November 2010 - arrl-odv - reflector.arrl.org

Re: "In-Newington" Newsletter Chaff Reduction Request
by Brian Mileshosky 16 Nov '10

16 Nov '10

Since opinions were solicited, I'll share mine. I don't see a need to scrutinize this email publication, nor engage the Board to micromanage it or its associated staff. I'm neither concerned with a beyond-negligible 17.5 MB of space a YEAR (even if I should choose to archive them rather than deleting after reading), nor an attached Word document for those who prefer that format. Lastly...me and my huge, comfy carbon footprint wonder if by "green initiative" you mean the consumption of fire roasted green chile? 73, Brian N5ZGT ARRL Director, Rocky Mountain Division On the web at www.RockyMountainDivision.org On Tue, 16 Nov 2010, Richard J. Norton wrote: > In my six years on the board, I've always thought that my most significant > accomplishment was to get the content of weekly E-mail newsletter, > "IN-News," delivered to the board inside the text of the > E-mail. Previously it was delivered only as an attached .doc file, which was > particularly tedious to read, especially if you were at a > high-price-per-minute overseas Internet cafe. > > I now reflect back on my supposed accomplishment, and am concerned that I > may have harmed the environment more than I've reduced the burden of serving > on the ARRL board. > > 1) The IN-News as delivered today, still has the .doc version > attached, unnecessarily at least doubling the size of each E-mail. > > 2) There is a giant ARRL emblem included at the beginning of each version of > the newsletter. Each emblem appears to take up 35k of memory, which is > usually over half of the size of the total message. Therefore, with a total > of 70k of memory in each E-mail, times 50 E-mails a year, times the last 5 > years, means that 17.5 megabytes of space on each computer that saves the > messages, is now taken up with 500 giant ARRL emblem images. > > Having been an ARRL member for about 55 years, I am well acquainted with the > ARRL emblem, and don't fell the need for 17.5 MB of my computer memory to be > filled with 500 giant ARRL emblem images. > > In the event that most of you do not need the .doc versions of the > newsletter, and don't need the giant ARRL emblems, I am proposing that we > consider simplifying the newsletters to contain only the E-mail text > versions without any emblems. I encourage other board members, particularly > those who use the .doc versions and those who are desirous of large ARRL > emblems in their computer memories, to express their opposing views. > > Should there be consensus for this obviously green initiative, we might get > it adopted with either an amendment to the By-laws or simple motion at the > January board meeting. Alternatively, our EVP might direct Ms. Kustosik to > simply change the IN-News format. > > 73, > > Dick Norton, N6AA >

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RE: "In-Newington" Newsletter Chaff Reduction Request
by Sumner, Dave, K1ZZ 16 Nov '10

16 Nov '10

Dick, I will be happy to do whatever you and your colleagues collectively would like, no formal action required. Dave From: Richard J. Norton [mailto:richardjnorton@gmail.com] Sent: Tuesday, November 16, 2010 1:15 PM To: arrl-odv Subject: "In-Newington" Newsletter Chaff Reduction Request In my six years on the board, I've always thought that my most significant accomplishment was to get the content of weekly E-mail newsletter, "IN-News," delivered to the board inside the text of the E-mail. Previously it was delivered only as an attached .doc file, which was particularly tedious to read, especially if you were at a high-price-per-minute overseas Internet cafe. I now reflect back on my supposed accomplishment, and am concerned that I may have harmed the environment more than I've reduced the burden of serving on the ARRL board. 1) The IN-News as delivered today, still has the .doc version attached, unnecessarily at least doubling the size of each E-mail. 2) There is a giant ARRL emblem included at the beginning of each version of the newsletter. Each emblem appears to take up 35k of memory, which is usually over half of the size of the total message. Therefore, with a total of 70k of memory in each E-mail, times 50 E-mails a year, times the last 5 years, means that 17.5 megabytes of space on each computer that saves the messages, is now taken up with 500 giant ARRL emblem images. Having been an ARRL member for about 55 years, I am well acquainted with the ARRL emblem, and don't fell the need for 17.5 MB of my computer memory to be filled with 500 giant ARRL emblem images. In the event that most of you do not need the .doc versions of the newsletter, and don't need the giant ARRL emblems, I am proposing that we consider simplifying the newsletters to contain only the E-mail text versions without any emblems. I encourage other board members, particularly those who use the .doc versions and those who are desirous of large ARRL emblems in their computer memories, to express their opposing views. Should there be consensus for this obviously green initiative, we might get it adopted with either an amendment to the By-laws or simple motion at the January board meeting. Alternatively, our EVP might direct Ms. Kustosik to simply change the IN-News format. 73, Dick Norton, N6AA

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"In-Newington" Newsletter Chaff Reduction Request
by Richard J. Norton 16 Nov '10

16 Nov '10

In my six years on the board, I've always thought that my most significant accomplishment was to get the content of weekly E-mail newsletter, "IN-News," delivered to the board inside the text of the E-mail. Previously it was delivered only as an attached .doc file, which was particularly tedious to read, especially if you were at a high-price-per-minute overseas Internet cafe. I now reflect back on my supposed accomplishment, and am concerned that I may have harmed the environment more than I've reduced the burden of serving on the ARRL board. 1) The IN-News as delivered today, still has the .doc version attached, unnecessarily at least doubling the size of each E-mail. 2) There is a giant ARRL emblem included at the beginning of each version of the newsletter. Each emblem appears to take up 35k of memory, which is usually over half of the size of the total message. Therefore, with a total of 70k of memory in each E-mail, times 50 E-mails a year, times the last 5 years, means that 17.5 megabytes of space on each computer that saves the messages, is now taken up with 500 giant ARRL emblem images. Having been an ARRL member for about 55 years, I am well acquainted with the ARRL emblem, and don't fell the need for 17.5 MB of my computer memory to be filled with 500 giant ARRL emblem images. In the event that most of you do not need the .doc versions of the newsletter, and don't need the giant ARRL emblems, I am proposing that we consider simplifying the newsletters to contain only the E-mail text versions without any emblems. I encourage other board members, particularly those who use the .doc versions and those who are desirous of large ARRL emblems in their computer memories, to express their opposing views. Should there be consensus for this obviously green initiative, we might get it adopted with either an amendment to the By-laws or simple motion at the January board meeting. Alternatively, our EVP might direct Ms. Kustosik to simply change the IN-News format. 73, Dick Norton, N6AA

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RE: arrl.org
by Sumner, Dave, K1ZZ 14 Nov '10

14 Nov '10

Bob, currently the Web site resides on servers that are offsite. We don't own them. Here is an explanation of the current situation and our plan to improve it, taken from the capital budget proposal containd in the 2011-2012 plan that was sent to the A&F Committee a few days ago. The committee will be considering it next week. The project is not over budget although it has taken more staff time than had been anticipated. Dave C. Servers of ARRL Web Site The ARRL website is presently hosted in the Rackspace cloud, sharing server resources with other Rackspace customers. This was done when we discovered late in the process of deploying the new site that the system requires many more processors than anticipated -- more than can be provided in a single server. However, in the cloud we are sharing resources with other cloud users, and the site's performance suffers because of this. We considered getting additional leased servers at Rackspace or another provider but concluded it would be more cost-effective and more manageable to move the site back to HQ. (HQ Internet connectivity was upgraded substantially this year, making this move feasible.) We are requesting the addition of four small server-grade machines. The requested machines, which have multi-core processors but not much in the way of disk storage or memory, are to be used to service Web-page requests under the guidance of a master server. This is the same configuration as the present cloud-based system, but the hardware will be fully dedicated to the Web site, providing higher performance, and the backing database will be run on optimized SAN storage, substantially ameliorating one of the main bottlenecks of the present site. Each of the servers costs $1,500, amounting to a total of $6,000. ________________________________ From: Bob Vallio [mailto:rbvallio@gmail.com] Sent: Sun 11/14/2010 5:02 AM To: arrl-odv Subject: arrl.org Recently, I encountered several consecutive proxy errors when attempting to log on to arrl.org <http://arrl.org/> . That is an indication that the system was overloaded. One of the "features" of the new site is that it is very demanding of server resources, and the server system we are using is sometimes unable to keep up with that demand. The way to fix that is to buy more servers. How much more money must we spend on the new system, beyond the amount which is already over budget? Bob Vallio -- W6RGG

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arrl.org
by Bob Vallio 14 Nov '10

14 Nov '10

Recently, I encountered several consecutive proxy errors when attempting to log on to arrl.org. That is an indication that the system was overloaded. One of the "features" of the new site is that it is very demanding of server resources, and the server system we are using is sometimes unable to keep up with that demand. The way to fix that is to buy more servers. How much more money must we spend on the new system, beyond the amount which is already over budget? Bob Vallio -- W6RGG

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IN-News
by Kustosik, Lisa, KA1UFZ 11 Nov '10

11 Nov '10

<<111010.doc>> IN-Newsletter <<Microsoft Word Picture>> Vol. 33, No. 45 November 10, 2010 -- Covers the period October 31-November 6. Upcoming Meetings and Events AMSAT/ARISS Meeting November 12-13 @ 8:30am - ARRL HQ Programs & Services Committee: November 13 @ 8:30am - ARRL HQ Ballot Counting for Director/Vice Director Elections November 19 @ 8:30am - ARRL HQ Administration &Finance Committee November 20 @ 8:30am - ARRL HQ Congratulations to Maria Somma, AB1FM for celebrating 25 years of service and to Leona Adams, W1LGA for 10 years of service at the ARRL. Regulatory Information Reported by Dan Henderson, N1ND We continue to work to resolve issues with the Volunteer Counsel and Volunteer Consulting Engineer database. This is in an effort to process numerous updates/changes/additions that are pending. We worked with General Counsel Chris Imlay, W3KD, and West Gulf Vice-Director John Stratton, N5AUS, on a city zoning ordinance question for a town in the Dallas area, as well as on some suggested language for a CC&R query for a subdivision also in the Dallas area. At the request of Great Lakes Division Director Jim Weaver, K8JE, we provided information on the appropriate use of club callsigns, reminding parties that a club callsign carries no operating privileges. Operating privileges are determined by the class of license held by the control operator at any given time, not the license class of the trustee of the club callsign. Several queries on the transfer of trusteeship of a club callsign were also received and answered. Work has begun on a legislative action /grassroots newsletter that will be prepared as needed. We have spoken with the Information Technologies department about developing a sign-up procedure for the newsletter as well as how it will actually be distributed. Media & Public Relations Reported by Allen Pitts, W1AGP Three main project in play include the creation of a community service flier, revision and reprint of the presentation folders used for special occasions and the ongoing planning with the video task group. The presentation of historical video at the brown bag luncheon seemed to go well with thanks to Penny for her part in the practical joke played. Development Reported by Mary Hobart, K1MMH As we enter the final weeks of 2010 several ARRL programs still have an uphill climb to reach the fund raising goals for the year. The Spectrum Defense Fund stands at $160,234 still needed $165,000 to reach the 2010 goal of $325,000. Plan call for a final 2010 issue of the Spectrum Defense Matters newsletter which will help close the gap. The Education & Technology Fund has reached $36,301 in campaign contributions-well short of its $60,000 goal for the year. The ARRL Diamond Club has topped $209,000 or 80% of its $263,000 target for 2010. A special email solicitation will be sent to appropriate groups of ARRL members to encourage year end gifts with an offer of a discount coupon on ARRL publications for contributions over $50 by December 31. This message will link members to the donation page on the web site for ease of processing. The growth in the ARRL Endowment during the last few weeks has been dramatic and encouraging. In addition to the $1,000,000 gift from the Mathias Trust, ARRL has received $99,090 from the estate of Benjamin Poinsett. Production/Editorial Reported by Joel Kleinman, N1BKE Khrystyne Keane wrote and distributed The ARRL Letter and voiced and produced ARRL Audio News for November 4, 2010. Lab Reported by Ed Hare, W1RFI RFI The new Smart Meter FAQ Page has now been added to the ARRL RFI pages. This new page answers many of the questions that Amateurs had about Smart Meter technology, especially in California. Interference from a smart meter concentrator or concentrators may be causing interference to the Amateur Service in the 902 MHz band in deployments in or near the PG&E areas in northern California. This investigation remains ongoing at this time. Jerry Ramie, KI6LGY, a member of the ARRL EMC Committee, is assisting in this matter. His finding is that the reported interference is coming from a PG&E "smart grid" neighborhood 1.1 miles from the complainant. Mike Gruber discussed several PG&E cases with Jerry Ramie. Jerry has been active in reviewing cases in the area. There are a number of PG&E complaints at this time that remain unresolved. Although PG&E's attorney seems to suggest that they are working on the problem, cases are not getting fixed. Ed Hare will have a follow-up discussion with PG&E to determine if we can help PG&E resolve these cases. The 69 kV power line noise case that we've been working on in New Jersey remains ongoing. Although the utility has shut down the line and made the repairs, they did not actually fix the noise. Mike Gruber has contacted Mike Martin of RFI Services to offer some advice on how to proceed. Recent RFI complaints in California and Colorado have been traced to indoor grow lights. Jerry Ramie borrowed one of the offending grow light ballasts and sent it to us. Mike Gruber purchased the associated bulb and fixture in order to do some conduced emissions testing. Initial testing of this ballast shows that it exceeds the Part 18 absolute conducted emissions limits by a considerable amount. This ballast, in fact, is the noisiest device we've ever seen in the Lab. Product Review Steve Ford and Bob Allison put together the Product Review video for December. The video was shot entirely in the Screen Room and featured not only a high performance contest transceiver, but also the test equipment used for measuring third order intermodulation distortion dynamic range. Bob Allison completed testing of a late model, high performance HF/6M transceiver and started on a basic HF transceiver. Committee Work Ed Hare attended the ANSI accredited C63® meeting in Detroit, MI. Ed is the Chair of Subcommittee 5 (Immunity) and the Below 30 MHz Working Group (WG). At this point, the WG is developing measurement methods of field strength below 30 MHz. Ed also received a nice surprise - C63® presented him with an award for his service in helping resolve a large number of loose ends on the c63.org web site. This is award given annually by C63® for outstanding contributions to the work of the committee. Ed will be attending the IEEE EMC Society Standards Development Committee this week in Pittsburgh, PA. This is the EMC Society standards board, overseeing the development of all IEEE EMC standards. Ed is the elected Secretary of this group. This week, they expect to deal with standards on power-line harmonics and the outstanding issues with the P1775 BPL EMC standard. Membership & Volunteer Programs Reported by Dave Patton, NN1N W1AW Thanks to Sean Kutzko, KX9X, Mike Corey, W5MPC, and Ward Silver, NØAX for operating W1AW in the November CW Sweepstakes. They made 1,303 QSOs, with all 80 ARRL sections, for an initial claimed score of 208,180. Joe Carcia, NJ1G updated the web code practice files. He also temporarily installed a 40-meter dipole for use during Sweepstakes. Joe also installed a Kenwood TS-590 as part of the Sweepstakes operating equipment. Scott Gee, WB9RRU worked on slow and fast code practice files for the early part of the month of November. Field Organization/Public Service Team Congratulations to Leona Adams, W1LGA, on her ten years of service at ARRL Headquarters! Staff members recognized and honored Leona on November 4th. Steve Ryan, N2ITF, of Ashville, New York, has been appointed Section Manager of the ARRL Western New York Section, effective November 2. MVP Department Manager Dave Patton, NN1N, made the appointment in consultation with Director Bill Edgar, N3LLR, after Scott Bauer, W2LC, announced his resignation for personal reasons on October 31. Bauer had served as Section Manager since January 2000. There will be a Section Manager election this winter in Arkansas. Dale Temple, W5RXU, of North Little Rock, has been nominated to run for the Arkansas Section Manager position. Incumbent Arkansas SM J.M. Rowe, N5XFW, has already been nominated to run for a new term. Mississippi Section Manager Malcolm Keown, W5XX, has been nominated to run for a new term of office. Nominating petitions for this election cycle are due at HQ by December 10. Chuck Skolaut received news that the Mexican XE1FAS beacon has moved to 24928 kHz. This relieves interference to the NCDXF 24930 kHz beacon. An unidentified pulse type signal was reported on 40 meters, and unknown Spanish speaking stations operating on 40 meter USB were heard in the Southern Florida area. Questions received this week included operating overseas, Technician class band privileges, remote overseas stations, the 150 MHz commercial band, and a Vermont Field Day entry. One radio amateur from Western Pennsylvania and one from Western Washington completed their examinations and became Official Observers this past week. Chuck also assisted at W1AW while visitors were operating. Sincerely Compiled by, Lisa Kustosik, KA1UFZ Assistant to the CEO Staff Absentee List All Staff 11/25-11/26 Holiday All Staff 12/24 Holiday All Staff 12/31 Holiday Leona Adams 11/19 Vacation `` 12/3pm Vacation Margie Bourgoin 12/20-12/24 Vacation Hugh Brower 11/22-11/24 Vacation Steve Ewald 11/29-12/3 Vacation Jackie Ferreira 12/23 Vacation `` 12/30 Vacation Steve Ford 12/23-12/31 Vacation Scott Gee 12/6-12/7 Vacation `` 12/23-12/27 Vacation Dan Henderson 12/20-1/5 Vacation Mary Hobart 12/27-12/28 Vacation Bob Inderbitzen 12/27-12/30 Vacation Sabrina Jackson 12/6-12/7 Vacation Rose-Anne Lawrence 11/19 Vacation Maryann Macdonald 12/27-12/31 Vacation Diane Petrilli 11/22-11/24 Vacation `` 12/20-12/22 Vacation `` 12/27-12/29 Vacation Steve Sant Andrea 11/29 Vacation Barry Shelley 11/23-11/24 Vacation `` 12/16-12/23 Vacation Chuck Skolaut 11/22-11/24 Vacation Hamfest/Member Contact/ARRL Representative Mike Corey 11/17 NPSTC Meeting, Washington, DC Joel Hallas 12/3-12/4 W. Central Florida Section Convention, Palmetto, FL Dan Henderson 11/12-11/16 Indiana State Convention, Ft. Wayne, IN/Vacation Harold Kramer 11/9 Westchester County Emergency Comm. Assoc. Brennan Price 11/1-11/24 SCRPM, SG5 & subsidiary Working Parties, Geneva

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Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order
by Bruce Frahm 09 Nov '10

09 Nov '10

Since when was "less easy" a deterrent to hams interested in callsigns, DXCC entities, or pick-your-passion? :-) K0BJ On Tue, Nov 9, 2010 at 1:18 PM, Chris Imlay <w3kd(a)aol.com> wrote: > True enough, the same trustee using multiple FRNs would be in violation of > the new rules, but it might be less easy than you think to catch them at it. > > >

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RE: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order
by Sumner, Dave, K1ZZ 09 Nov '10

09 Nov '10

Joe Speroni seems to have it figured out: http://www.ah0a.org/FCC/Clubs5.htm Dave From: Chris Imlay [mailto:w3kd@aol.com] Sent: Tuesday, November 09, 2010 2:18 PM To: arrl-odv Subject: Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order True enough, the same trustee using multiple FRNs would be in violation of the new rules, but it might be less easy than you think to catch them at it. Chris Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD(a)ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ <dsumner(a)arrl.org> To: arrl-odv <arrl-odv(a)reflector.arrl.org> Sent: Tue, Nov 9, 2010 9:56 am Subject: RE: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order Thanks, Chris. While a trustee might be able to fool the system into accepting an application for an additional club vanity call sign, my reading of 97.19(a) is that the trustee would not be eligible for the second club vanity call and the FCC could pull it after it was issued. Given the number of watchdogs looking for vanity call sign abuses, such a violation would not go undetected for long. However, I see nothing in the rules to prevent a club from having multiple trustees. Dave From: Chris Imlay [mailto:w3kd@aol.com <mailto:w3kd@aol.com?> ] Sent: Tuesday, November 09, 2010 9:27 AM To: arrl-odv Subject: Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order Yes, Dave, Section 97.19 IS badly worded. And there are actually two loopholes that would allow a club to have an unlimited number of club call signs despite the language in that revised Section and Section 97.17(d) as amended by the Order. Here's why: (1) a club could simply have multiple trustees, as you note; or (2) the same trustee could get multiple FRNs and use his or her own name multiple times. The ULS goes by FRN, not name, because licensees can have the same name and be two different persons. You can have multiple FRNs for the same Social Security Number or EIN (I know this because I do, and so do some of my clients). So, in order to fool the ULS (though perhaps not its successor, the consolidated database system now under development) it is easy to register for any number of FRNs and therefore any number of club licenses. As to the FCC's rather brusque dismissal of ARRL's proposals to increase the availability of Group A callsigns and other helpful proposals, the Executive Committee discussed, since we knew in advance that FCC was going to not adopt our proposals, how to respond. We discussed the two alternatives, depending on how the FCC addressed our proposals. If they simply said they were beyond the scope of the rulemaking, we would consider filing a separate petition for issuance of further rulemaking or a stand-alone petition. However, if the FCC dealt with our proposals substantively, we would have no choice but to either (1) forget it, or (2) file a Petition for Reconsideration. Since the FCC did in fact deal with our proposals in a substantive manner (albeit tersely and summarily, and in my view not well) we can either abandon the proposals or file a Petition for Reconsideration. The politics of the matter do not seem overly favorable to us, but now that this order is out, perhaps the EC might want to revisit the issue of ARRL's response to this Report and Order. There is time to consider this. A Petition for Reconsideration is due within 30 days of the date of publication of the Order in the Federal Register, which of course has not yet occurred and may not for a few weeks. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD(a)ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ <dsumner(a)arrl.org> To: arrl-odv <arrl-odv(a)reflector.arrl.org> Sent: Mon, Nov 8, 2010 12:48 pm Subject: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order I have read this over. The only possibly controversial parts that I have spotted are: 1. Club station trustees are limited to being trustee for one club. Present trustees are grandfathered. (New 97.17(d)). 2. The R&O says (paragraph 30) that clubs are limited to one vanity call sign, with existing holders grandfathered. However, as I read the rules as adopted, the FCC is assuming that a club can only name one person as a club station trustee. There appears to be a loophole that will permit a club to apply for multiple vanity call signs if they appoint multiple trustees. (Note to Chris Imlay: Chris, am I reading new 97.19(a) correctly? It looks badly worded to me.) 3. Unrelated to vanity call signs, the FCC chose to use this proceeding to delete the rule pertaining to RACES stations – which makes sense since there are no longer any RACES station licenses, but which probably will set off a flurry of comment that “the FCC has killed RACES.” 4. None of our proposals to expand the pools of available call signs were adopted, nor was our proposal to limit vanity call signs to U.S. citizens. Dave K1ZZ From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org <mailto:dsumner@arrl.org?> ] Sent: Monday, November 08, 2010 11:49 AM To: arrl-odv Subject: [arrl-odv:19506] Vanity call sign Report and Order I haven’t read this yet. Dave <<FCC-10-189A1.pdf>>

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Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order
by Chris Imlay 09 Nov '10

09 Nov '10

True enough, the same trustee using multiple FRNs would be in violation of the new rules, but it might be less easy than you think to catch them at it. Chris Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD(a)ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ <dsumner(a)arrl.org> To: arrl-odv <arrl-odv(a)reflector.arrl.org> Sent: Tue, Nov 9, 2010 9:56 am Subject: RE: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order Thanks, Chris. While a trustee might be able to fool the system into accepting an application for an additional club vanity call sign, my reading of 97.19(a) is that the trustee would not be eligible for the second club vanity call and the FCC could pull it after it was issued. Given the number of watchdogs looking for vanity call sign abuses, such a violation would not go undetected for long. However, I see nothing in the rules to prevent a club from having multiple trustees. Dave From: Chris Imlay [mailto:w3kd@aol.com] Sent: Tuesday, November 09, 2010 9:27 AM To: arrl-odv Subject: Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order Yes, Dave, Section 97.19 IS badly worded. And there are actually two loopholes that would allow a club to have an unlimited number of club call signs despite the language in that revised Section and Section 97.17(d) as amended by the Order. Here's why: (1) a club could simply have multiple trustees, as you note; or (2) the same trustee could get multiple FRNs and use his or her own name multiple times. The ULS goes by FRN, not name, because licensees can have the same name and be two different persons. You can have multiple FRNs for the same Social Security Number or EIN (I know this because I do, and so do some of my clients). So, in order to fool the ULS (though perhaps not its successor, the consolidated database system now under development) it is easy to register for any number of FRNs and therefore any number of club licenses. As to the FCC's rather brusque dismissal of ARRL's proposals to increase the availability of Group A callsigns and other helpful proposals, the Executive Committee discussed, since we knew in advance that FCC was going to not adopt our proposals, how to respond. We discussed the two alternatives, depending on how the FCC addressed our proposals. If they simply said they were beyond the scope of the rulemaking, we would consider filing a separate petition for issuance of further rulemaking or a stand-alone petition. However, if the FCC dealt with our proposals substantively, we would have no choice but to either (1) forget it, or (2) file a Petition for Reconsideration. Since the FCC did in fact deal with our proposals in a substantive manner (albeit tersely and summarily, and in my view not well) we can either abandon the proposals or file a Petition for Reconsideration. The politics of the matter do not seem overly favorable to us, but now that this order is out, perhaps the EC might want to revisit the issue of ARRL's response to this Report and Order. There is time to consider this. A Petition for Reconsideration is due within 30 days of the date of publication of the Order in the Federal Register, which of course has not yet occurred and may not for a few weeks. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD(a)ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ <dsumner(a)arrl.org> To: arrl-odv <arrl-odv(a)reflector.arrl.org> Sent: Mon, Nov 8, 2010 12:48 pm Subject: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order I have read this over. The only possibly controversial parts that I have spotted are: 1. Club station trustees are limited to being trustee for one club. Present trustees are grandfathered. (New 97.17(d)). 2. The R&O says (paragraph 30) that clubs are limited to one vanity call sign, with existing holders grandfathered. However, as I read the rules as adopted, the FCC is assuming that a club can only name one person as a club station trustee. There appears to be a loophole that will permit a club to apply for multiple vanity call signs if they appoint multiple trustees. (Note to Chris Imlay: Chris, am I reading new 97.19(a) correctly? It looks badly worded to me.) 3. Unrelated to vanity call signs, the FCC chose to use this proceeding to delete the rule pertaining to RACES stations – which makes sense since there are no longer any RACES station licenses, but which probably will set off a flurry of comment that “the FCC has killed RACES.” 4. None of our proposals to expand the pools of available call signs were adopted, nor was our proposal to limit vanity call signs to U.S. citizens. Dave K1ZZ From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org] Sent: Monday, November 08, 2010 11:49 AM To: arrl-odv Subject: [arrl-odv:19506] Vanity call sign Report and Order I haven’t read this yet. Dave <<FCC-10-189A1.pdf>>

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RE: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order
by Sumner, Dave, K1ZZ 09 Nov '10

09 Nov '10

Thanks, Chris. While a trustee might be able to fool the system into accepting an application for an additional club vanity call sign, my reading of 97.19(a) is that the trustee would not be eligible for the second club vanity call and the FCC could pull it after it was issued. Given the number of watchdogs looking for vanity call sign abuses, such a violation would not go undetected for long. However, I see nothing in the rules to prevent a club from having multiple trustees. Dave From: Chris Imlay [mailto:w3kd@aol.com] Sent: Tuesday, November 09, 2010 9:27 AM To: arrl-odv Subject: Re: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order Yes, Dave, Section 97.19 IS badly worded. And there are actually two loopholes that would allow a club to have an unlimited number of club call signs despite the language in that revised Section and Section 97.17(d) as amended by the Order. Here's why: (1) a club could simply have multiple trustees, as you note; or (2) the same trustee could get multiple FRNs and use his or her own name multiple times. The ULS goes by FRN, not name, because licensees can have the same name and be two different persons. You can have multiple FRNs for the same Social Security Number or EIN (I know this because I do, and so do some of my clients). So, in order to fool the ULS (though perhaps not its successor, the consolidated database system now under development) it is easy to register for any number of FRNs and therefore any number of club licenses. As to the FCC's rather brusque dismissal of ARRL's proposals to increase the availability of Group A callsigns and other helpful proposals, the Executive Committee discussed, since we knew in advance that FCC was going to not adopt our proposals, how to respond. We discussed the two alternatives, depending on how the FCC addressed our proposals. If they simply said they were beyond the scope of the rulemaking, we would consider filing a separate petition for issuance of further rulemaking or a stand-alone petition. However, if the FCC dealt with our proposals substantively, we would have no choice but to either (1) forget it, or (2) file a Petition for Reconsideration. Since the FCC did in fact deal with our proposals in a substantive manner (albeit tersely and summarily, and in my view not well) we can either abandon the proposals or file a Petition for Reconsideration. The politics of the matter do not seem overly favorable to us, but now that this order is out, perhaps the EC might want to revisit the issue of ARRL's response to this Report and Order. There is time to consider this. A Petition for Reconsideration is due within 30 days of the date of publication of the Order in the Federal Register, which of course has not yet occurred and may not for a few weeks. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD(a)ARRL.ORG -----Original Message----- From: Sumner, Dave, K1ZZ <dsumner(a)arrl.org> To: arrl-odv <arrl-odv(a)reflector.arrl.org> Sent: Mon, Nov 8, 2010 12:48 pm Subject: [arrl-odv:19507] RE: [arrl-odv:19506] Vanity call sign Report and Order I have read this over. The only possibly controversial parts that I have spotted are: 1. Club station trustees are limited to being trustee for one club. Present trustees are grandfathered. (New 97.17(d)). 2. The R&O says (paragraph 30) that clubs are limited to one vanity call sign, with existing holders grandfathered. However, as I read the rules as adopted, the FCC is assuming that a club can only name one person as a club station trustee. There appears to be a loophole that will permit a club to apply for multiple vanity call signs if they appoint multiple trustees. (Note to Chris Imlay: Chris, am I reading new 97.19(a) correctly? It looks badly worded to me.) 3. Unrelated to vanity call signs, the FCC chose to use this proceeding to delete the rule pertaining to RACES stations – which makes sense since there are no longer any RACES station licenses, but which probably will set off a flurry of comment that “the FCC has killed RACES.” 4. None of our proposals to expand the pools of available call signs were adopted, nor was our proposal to limit vanity call signs to U.S. citizens. Dave K1ZZ From: Sumner, Dave, K1ZZ [mailto:dsumner@arrl.org <mailto:dsumner@arrl.org?> ] Sent: Monday, November 08, 2010 11:49 AM To: arrl-odv Subject: [arrl-odv:19506] Vanity call sign Report and Order I haven’t read this yet. Dave <<FCC-10-189A1.pdf>>

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