CONFIDENTIAL ODV Kermit et al, I had a brief call with Barry and Maria last week on this issue. There have been multiple email requests, including some directly to the FCC. That being said, the COVID-19 problem such that it prevents even small test sessions in some states is estimated to last for up to 3 months, before significant (maybe not all) relaxation of social distancing recommendations. That’s what I understand, anyways, of course, who knows? Some restrictions are likely for up to an additional year or until a vaccine is in general use. What specific regulation would you (or anyone on ODV) suggest be waived, and is the substantial time and effort required by staff to re-jigger the testing worth the investment at a time when the staff is under substantial stress already with headquarters being completely closed tomorrow -- if some our VEs even might be interested in participating at a time of stress in their own lives? And exactly would be the need justification? I do want to note several things: 1. remote testing already is authorized in the FCC’s rules, and has been since 2014. 2. I will be talking with the FCC staff this week, as I have on the past week, including on this issue. Yes, they are willing to consider a waiver – what would you waive and then how would you conduct examinations? You most definitely do not want to ask and obtain a waiver, then not use it. Maria, Barry, and I discussed this last week and concluded that an awful lot of time and effort would be needed to get something going, among everything else going on, and this hopefully is a short-time need. There is no off-the-shelf solution at HQ VEC as I understand it, and cobbling something together will take a lot of time and effort for what looks like a fairly short-term problem. 3. On the longer term, my understanding is that the ARRL has been planning to implement a remote testing option for some time. A contract was let last year and the staff already is in the process of working with the contractor to implement remote testing. This project is intended to be ready the end of this year or early next year. It might make more sense to see if in this environment it is possible to speed this work and, in turn, assure those seeking exams that the League already has been working on remote exams and that if the crisis that prevents even small gatherings continues for an extended period, we hope to roll something out by ______. (September?) On the other hand, if someone has a readily-implementable solution that the HQ VEC believes workable, then it could be tried. I also want to note that from I can tell, no other VEC offers remote exams and do not seem to be working on remote exams. Alaska VEC is an exception which we all understand given the geography and population of that State. One last note: the ARRL in fact has worked to provide remote testing when justified, including in Antarctica, a remote island in Hawaii, and Japan. There may be others, I’m not sure. 73, Dave David R. Siddall Managing Partner DS Law, PLLC 1629 K St. NW, Ste 300 Washington, DC 20006 direct: +1 202 559 4690 Unauthorized Disclosure Prohibited. This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you. From: arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> Reply-To: Kermit Carlson <w9xa@yahoo.com> Date: Sunday, March 22, 2020 at 1:36 PM To: "rjairam@gmail.com" <rjairam@gmail.com>, ODV <arrl-odv@arrl.org> Subject: [arrl-odv:29914] Re: Remote VE testing Hello All, I have had similar requests made from Central Division members directly to Maria Somma, but I have not yet seen a response. This would definitely be in the VECC ‘s “wheelhouse” for all of the VEC’s. With the ”shutdown” status of the Gettysburg office, where all staff is working from home, for actual official database enries processes might not be something that can be run remotely. I would assume that the efficiency of accommodating special temporary requests such as this also might not be a “fit” for the expected timeline of the government office ”shutdowns”. Perhaps Mr. Sidall might have some insight as to whether he feels an approach to the Commission for special rules at this time is appropriate and if the establishment a remote test proctoring procedure has a reasonable chance of being established. 73, Kermit W9XA Sent from Yahoo Mail for iPhone<https://overview.mail.yahoo.com/?.src=iOS> On Sunday, March 22, 2020, 11:20, rjairam@gmail.com <rjairam@gmail.com> wrote: So when I asked Barry about this individually he did say that right now he is dealing with HQ emergency operational issues. But he also did say this: “ If you want to investigate it, please do so but I would like to be kept in the loop. Please understand all the FCC requirements and what I will call “chain of evidence” type procedures we use to insure the propriety of the exams and the examinees. I realize there are other FCC exams that are given remotely as testingfacilities which, in this case, may be closed as well. I know what people want, they want to sit at home with no proctors and be able to take the exam at their computer or tablet. Not something that can be made to happen in the timeframes in which they want it to happen.” Someone has proposed a solution: https://n0ssc.com/posts/1033-trying-to-take-a-ham-radio-license-exam-sorry-w... Ignore the bashing and other commentary. The 9 step plan is what I’m interested in. Is anyone on the board or other (committee) willing to get something together so this could be implemented? Ria N2RJ On Wed, Mar 18, 2020 at 7:40 PM rjairam@gmail.com<mailto:rjairam@gmail.com> <rjairam@gmail.com<mailto:rjairam@gmail.com>> wrote: Anchorage VEC is doing it. Why can't we? https://kl7aa.org/vec/remote-testing/ 73 Ria, N2RJ _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv

Hi David (and Barry and Rick) - "It might make more sense to see if in this environment it is possible to speed this work and, in turn, assure those seeking exams that the League already has been working on remote exams and that if the crisis that prevents even small gatherings continues for an extended period, we hope to roll something out by ______. (September?) On the other hand, if someone has a readily-implementable solution that the HQ VEC believes workable, then it could be tried." I think this is excellent. If someone could share this plan with us, I would like to see it. "no other VEC offers remote exams and do not seem to be working on remote exams. Alaska VEC is an exception which we all understand given the geography and population of that State." This is true of amateur exams ( Anchorage VEC). However, commercial exams are given online all the time, in fact even GROL can be taken online now: https://inarte.org/fcc-licensing-exams/ 73 Ria, N2RJ On Sun, 22 Mar 2020 at 18:28, david davidsiddall-law.com < david@davidsiddall-law.com> wrote:

*CONFIDENTIAL ODV*

Kermit et al,

I had a brief call with Barry and Maria last week on this issue. There have been multiple email requests, including some directly to the FCC.

That being said, the COVID-19 problem such that it prevents even small test sessions in some states is estimated to last for up to 3 months, before significant (maybe not all) relaxation of social distancing recommendations. That’s what I understand, anyways, of course, who knows? Some restrictions are likely for up to an additional year or until a vaccine is in general use.

What specific regulation would you (or anyone on ODV) suggest be waived, and is the substantial time and effort required by staff to re-jigger the testing worth the investment at a time when the staff is under substantial stress already with headquarters being completely closed tomorrow -- if some our VEs even might be interested in participating at a time of stress in their own lives? And exactly would be the need justification?

I do want to note several things:

1. remote testing already is authorized in the FCC’s rules, and has been since 2014. 2. I will be talking with the FCC staff this week, as I have on the past week, including on this issue. Yes, they are willing to consider a waiver – what would you waive and then how would you conduct examinations? You most definitely do not want to ask and obtain a waiver, then not use it. Maria, Barry, and I discussed this last week and concluded that an awful lot of time and effort would be needed to get something going, among everything else going on, and this hopefully is a short-time need. There is no off-the-shelf solution at HQ VEC as I understand it, and cobbling something together will take a lot of time and effort for what looks like a fairly short-term problem. 3. On the longer term, my understanding is that the ARRL has been planning to implement a remote testing option for some time. A contract was let last year and the staff already is in the process of working with the contractor to implement remote testing. This project is intended to be ready the end of this year or early next year. It might make more sense to see if in this environment it is possible to speed this work and, in turn, assure those seeking exams that the League already has been working on remote exams and that if the crisis that prevents even small gatherings continues for an extended period, we hope to roll something out by ______. (September?) On the other hand, if someone has a readily-implementable solution that the HQ VEC believes workable, then it could be tried.

I also want to note that from I can tell, no other VEC offers remote exams and do not seem to be working on remote exams. Alaska VEC is an exception which we all understand given the geography and population of that State.

One last note: the ARRL in fact has worked to provide remote testing when justified, including in Antarctica, a remote island in Hawaii, and Japan. There may be others, I’m not sure.

73, Dave

*David R. Siddall*

*Managing Partner*

*DS Law, PLLC*

*1629 K St. NW, Ste 300*

*Washington, DC 20006*

*direct: +1 202 559 4690*

[image: Default Line]

*Unauthorized Disclosure Prohibited.* This e-mail is intended solely for the intended recipient(s) and may contain information that is proprietary, confidential or privileged. If you are not the intended recipient, it is prohibited to disclose, copy, distribute, or use the contents of this email and its attachments. If you received this e-mail in error, please notify the sender by reply e-mail and destroy all electronic and physical copies of the e-mail message and its attachments. Unintended transmission shall not constitute waiver of attorney-client or any other privilege. Thank you.

*From: *arrl-odv <arrl-odv-bounces@reflector.arrl.org> on behalf of Kermit Carlson via arrl-odv <arrl-odv@reflector.arrl.org> *Reply-To: *Kermit Carlson <w9xa@yahoo.com> *Date: *Sunday, March 22, 2020 at 1:36 PM *To: *"rjairam@gmail.com" <rjairam@gmail.com>, ODV <arrl-odv@arrl.org> *Subject: *[arrl-odv:29914] Re: Remote VE testing

Hello All,

I have had similar requests made from Central Division members directly to Maria Somma, but I have not yet seen a response.

This would definitely be in the VECC ‘s “wheelhouse” for all of the VEC’s.

With the ”shutdown” status of the Gettysburg office, where all staff is working from home, for actual official database enries processes might not be something that can be run remotely. I would assume that the efficiency of accommodating special temporary requests such as this also might not be a “fit” for the expected timeline of the government office ”shutdowns”.

Perhaps Mr. Sidall might have some insight as to whether he feels an approach to the Commission for special rules at this time is appropriate and if the establishment a remote test proctoring procedure has a reasonable chance of being established.

73, Kermit W9XA

Sent from Yahoo Mail for iPhone <https://overview.mail.yahoo.com/?.src=iOS>

On Sunday, March 22, 2020, 11:20, rjairam@gmail.com <rjairam@gmail.com> wrote:

So when I asked Barry about this individually he did say that right now he is dealing with HQ emergency operational issues.

But he also did say this:

“ If you want to investigate it, please do so but I would like to be kept in the loop. Please understand all the FCC requirements and what I will call “chain of evidence” type procedures we use to insure the propriety of the exams and the examinees. I realize there are other FCC exams that are given remotely as testingfacilities which, in this case, may be closed as well. I know what people want, they want to sit at home with no proctors and be able to take the exam at their computer or tablet. Not something that can be made to happen in the timeframes in which they want it to happen.”

Someone has proposed a solution:

https://n0ssc.com/posts/1033-trying-to-take-a-ham-radio-license-exam-sorry-w...

Ignore the bashing and other commentary. The 9 step plan is what I’m interested in.

Is anyone on the board or other (committee) willing to get something together so this could be implemented?

Ria

N2RJ

On Wed, Mar 18, 2020 at 7:40 PM rjairam@gmail.com <rjairam@gmail.com> wrote:

Anchorage VEC is doing it. Why can't we?

https://kl7aa.org/vec/remote-testing/

73 Ria, N2RJ

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