On January 11, the FCC issued a Memorandum Opinion and Order, denying an ARRL Petition for Reconsideration concerning vanity and club call signs. Filed with the Commission in January 2011, the ARRL’s Petition was in response to the FCC’s Report and Order (R&O) that detailed rules changes to the vanity call sign system and call signs for Amateur Radio clubs. These new rules went into effect on February 14, 2011.

The ARRL found that most changes made by the R&O were “reasonable codifications and clarifications of existing policies.” But it asserted that several amended Sections of Part 97 -- including Sections 97.5 and 97.19 -- were unclear. In its Petition, the ARRL urged 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 pointed out that it had “amended and clarified its rules with respect to vanity call signs and club station licenses to promote processes that are more to limit club stations to holding only one vanity call sign and to limit an individual to being the trustee for only one club station license.” It said that the purpose of the rules change was “to prevent club stations from obtaining an unfair share of desirable call signs, given that individuals are limited to holding one operator/primary station license (and, therefore, one call sign), while there was no limit on the number of licenses a club could hold.”

The FCC said that it had heard from radio amateurs who urged the FCC to limit the number of club stations for which an individual could serve as trustee, “pointing out that limiting the number of vanity call signs that a club can obtain would accomplish nothing if an individual could bypass the rule by creating multiple clubs.”

The FCC noted that the ARRL supports its efforts to prevent club stations from obtaining an unfair share of desirable call signs, but expresses concern that the specific rule language adopted by the Commission “does not preclude the abuses that the Report and Order intended to preclude.” In its Petition, the ARRL stated that if a club has multiple station trustees, each of these trustees could obtain a vanity call sign for the club, thereby allowing the club to obtain multiple vanity call signs. The ARRL also argued that a club could “‘gam[e]’ the club station vanity call sign system” by obtaining multiple FCC Registration Numbers (FRNs) and applying for a vanity call sign under each FRN. “We do not believe that the vanity call sign system is subject to the abuses identified by the ARRL,” the FCC said, “or that its suggested rule changes are necessary.”

In denying the ARRL’s Petition for Reconsideration, the FCC maintained that a club may have only one license trustee at a time: “Section 97.5(b)(2) of our Rules states, in part, ‘A club station license grant may be held only by the person who is the license trustee designated by an officer of the club.’ Consequently, we believe that Section 97.19(a), which provides that ‘the person named in a club station license grant that shows on the license a call sign that was selected by a trustee is not eligible for an additional vanity call sign,’ effectively implements the Commission’s decision to limit club stations to holding only one vanity call sign. Any application from a club for an additional vanity call sign when the club already is assigned a vanity call sign will be dismissed because the trustee is not eligible for an additional vanity call sign. Accordingly, we decline to revise Section 97.19(a) as ARRL requests.”

With regard to the ARRL’s concern that a club could obtain multiple FRNs and thereby obtain multiple vanity call signs, the FCC asserted that vanity call sign applications from club stations are checked not only with respect to whether the FRN on the application matches the FRN on the grant of a vanity call sign to any club station, but also with respect to whether the club name on the application matches the club name on the grant of a vanity call sign to any club station: “Therefore, even if a club obtains or holds multiple FRNs, if an application is received from a club and the database shows that a club with the same name already has a vanity call sign, the application will not be granted, absent further review. We accordingly conclude that the change that ARRL requests to Section 97.5(b)(2) is not necessary.”

The FCC maintained that the ARRL’s Petition for Reconsideration “does not provide any grounds for reconsidering the Commission’s decision in the Report and Order. The concerns expressed by the ARRL about licensees attempting to evade the rules adopted in the Report and Order are already addressed by our licensing rules and processes. We therefore deny the Petition for Reconsideration.” The FCC also noted that while ARRL suggests that it take the matter up again in a future proceeding, “we have no plans to revisit the issue at this time.”

Commenting on the Memorandum Opinion and Order, ARRL Chief Executive Officer David Sumner, K1ZZ, observed: “We believe the FCC has been too hasty in denying the ARRL’s Petition for Reconsideration. In footnote 6, the FCC assures amateurs that ‘Club stations may continue to obtain multiple sequential call signs.’ However, this is inconsistent with the Commission’s interpretation of 97.5(b)(2), as preventing a club from having more than one trustee, because 97.5(b)(2) applies to all club station licenses and not simply to those with vanity call signs. Coupled with 97.17(d), this appears to make it impossible for clubs to obtain more than one sequential call sign, contrary to the Commission’s intent as stated in footnote 6.”