In October 2010, the FCC released a Report and Order (R&O), detailing rules changes to the vanity call sign system and call signs for Amateur Radio clubs. These new rules are scheduled to go into effect on February 14. The ARRL found that most changes made by the R&O are “reasonable codifications and clarifications of existing policies.” But several amended Sections of Part 97 -- including §§97.5 and 97.19 -- are unclear. As such, the ARRL filed a Petition for Partial Reconsideration, urging the FCC to reconsider and modify these portions “in order to reflect the intent of the Report and Order.”

In the R&O, the FCC took into consideration some of the ARRL’s comments, but not all. The ARRL found it “disappointing” that the Commission refused to consider in this proceeding “a series of reasonable proposals aimed at increasing the available pools of Group A call signs.” The ARRL, in its comments, asked the FCC to consider several changes that could be made “that would increase the number of desirable call signs available for assignment, both sequentially and in the vanity call sign program, and which would provide greater flexibility in the temporary assignment of special-event call signs in the Amateur Service.”

While the ARRL did not seek reconsideration of this refusal, it noted that the Commission’s “tersely stated dismissal of these proposals” should, however, be reevaluated in the near term in a separate proceeding. As such, the ARRL urged the FCC to remain open to “future, near-term proposals to address improvements to the sequential, vanity and special event call sign systems; to preclude abuses of the vanity call sign assignment system; and to remedy the serious shortage of available Group A call sign permutations.”

Limits on Club Station Licenses

In the Notice of Proposed Rule Making (NPRM) on this matter, released in November 2009, on this matter, the ARRL found the FCC’s positions “relatively straightforward” and supported most of them; however, with respect to the NPRM’s proposal to impose limits on club station licenses and call signs, the ARRL offered a counterproposal. In the NPRM, the FCC proposed to limit each amateur club to one license grant and one club call sign (of any type); clubs now holding more than one would be allowed to keep those already assigned to them. The proposal was a per-club limit rather than a per-trustee limit. The ARRL’s Petition, if adopted, would close a loop hole that would have allowed a club with multiple trustees to obtain more than one vanity call sign.

“The principal abuse that the NPRM sought to prevent was (and is) the situation, often encountered, in which a trustee holds a number (sometimes a large number) of preferred vanity call signs (typically Group A call signs, principally those in a 1×2 or 2×1 format), whether or not the call signs are in the name of the same club,” the ARRL noted in its Petition. “There are numerous examples of individual trustees ‘hoarding’ large numbers of desirable call sign combinations.”

The ARRL agreed with the FCC that there were “more than a few instances of flagrant abuse of the Commission’s procedures by individual club trustees,” and noted that it is well aware of the acute shortage of Group A call sign combinations. In its comments, the ARRL proposed a number of solutions to the readily apparent, acute shortage of call signs in preferred formats, principally Group A call signs, but the R&O did not adopt any of them.

The ARRL was critical, however, of the proposed remedy in the NPRM: “The problem with a blanket limitation on club licenses and call signs was that many clubs have, for example, more than one station (such as a club that operates numerous repeaters). Those clubs have a legitimate need for more than one call sign. Furthermore, the Notice-proposed limit would not be sufficient to stem instances of ‘hoarding’ desirable call signs through multiple club licenses, because a trustee could bypass this rule simply by creating multiple clubs involving the same persons. There is no limit on the number of clubs that a group of four persons or more can form.”

In its comments, the ARRL argued that, since the premise for the limits proposed in the NPRM was that there is a shortage of preferred format call signs, “the rules should provide a means of inhibiting the perceived problem of an individual obtaining multiple vanity call signs in those formats in his or her role as the trustee of a club.” As such, the ARRL offered a counterproposal, asking that the FCC prohibit clubs from applying for new Group A call signs, with the exception of in memoriam call signs. Existing Group A call signs held by clubs could be grandfathered. It was the ARRL’s position that this was “significantly less burdensome on amateur clubs than the NPRM proposal would have been, and it dealt directly with the fundamental problem sought to be addressed.”

Not only did the FCC refuse to adopt the ARRL’s counterproposal, it also refused to adopt the proposal offered in the NPRM to limit club stations to one call sign, but not to limit the number of clubs for which a licensee may serve as a trustee. Instead, as outlined in the R&O, the FCC decided to adopt the following provisions:

• A limit of one vanity call sign per club.
• No limit on the number of sequential call signs that a club can have, thus permitting one club to have multiple licenses as needed.
• To limit each trustee to one club station license (thus to prevent trustees from bypassing the “one vanity call sign per club” rule by allowing a single trustee to form multiple clubs).

The real problem, the ARRL maintains, is not the FCC’s decision to limit vanity call signs to one per club going forward, or even to limit an individual to service as a trustee for only one club station license grant. The problem instead is the way the Commission has chosen to implement these limitations in Section 97.19(a) as amended, which does not preclude the abuses that the R&O intended to preclude.

Under the new rules -- which go into effect on February 14 -- a licensee can be a trustee for only one club license and a club can obtain only one vanity call sign; however, there are several methods by which the rule implementing this new policy can be avoided. The ARRL pointed out a number of them in its Petition and offered new wording to these portions of the rules that would prevent “gaming” the club station vanity call sign assignment system “to close as many of these loopholes as possible relative to aggregating vanity call signs while still permitting multiple club licenses.”

Group A Call Sign Permutations and Administration of Group A Call Signs

Even though the ARRL does not seek reconsideration of the FCC’s refusal to address what it called “the critical shortage of Group A call signs,” it did suggest that the FCC “failed in this proceeding to address the underlying premise for the NPRM proposals, and the rule changes adopted in this proceeding: the shortage of Amateur Radio call signs in the preferred formats.”

The ARRL pointed out that the FCC, even after issuance of this R&O, “still allows abuses in the assignment of the most desirable blocks of call signs through the vanity call sign assignment system.” Saying that there is “intense competition among radio amateurs for these call signs,” the ARRL noted that the matter was an important issue within the amateur community. As such, the ARRL said that it hoped that “as a necessary subsequent adjunct to the rule clarifications and modifications adopted in the R&O, the Commission will in a near-term, separate proceeding address obvious issues of fairness in the administration of Group A call signs and consider reasonable proposals to expand the pool of available Group A call signs (and as well sequential and special event call signs).”

While there are indeed large numbers of call signs available in other than 1×2 or 2×1 formats, the ARRL stated that there is a critical shortage of available Group A call signs: “These opportunities deserve a fair hearing and serious consideration, though the R&O in this proceeding does not indicate that one was provided.”

The ARRL maintained that the FCC, with this R&O, has “missed an opportunity to make available new call signs in preferred formats; to preclude abuses in the assignment of Group A call signs, and to address the root problem which gave rise to some of the rule changes accomplished by the R&O, which is the scarcity of such preferred call sign formats.”

As such, the ARRL asks that the FCC take “the timely opportunity to comprehensively update the call sign assignment system for the Amateur Service and thereby provide for the continued, steady growth of the Service. Without substantial administrative burden, such an updating will help to enhance the pride and satisfaction of licensees in their personal achievements in the radio art and their dedication to public service.”