ODV,
There are a number of unhappy members in the Delta
Division right now concerning the "strict" interpretation of 97.113 by Bill
Cross, etc. For example, over the past several years a lot of hospital
employees (particularly in AR, but also in LA, MS, and TN) have received their
ham tickets with an obvious eye toward emcomm operations "on behalf" of their
employers. In addition, I've heard from disgruntled ARRL
members who are either professionally employed in emergency management or
closely allied with such organizations. One emcomm manager in TN (who also
happens to be a Delta Division Assistant Director) has directly told me that he
will use MARS rather than ARES until/unless this issue is resolved.
At this time I would like to see more flexibility as
outlined in Option C (Expanded Training Option) on page 3 in the Options
paper. However, I would also suggest that some time limitations be
included with this option in a similar spirit as found in 97.407(e)(4) for RACES
tests and drills. For example, an amateur participating in emergency
tests and drills "on behalf of an employer" should be limited to one
hour per week or a total of 72 hours per year. (We can debate the best
choice of numbers later.) A time limitation along these lines
would help minimize the risk that businesses would use amateur radio
for inappropriate purposes.
I look forward to hearing the thoughts from other Board
members on this issue!
73, Mickey K5MC
----- Original Message -----
Sent: Monday, December 28, 2009 3:18
PM
Subject: [arrl-odv:18367] Options paper,
Section 97.113
Item 10.d. on the draft agenda
for next month’s Board
meeting is the development of the ARRL position on possible amendment
of the FCC rules concerning
pecuniary interest and communications on behalf of one’s employer (Section 97.113). To assist the Board in its
deliberations the Executive Committee requested that an options paper be
prepared. General Counsel Imlay and Regulatory Information Manager Henderson
developed an excellent
paper, which is attached for your review.
There will be ample opportunity
for discussion of the issues addressed in this paper at the meeting, but of
course any consideration that you can give to them in advance of the meeting
will facilitate the
Board’s work.
73,
David Sumner,
K1ZZ
Secretary
<<97.113 Options FINAL.doc>>