHYLLIS J. KLAUS
JAMES D. HYATT
JONATHAN TILL
JOHN R. MOORE
JOHN H. SIKES
ANN M. SANTOS
WILLIAM BORUP
WILLIAM BORUP
JIM LEININGER
BRIAN NORRIS
HARVEY ZION
M.R. WALLS
GLENN SHAW
JEAN-PHILIPPE LESTRALE
WILLIS C. STRICKLAND
MICHAEL P. OLBRISCH
BELA W. LINDENFELD
LOWELL D. FRAZIER
LLOYD M. SCHWARTZ
JEFF K. STEINKAMP
CHARLES E. SCHENK
ALLAN M. SNIFFEN
RICHARD H. WEIL
KEVIN G. MANZER
JERRY H. BENSON
JAMES E. DALLAS
HOWARD P. GOULD
HOWARD P. GOULD
FRANK E. ROESCH
DUANE M. BROPHY
BRUCE A. WILKIE
MARTIN FEIGERT
KARL F. LARSEN
JOHN R. ABBOTT
JAMES M. MINOR
ETHAN C. BANKS
ERIC A. ESTILL
DOUGLAS WALKER
DAVID A. YOUNG
CHRIS COLLIVER
BARRY ANDERSON
PAUL KANIKULA
MARTIN EHMANN
JOSEPH MILLER
CHARLES NEHER
JAMES SUMNER
MARK NOWELL
JOHN HAUGEN
JAY BENNETT
SAM REAVES
JOHN GOZUM
BILL SMITH
NUMEROUS
NUMEROUS
RICHARD GARRISON NEILL
EDWARD J. TENHULZEN
DONALD R. DICKERSON
JOSEPH D. CARVALHO
DAVID LEE TOWNSEND
WAYNE G. WILLIAMS
GEORGE J. MCCOUCH
GEORGE J. MCCOUCH
JAMES R. PARSONS
EDWARD A. GOLDEN
WAYNE P. STAATS
MARCOS A. MANON
JONATHAN NALLEY
ERIC SONNENWALD
CLAYTON BURNHAM
DAVID A. COLES
ROBERT SHRADER
LEO J. ROSNECK
JOHN J. STARK
THOMAS BROWN
KEITH PRICE
BILL WYNNE
NUMEROUS
RICHARD E. WEINGARTEN
MICHAEL A. SAUNDERS
RICHARD R. HENSEL
EDWARD H. ESZLARI
THOMAS J. SALUTI
JAMES A. STEVENS
HERBERT W. BLAIR
ROBERT B. MUNRO
HOWARD P. GOULD
RONNIE E. HEGE
DIRK ESTERLINE
MARK RICHARDS
DONN J. SACHS
CHARLES NEHER
ROBERT CASEY
FRED NICHOLS
OTIS MURPHY
HAROLD TATE
KB3BYT ET AL.
NUMEROUS
NUMEROUS
STEPHEN B. GERSTENSCHLAGE
MADANAGOPAL KUNNAVAKKAM
WILLIAM L. HOENSTINE
MARTIN K. CAMPBELL
KEITH R. SCHREIBER
GEORGE A. ROBINSON
MICHAEL GRIZZAFFI
JONATHAN W. DIXON
CHARLES P. ADKINS
FRANCIS J. MIELE
DOUGLAS E. WHITE
ROBERT M. MOORE
MAX JUARBE-DIAZ
LARRY R. FRAVEL
JAMES G. WILCOX
EMERY D. WOOTEN
CALVIN F. GROOM
BONNIE V. SMITH
RICHARD SNYDER
GUNNAR SEABURG
CRAIG BOSWORTH
STEVEN SMITH
RICK LABANCA
MICHAEL DELL
LEN WINKLER
JOHN WILSON
JOHN RAUCH
HOWARD ALT
LEO OWENS
BOB BROWN
NUMEROUS
WILLIAM JOOH JOSEPH HOGE
CHRISTOPHER D. RUMBAUGH
CHRISTOPHER J. CIESLAK
WILLIAM A. YOREO
HOWARD F. HOLDEN
BRADLEY W. WYATT
JOHN M. MCCLARY
JACK ROBERTSON
JOHN P. SMITH
JIM LEININGER
ED A. JONES
AL DESHOTEL
HAL SILVERMAN
STEVE MACEY
DAVID TOWNSEND
BILL CLARK
WILLIAM B. FREELY
BRUCE PERENS
DON DEJARNETTE
DON DEJARNETTE
DUANE P. MANTICK
D. TOWNSEND
D. TOWNSEND
JOHN R. IRVIN Reply Comments
ROY W. ANDERSON, JR.--W1CRD
LEROY KLOSE III
NO CODE INTERNATIONAL
SCOTT LEYSHONE
AMERICAN RADIO RELAY LEAGUE,INC.
COURTNEY B. DUNCAN ET AL.
MICHAEL J. SPARLING
TIM E. BILLINGSLEY
BARNETT CARWILE 'JAY' JACKSON JR.
DAVID J ROSEN
JIMMIE L. GILES JR.
RICHARD C. SHERMAN
DONALD C. MILLS
JAMES H. SCOTT
WILLIAM DUMAS
NATIONAL CONFERENCE OF VEC'S
SUNNYVALE VEC ARC, INC.
VALERIE GILBERT
THOMAS TULLY
JANET HOWITT
DAVID MOISAN
BRUCE PERENS
LEONARD H. ANDERSON
MICHAEL P. DEIGNAN
ROBERT LECH, WA2HOQ
EDWARD MITCHELL
DENNIS G. MAJOR
EDWARD P. HUTCHINSON, W7EPH
DAVID N JOHANSON
MARSHALL G. EMM
HAROLD D. BATES
HAROLD D. BATES
PAT CHU, KH6KL
FREDERICK V. ADSIT
J.V.SCHEINDELEN PE1KTH , NCI-2261
ANTHONY LOUIS IMPELLITTERI
ANTHONY LOUIS IMPELLITTERI
WILLIAM H. SOHL
ALAN J. WORMSER
RICHARD E. DEPAULIS N1JEE
NATIONAL CONFERENCE OF VEC
TIM BILLINGSLEY, KD5CKP
CHRISTOPHER D. RUMBAUGH
JEFFREY R. HARRIS NZ6Y
RIKU J KALINEN, K2LWO
THOMAS TERPENING JR.
JAMES A. WALKER, JR.
ROBERT A. MATTEUCCI
JOE SPINOSA - W6JOE
FREDERICK A. PYLANT
ED GRIFFITH, KC6WCT
DOUGLAS W. FOREHAND
BOB VERNALL, ZL2CA
WILLIAM A. EITNER
QUINCE W. GRAVEEN
MICHAEL C. HUGHES
JERRY S. GODSHALK
JAMES KELLY, KK3K
GEORGE J. DIERING
BARBARA PATTERSON
JOHN R. HARTZELL
DARRELL FRAPPIER
JOSEPH A SHIPEK
JAMES W. THOMAS
JAMES T. KINSEY
CAROLYN MATHEWS
BRUCE W. CURTIS
THOMAS R. SHAY
LAWRENCE LAUER
JEROME V. BELL
DAVID LEE EDDY
BARRY CHOISSER
ROBERT RETTIE
CHARLES BROWN
TERESA SMITH
JACK CHALAIS
DAVID MORGAN
DAVID KAPLAN
DALE R. REED
PAT RALSTON
MIKE SHEAT
MICHAEL J. DINELLI
JAMES S. HANSON
EARL H. CARTER
STEVEN L. KARTY
ED GRIFFITH
LAWRENCE E. MELBY II,KA5TXL
NICKOLAUS E. LEGGET
LARRY R. LABB
STEVEN JAMES ROBESON, K4YZ
ED GRIFFITH
EDGEWOOD AMATEUR RADIO SOCIETY, INC.
KENNETH J. COLLIER
RICHARD G. GUTKNECHT, NZ2I
ED GRIFFITH, KC6WCT
LARRY ANGER
BRADLEY A. FARRELL APPENDIX B
Final Rules
Part 97 of Chapter I of Title 47 of the Code of Federal Regulations is amended to read as follows:
Part 97 - AMATEUR RADIO SERVICE
1. The authority citation for Part 97 continues to read as follows:
Authority: 48 Stat. 1066, 1082, as amended; 47 U.S.C. 154, 303. Interpret or
apply 48 Stat. 1064-1068, 1081-1105, as amended; 47 U.S.C. 151-155, 301-609, unless
otherwise noted.
2. Section 97.9 is amended by revising paragraph (b) to read as follows:
97.9 Operator license.
(a) ***
(b) The person named in an operator license grant of Novice, Technician, Technician Plus, General
or Advanced Class, who has properly submitted to the administering VEs a FCC Form 605 document
requesting examination for an operator license grant of a higher class, and who holds a CSCE indicating that
the person has completed the necessary examinations within the previous 365 days, is authorized to exercise
the rights and privileges of the higher operator class until final disposition of the application or until 365 days
following the passing of the examination, whichever comes first.
3. Section 97.13 is amended by revising paragraphs (b) and (c)(2) to read as follows:
97.13 Restrictions on station location.
* * * * *
(b) A station within 1600 m (1 mile) of an FCC monitoring facility must protect that facility from
harmful interference. Failure to do so could result in imposition of operating restrictions upon the amateur
station by a District Director pursuant to 97.121 of this Part. Geographical coordinates of the facilities that
require protection are listed in 0.121(c) of this chapter.
(c) * * *
(1) * * *
(2) If the routine environmental evaluation indicates that the RF electromagnetic fields could exceed
the limits contained in 1.1310 of this chapter in accessible areas, the licensee must take action to prevent
human exposure to such RF electromagnetic fields. Further information on evaluating compliance with these
limits can be found in the FCC's OET Bulletin Number 65, "Evaluating Compliance with FCC Guidelines for
Human Exposure to Radiofrequency Electromagnetic Fields."
4. Section 97.17 is amended by revising paragraphs (a), (b)(1) and (c) to read as follows:
97.17 Application for new license grant.
(a) Any qualified person is eligible to apply for a new operator/primary station, club station or military
recreation station license grant. No new license grant will be issued for a Novice, Technician Plus, or
Advanced Class operator/primary station or RACES station.
*****
5. Section 97.21 is amended by revising paragraph (a)(2), (a)(3), and (a)(3)(iii) to read as follows:
97.21 Application for a modified or renewed license.
(a) ***
(3) May apply to the FCC for renewal of the license grant for another term in accordance with 1.913
of this chapter. Application for renewal of a Technician Plus Class operator/primary station license will be
processed as an application for renewal of a Technician Class operator/primary station license.
(i) ***
(ii) ***
(iii) For a club station or military recreation station license grant showing a call sign obtained through
the sequential call sign system, and for a club or military recreation station license grant showing a call sign
obtained through the vanity call sign system but whose grantee does not want to have the vanity call sign
reassigned to the station, the application must be presented in document form to a Club Station Call Sign
Administrator who must submit the information thereon to the FCC in an electronic batch file. The Club
Station Call Sign Administrator must retain the collected information for at least 15 months and make it
available to the FCC upon request. RACES station license grants will not be renewed.
*****
6. Section 97.301 is amended by revising paragraph (e) to read as follows. Section 97.301(f) is deleted.
The frequency tables in Section 97.301(a), (b), (c), and (d) remain unchanged.
97.301 Authorized frequency bands.
*****
(e) For a station having a control operator who has been granted an operator license of Novice
Class or Technician Class and who has received credit for proficiency in telegraphy in accordance with
the international requirements.
Wavelength ITU ITU ITU Sharing requirements See 97.303
band Region 1 Region 2 Region 3 Paragraph
HF MHz MHz MHz
80 m 3.675-3.725 3.675-3.725 3.675-3.725 (a)
40 m 7.050-7.075 7.10-7.15 7.050-7.075 (a)
15 m 21.10-21.20 21.10-21.20 21.10-21.20
10 m 28.10-28.50 28.10-28.50 28.10-28.50
VHF MHz MHz MHz
1.25 m --- 222-225 --- (a)
UHF MHz MHz MHz
23 cm 1270-1295 1270-1295 1270-1295 (h) (i)
7. Section 97.307 is amended by revising paragraph (f) (10) to read as follows:
97.307 Emission standards.
*****
(f) ***
(10) A station having a control operator holding a Novice Class operator license or a Technician Class
operator license and who has received credit for proficiency in telegraphy in accordance with the international
requirements may only transmit a CW emission using the international Morse code or phone emissions J3E and
R3E.
*****
8. Section 97.313 is amended by revising paragraphs (c) and (f) to read as follows:
97.313 Transmitter power standards.
*****
(c) *****
(2) The 28.1-28.5 MHz segment when the control operator is a Novice Class operator or a Technician
Class operator who has received credit for proficiency in telegraphy in accordance with the international
requirements; or
*****
(f) No station may transmit with a transmitter power exceeding 50 W PEP on the UHF 70 cm
band from an area specified in footnote US7 to 2.106 of Part 2, unless expressly authorized by the
FCC after mutual agreement, on a case-by-case basis, between the District Director of the applicable field
facility and the military area frequency coordinator at the applicable military base. An Earth station or
telecommand station, however, may transmit on the 435-438 MHz segment with a maximum of 611 W
effective radiated power (1 kW equivalent isotropically radiated power) without the authorization otherwise
required. The transmitting antenna elevation angle between the lower half-power (-3 dB relative to the
peak or antenna bore sight) point and the horizon must always be greater than 10o.
*****
9. Section 97.407 is amended by revising paragraph (b) introductory text to read as follows:
97.407 Radio Amateur Civil Emergency Service (RACES).
*****
(b) The frequency bands and segments and emissions authorized to the control operator are
available to stations transmitting communications in RACES on a shared basis with the amateur service. In
the event of an emergency which necessitates the invoking of the President's War Emergency Powers
under the provisions of Section 706 of the Communications Act of 1934, as amended, 47 U.S.C. 606,
RACES stations and amateur stations participating in RACES may only transmit on the following
frequency segments:
*****
10. Section 97.501 is amended by revising the introductory text and paragraphs (a), (b), and (c)
to read as follows:
97.501 Qualifying for an amateur operator license.
Each applicant must pass an examination for a new amateur operator license grant and for each
change in operator class. Each applicant for the class of operator license grant specified below must pass,
or otherwise receive examination credit for, the following examination elements:
(a) Amateur Extra Class operator: Elements 1, 2, 3, and 4;
(b) General Class operator: Elements 1, 2, and 3;
(c) Technician Class operator: Element 2.
11. Section 97.503 is amended by removing paragraph (c) and revising paragraphs (a) and (b) to read as
follows:
97.503 Element standards.
(a) ***
Element 1: 5 words per minute
(b) ***
(1) Element 2: 35 questions concerning the privileges of a Technician Class operator license. The
minimum passing score is 26 questions answered correctly.
(2) Element 3: 35 questions concerning the privileges of a General Class operator license.
The minimum passing score is 26 questions answered correctly.
(3) Element 4: 50 questions concerning the privileges of an Amateur Extra Class operator license.
The minimum passing score is 37 questions answered correctly.
12. Section 97.505 is amended by revising paragraph (a) to read as follows:
97.505 Element credit.
(a) The administering VEs must give credit as specified below to an examinee holding any of the
following license grants or license documents:
(1) An unexpired (or expired but within the grace period for renewal) FCC-granted Advanced
Class operator license grant: Elements 1, 2, and 3.
(2) An unexpired (or expired but within the grace period for renewal) FCC-granted General Class
operator license grant: Elements 1, 2, and 3.
(3) An unexpired (or expired but within the grace period for renewal) FCC-granted Technician
Plus Class operator (including a Technician Class operator license granted before February 14, 1991) license
grant: Elements 1 and 2.
(4) An unexpired (or expired but within the grace period for renewal) FCC-granted Technician
Class operator license grant: Element 2.
(5) An unexpired (or expired but within the grace period for renewal) FCC-granted Novice Class
operator license grant: Element 1.
(6) ***
(7) An unexpired (or expired less than 5 years) FCC-issued commercial radiotelegraph operator
license or permit: Element 1.
(8) An expired FCC-issued Technician Class operator license document granted before March 21,
1987: Element 3.
(9) An expired or unexpired FCC-issued Technician Class operator license document granted before
February 14, 1991: Element 1.
(b) ***
13. Section 97.507 is amended by revising paragraph (a) to read as follows:
97.507 Preparing an examination.
(a) Each telegraphy message and each written question set administered to an examinee must be
prepared by a VE holding an Amateur Extra Class operator license. A telegraphy message or written
question set may also be prepared for the following elements by a VE holding an operator license of the
class indicated:
(1) Element 3: Advanced Class operator.
(2) Elements 1 and 2: Advanced, General, or Technician (including Technician Plus) Class operators.
*****
14. Section 97.509 amended by revising paragraphs (a), (b)(3), and (i) to read as follows:
97.509 Administering VE requirements.
(a) Each examination for an amateur operator license must be administered by a team of at least
3 VEs at an examination session coordinated by a VEC. Before the session, the administering VEs or the
VE session manager must ensure that a public announcement is made giving the location and time of the
session. The number of examinees at the session may be limited.
(b) ***
(1) ***
(2) ***
(3) Be a person who holds an amateur operator license of the class specified below:
(i) Amateur Extra, Advanced or General Class in order to administer a Technician Class operator
license examination;
(ii) Amateur Extra or Advanced Class in order to administer a General Class operator license
examination;
(iii) Amateur Extra Class in order to administer an Amateur Extra Class operator
license examination.
*****
73 de Mirko +++ DL 8 ABO / AB 0 DL +++
Read previous mail | Read next mail
| |
