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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) WT Docket No. 98-143 ) 1998 Biennial Regulatory Review -- ) RM-9148 Amendment of Part 97 of the Commission's ) RM-9150 Amateur Service Rules. ) RM-9196 ) ) REPORT AND ORDER Adopted: December 22, 1999 Released: December 30, 1999 By the Commission: TABLE OF CONTENTS Paragraph INTRODUCTION AND EXECUTIVE SUMMARY . . . . . . . . . . . . . . .1 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . .4 DISCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . .7 License Structure . . . . . . . . . . . . . . . . . . . . .7 Number of License Classes. . . . . . . . . . . . . . .9 Telegraphy Examination Requirements. . . . . . . . . 22 Written Examinations . . . . . . . . . . . . . . . . 40 Disposition of the Designated Novice Bands . . . . . 53 Greater Volunteer Examiner Opportunities. . . . . . . . . 57 RACES Station Licenses. . . . . . . . . . . . . . . . . . 61 Privatization of Certain Enforcement Procedures . . . . . 64 Other Issues. . . . . . . . . . . . . . . . . . . . . . . 67 CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . 69 PROCEDURAL MATTERS . . . . . . . . . . . . . . . . . . . . . . 70 ORDERING CLAUSES . . . . . . . . . . . . . . . . . . . . . . . 72 I. INTRODUCTION AND EXECUTIVE SUMMARY 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. II. BACKGROUND 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. III. DISCUSSION A. License Structure 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. 1. Number of License Classes 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. 2. Telegraphy Examination Requirements 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 do not concur with the comments alleging that the passing of a telegraphy examination is an indication of the examinee's good character, high intelligence, cooperative demeanor, or willingness to comply with our rules. These traits are also found in individuals who have not passed a telegraphy examination rather that being exclusive to those who have passed such a test. With respect to comments that make claims for the superiority of telegraphy over other types of communications, we do not consider these arguments as germane to this proceeding. The Notice did not propose to discontinue the authorization of telegraphy CW emission types on any amateur service frequency. The amateur service in the future, as it has in the past, can provide to those who personally desire to do so the opportunity to communicate by telegraphy. 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. 3. Written Examinations 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. 4. Disposition of the Designated Novice Band 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. B. Greater Volunteer Examiner Opportunities 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. C. RACES Station Licenses 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. D. Privatization of Certain Enforcement Procedures 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. E. Other Issues 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. IV. CONCLUSION 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. V. PROCEDURAL MATTERS Regulatory Flexibility Act 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 . This Report and Order also is available at the Commission's internet site at: . VI. ORDERING CLAUSES 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. Further Information 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 APPENDIX A Comments 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 Reply Comments 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 APPENDIX B Final Rules Part 97 of Chapter I of Title 47 of the Code of Federal Regulations is amended to read as follows: Part 97 - AMATEUR RADIO SERVICE 1. The authority citation for Part 97 continues to read as follows: Authority: 48 Stat. 1066, 1082, as amended; 47 U.S.C.  154, 303. Interpret or apply 48 Stat. 1064-1068, 1081-1105, as amended; 47 U.S.C.  151-155, 301-609, unless otherwise noted. 2. Section 97.9 is amended by revising paragraph (b) to read as follows:  97.9 Operator license. (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:  97.13 Restrictions on station location. * * * * * (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:  97.17 Application for new license grant. (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:  97.21 Application for a modified or renewed license. (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.  97.301 Authorized frequency bands. ***** (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:  97.307 Emission standards. ***** (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:  97.313 Transmitter power standards. ***** (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 10o. ***** 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:  97.501 Qualifying for an amateur operator license. 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:  97.503 Element standards. (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:  97.505 Element credit. (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:  97.507 Preparing an examination. (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:  97.509 Administering VE requirements. (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. *****