In the Matter of ) WT Docket No. 98-143

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1998 Biennial Regulatory Review -- ) RM-9148

Amendment of Part 97 of the Commission's ) RM-9150

Amateur Service Rules. ) RM-9196

)

)

Adopted: December 22, 1999 Released: December 30, 1999

By the Commission:

Paragraph

Number of License Classes 9

Disposition of the Designated Novice Bands 53

Greater Volunteer Examiner Opportunities 57

Other Issues 67

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.

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.

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.

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.

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 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.

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.

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.

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.

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.

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.

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.

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.

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>.

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.

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

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

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

Final Rules

Part 97 of Chapter I of Title 47 of the Code of Federal Regulations is amended to read as follows:

1. The authority citation for Part 97 continues to read as follows:

2. Section 97.9 is amended by revising paragraph (b) to read as follows:

(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:

* * * * *

(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:

(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:

(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.

*****

(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:

*****

(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:

*****

(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 10^o.

*****

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:

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:

(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:

(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:

(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:

(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.

*****