My comments on FCC-10-189A1 (WT 09-209)

Para 34 says:

34. Decision. We decline to make additional call signs available to the sequential call sign
system. As noted above, millions of call signs are presently available to amateur stations. We believe,
therefore, that a sufficient number of call signs is available for an amateur service licensee to obtain a
vanity call sign that is acceptable to him or her. Additionally, we note that ARRL's requests would not
substantially increase the availability of call signs of the format,
i.e., one-by-two call signs (i.e. , call signs
consisting of one letter, followed by a numeral, followed by two letters), that experience has shown to be
most desired by amateur radio operators.

This is a flawed response by the FCC.  There are no other ways to make more 1x2 callsigns available.  We should document how many 1x2 callsigns are held by non-USA residents.  It will only grow over time.  At some point it will matter to more people.   We should not underestimate the impact.  Yes, it sounds xenophobic but it isn't, unless we really want the USA to be the defacto licensing and callsign authority for the world, and if we are willing to see the pool of preferred callsigns available to US residents continue to shrink.

But, I don't think we can prevail in a request for reconsideration.   On the other hand, I think we can raise the issue and at least put something in the record indicating how widespread the problem already is in some places (offshore USA regions).

    -- Tom

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e-mail: k1ki@arrl.org   ARRL New England Division Director  http://www.arrl.org/
Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093 Phone: 860-668-5444