My description of the history of the ARRL proposal for a lifetime operator's license was incomplete. Our petition, RM-8418, was incorporated in an FCC "omnibus" proceeding, WT Docket No. 95-57. In the NPRM the FCC offered an alternative proposal, namely that the holder of an expired license could apply to a VE team for examination credit for the examination elements previously passed. In our comments the ARRL argued that the Communications Act did not allow the delegation of what amounted to the renewal of a license. In its Report and Order issued April 1, 1997 the Commission did not address that argument but cited general opposition in deciding not to adopt its own proposal. Here is the relevant excerpt from the 1997 R&O. It will be interesting to see if anything has changed in 14 years. Dave E. Examination Credit 17. Proposal. Our Notice proposed to allow examination credit for persons whose amateur operator licenses have lapsed. Our objective was to encourage former amateur operators to become involved again in the opportunities provided by the amateur service. We proposed to authorize VEs to give examination element credit for any examination that the examinee previously passed in obtaining a license formerly held. We also solicited comments concerning the criteria that we should use to allow any other qualified persons similarly situated (such as former and current holders of other types of operator licenses issued by the Commission, other United States government agencies, and foreign governments) to obtain examination credit, without examination, for licenses previously or currently held. 18. Comments. The comments generally oppose allowing examination credit for amateur operator licenses formerly held. Gary David Gray, however, states that such examination credit would benefit his friend who passed an operator license examination in 1931, but inadvertently allowed the license to lapse years later and now has difficulty in taking examinations. In opposing the proposal, Richard A. Stalls argues that persons who do not renew their operator licenses within the two-year grace period following the expiration will probably never do so. He points out that renewal of an amateur operator/station license is required only every ten years and is a process that should take no longer than five-minutes to complete. Further, he states that, even if they do file belatedly, it is not likely that they will have maintained an acceptable level of expertise. Winford H. Guin also opposes our proposal. He states that the fact amateur operators are not retested for license renewal cannot be equated with relicensing persons who were tested many years ago. He argues that the level of knowledge of the Commission's rules by the two groups would not be comparable. In lieu of the Commission's proposal to give examination credit, ARRL suggests that the operator license be valid for the lifetime of the holder. No comments addressed the matter of allowing examination credit for other types of licenses held. 19. Discussion. In view of the opposition expressed in the comments, we decline to adopt our proposal to give examination credit for licenses formerly held. Persons who allow their amateur operator license to expire will have to pass the requisite examinations if they later decide to obtain another amateur operator license. We do not believe that attending an examination session is a hardship. The VEs provide abundant examination opportunities. They must, moreover, accommodate an examinee whose physical disabilities require a special examination procedure, including administering examinations in the home. 20. We believe that our procedures provide ample notification and opportunity for license renewal. The license expiration date is shown on our licensee data base, so that it can obtained through the Internet even if the license document is lost. Providers in the private sector often use this information to remind licensees that expiration is about to occur. For those persons who inadvertently fail to renew, a two-year grace period is allowed. At the conclusion of the grace period, the record of the former licensee is purged from the data base and the call sign becomes available for reassignment in the vanity call sign system. Further, we have made the license renewal process as simple as possible by expanding our electronic filing procedures to include license renewal. With respect to the lifetime operator license suggestion, the operator would still have to renew the station license every ten years. We would, therefore, have to develop and maintain a separate data base specifically for the purpose of maintaining indefinitely records of amateur operators who allow their station license to expire. It would not be in the public interest to expend resources for such increased record retention.