Posted April 11, 1994

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

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

Executive Summary

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

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

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

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

Recommendations

1.  Who Should Participate

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

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

2.  The issue of Fees

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

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

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

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

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

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

3.  Holders of previous Preferred Callsigns

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

4.  Phase-in Periods and Priorities

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

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

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

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

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

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

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

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

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

5.  Club Applications

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

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

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

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

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

6.  Vacated Callsigns

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

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

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

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

7.  Number of Choices on Form 610-V

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

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

8.  Retirement of Callsigns

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

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

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

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

9.  Out of Area Callsign Issuance

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

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

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

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

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

10.  Outside of the Continental United States

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

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

11.  Specific Comments on the NPRM

New 97.19 (c)  Substitute the following:

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

New 97.19(f)(3)

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

Sentence Added to the end of 97.19(g)

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

New 97.19(g)(1)

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

New 97.19(g)(2)

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

New 97.5(d)(2)

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

12.  Questions Posed in the Discussion Section

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

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

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

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

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

13.  Special Event Callsigns

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

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

14.  Final Comments

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

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

Respectfully Submitted,  

Stephen Mendelsohn, WA2DHF, Chairman
