At the request of the FCC, the ARRL on has filed supplemental comments urging the Commission to continue to make available via the Universal Licensing System (ULS) historical Amateur Radio license information not associated with a current licensee or a pending application. The League filed its initial comments in the proceeding, WT Docket 15-81, last June. In its earlier comments, the ARRL argued that historical license data not associated with a current license is a primary means for volunteer examiner coordinators (VECs) to research the validity of exam credit on the basis of a license once held by the candidate. ARRL General Counsel Chris Imlay, W3KD, who filed the supplemental comments on November 13, said the Commission now wanted to know how many applicants were taking advantage of lifetime examination credit, which went into effect in the summer of 2014.

The ARRL told the FCC that its VEC currently transmits an average of five applications with expired license credits each week, and has handled some 300 such applications since July 2014. The W5YI VEC told the ARRL that it relies heavily on historical license information too. The ARRL argued that the number could grow, as word of the expanded opportunity for exam element credit continues to spread.

“The Commission, having obligated VECs to validate claims of former licensee status and the data associated therewith cannot fairly take away a key resource for objectively evaluating the validity of applicants’ claims and documentation,” the League said in its supplemental comments. “To do so, decreases substantially the ability of VECs to maintain the historically high degree of integrity of the Amateur Radio licensing process. Since the Commission clearly has no intention of assuming any of the burden of the validation process — and is ill equipped to do so in any case — the proposal is both unfair and illogical.”

The ARRL said that researching expired license credit is just one of several instances in which VECs might have to access historical license data. Other possibilities, the League said, could include using historical data to validate a candidate’s identification, and to research exam credit for pre-1987 Technician licenses.

The League concluded by again asking the FCC to continue to make available historical license data at least to VECs, if not the general public.