GEPS
AND GAPS
John B. Johnston, W3BE
FCC rule Section
97.101(a) says that in all respects not specifically covered by FCC Rules each amateur station must be operated in accordance
with good engineering and good amateur practice. This file is a collection of W3BE’s good engineering practices (“GEPs”)
and good amateur practices (“GAPs”) most of which have appeared in the column THE RULES SAY… .
C1. Read the rules – Heed the rules. Read BE Informed No. 18 Arguments For Complying With The United States Code of Federal Regulations Title
47 Part 97 Amateur Radio Services Rules.
C3. The FCC rules mean what they say.
C4. No contest rule can legitimately override
the FCC rules for our amateur service as codified in the United States Code of Federal Regulations.
C5. Attaining a respectable compliance level depends first upon
the self-policing effort within our amateur service community.
C6. The extensive privileges afforded to our amateur
service are attributable to the reputation it has earned for self-enforcement in the past.
C7. The FCC cannot be faulted for assuming that
we comprehend that rule observance is in our own best interest.
C8. Amateur Auxiliary Official Observers should have begun doing whatever needs to be done in order to encourage rule compliance
on March 28, 1983, when the Agreement Between The ARRL And The FCC With Respect To Amateur Volunteers was signed. Read BE Informed No. 26.
C9. Our highly accommodating rules are irresistibly
tempting to those who would misuse our privileges.
C10. A un-monitor-able communication system
practically invites abuse by those persons having a need for free unchecked stealth communications.
C11. Whenever you become aware of a station
transmitting on the amateur service bands without the authority of an amateur station license grant, call the FCC at 717-338-2502
pronto.
C12. The station licensee must use caution
when designating the station control operator.
C13. Always rely upon the ULS; an official-looking
copy of almost any document can be forged easily.
C14. Ham radio is unbelievably resilient
and has many dedicated hams who are deeply concerned for its continued wellbeing.
C15. Those assaults on the necessity for a FCC-licensed
station control operator (SCO) may just be an expression of a fundamental disagreement with the need for every SCO to qualify
for privileges by examination and/or with our frequency-based-incentive operator license class structure. The danger in these
tactics is that they conflict with the very purpose for our spectrum allocation. In fact, it undercuts the justification for
any amateur radio service whatsoever.
C16. While an untarnished record of strict compliance with the rules might not necessarily guarantee the future of our amateur
service, it sure can’t hurt. Just the perception that our amateur service is un-regulatable might be all that is needed
to do it in. Read BE Informed No. 24 We Are Regulatable (Aren’t we?)
FR1. In many countries, amateur radio is considered to be a form of recreation. In the places where the FCC regulates
the amateur radio and amateur-satellite services, however, the rules are designed to provide an amateur radio service having
a fundamental purpose as expressed in the following principles: Recognition and enhancement of the value of the amateur service
to the public as a voluntary noncommercial communication service, particularly with respect to providing emergency communications;
Continuation and extension of the amateur's proven ability to contribute to the advancement of the radio art; Encouragement
and improvement of the amateur service through rules which provide for advancing skills in both the communication and technical
phases of the art; Expansion of the existing reservoir within the amateur radio service of trained operators, technicians,
and electronics experts; and Continuation and extension of the amateur's unique ability to enhance international goodwill.
Read United States Code of Federal Regulations Title 47, Part 97 Section 97.1.
FR2. The station license is analogous to a vehicle registration,
with the license plate characters being similar to a radio station call sign.
FR3. The amateur operator license is analogous to a driver’s
license.
FR4. An amateur service license grant must be
exposed to scrutiny; it is listed on public data base records such that the entity accountable can be determined.
FR5. Amateur stations and control operators are regulated. Read BE Informed No. 1 W3BE Checklists. Any system of amateur stations is permissible as long as each
individual amateur station and its control operator are in compliance.
FR6. In Sections 97.313(b) through (h) where it says that no station may transmit with a transmitter
power exceeding a certain number of watts for various combinations of control operator class, frequency bands and segments
and locations, good amateur practice considers that a transmitter is all of the apparatus that produces and modulates an RF
signal on one channel for conveyance to an antenna system.
LICENSE QUALIFICATION SYSTEM
LQS1. The purpose of a written examination must
be such as to prove that the examinee possesses the operational and technical qualifications required to perform properly
the duties of an amateur service licensee having the privileges of the class of license sought. Read Section 97.503.
LQS2. The VECs are challenged indeed by our
license structure wherein the privileges of three classes of operator privileges are largely identical. The VECs should come
together with a common understanding on the purpose for each class of operator license. They should then make their privilege
usage predictions for each operator class.
LQS3. The VECs should design carefully each
pool syllabus to verify that a successful examinee has (1) a working understanding of all FCC rules commensurate with their
usage predictions; (2) a basic knowledge of the technology sufficient to make those rules meaningful; and (3) a reasonable
comprehension of the most-widely accepted good practices employed by our amateur service community.
LQS4. The VECs should they solicit questions from true no-conflict-of-interest
volunteer examiners, mounting a concerted effort to engage the support of our most qualified experts in the various fields.
LQS5. The VECs should not acquiesce to the publishers,
distributors and others who benefit monetarily from frequent revamping and making the pools obsolete.
LQS6. Any scheme to recruit into our hobby persons
who are not particularly interested in radio technique solely with a personal aim and without pecuniary interest or who are
disinclined toward self-training, intercommunication and technical investigations, is counterproductive to our radio service
serving its purpose - the very reason for our precious spectrum allocation. Read Section 97.3(a)(4).
LQS7. Upon establishing that an examinee has
passed an examination, the administering VEs should review the question set with the examinee, explaining carefully the background
of the correct answer to every question missed.
LQS8. The VECs should implement a system of reviewing questions
most often missed.
LQS9. VEs should not administer any defective question.
LQS10. Full disclosure of each VEC’s instructions to its
VEs would aid our VEs in making a more-informed decision when selecting which VEC they wish to have coordinating their examination
administering work.
LQS11. The only thing that we can blame upon
the FCC is for giving us exactly that for which we asked. The legitimacy of our hobby is now is in the hands of our amateur
service community.
LQS12. Before receiving an operator license
grant of any class, every examinee should know that no station may be automatically controlled while transmitting third party
communications, except a station transmitting a RTTY or data emission. All messages that are retransmitted must originate
at a station that is being locally or remotely controlled. This safeguard assures that third party messages are screened by
the control operator at the originating station before being allowed into our systems. Read Section 97.109(e).
LQS14. The VEs must not revise the answer to
any question without receiving instructions from the coordinating VEC to do so. There is no FCC requirement that the question
pools contain answers. It is the choice of the coordinating VEC, in its instructions to its administering VEs, as to whether
the VEs must administer any exam question in multiple-choice, essay, fill-in-the-blank or some other format. Read Section 97.507(c).
LQS15. No VE should administer defective, trick,
freebee or misleading questions. They should not administer any question that addresses privileges or duties that are not
committed to memory generally by amateur operators, but for which there are widely available references; example: frequency
bands and emission types charts. Suppliers of those charts obviously recognize that few of us memorize such detail for long.
LQS16. For any question set, the coordinating
VECs may revise any answer, correct or incorrect, offered in a question pool. The coordinating VEC may also instruct its VEs
to retain or revise any answer offered in a question pool. The coordinating VEC may choose to use, or not to use, any question
in the pool. Neither the administering VEs nor the VEC, however, may change the wording of any question they choose to use.
LQS17. For me - and probably most other hams who mastered the
arduous challenges of self-study for those serious examinations, taking time off from work, traveling to that imposing federal
building and qualifying under the icy scrutiny of that dispassionate professional FCC examiner - it is most disturbing and
saddening to observe our hobby being stripped of the mystique that has made those successes so meaningful to us.
LQS18. Taken together, the
technical content of Elements 2 and 3 is arguably appropriate. Element 2, however, is woefully inadequate on knowledge of our rules and technical understandings
necessary for the vast privileges granted to a Technician Class Operator. This practically guarantees that, in short order,
the vast majority of our amateur service community will be under-qualified for the privileges they are authorized. Further,
it supports the assertion that Element 3 is unnecessary because the differences in privileges between Technician and General
Class operators are so minimal.
LQS19. Element 3 is short on several topics that are also missing from Element 2. For example, here are a few taken from readers’ questions: Cooperation
in selecting transmitting channels; Duties of the control operator; Duties of the station licensee; Proper station identification
announcement; Reasons for knowing and observing the FCC rules; Responsibility for system operation; Self-assigned indicators; Third party communications;
Third party privileges.
LQS20. All VEs must keep a watchful
eye over their coordinating VEC. Your VEC is your coordinator, not your director. Demand an explanation as to why the previous
Technician Class operator question pool was terminated one year ahead of schedule, during the very period when pending major
rule amendments were anticipated, including the elimination of telegraphy skill. In its place came a greatly dumbed-down,
defective-question riddled, drive-thru-exam Element 2 pool. For an eye-opening report on how this disaster was accomplished,
e-mail: winguin@bellsouth.net. LQS21. The VECs’ venture into policy-making
committed to reinventing our hobby is one of the biggest stories in amateur radio history. They are observably bent on changing
amateur radio from “A radiocommunication service for the purpose of self-training, intercommunication and technical
investigations carried out by amateurs, that is, duly authorized persons interested in radio technique solely with a personal
aim and without pecuniary interest” into - as they petitioned the FCC to do in RM-10870 - something that makes “…
the amateur service accessible to as many citizens as possible.”
LQS22. Although the FCC denied their request,
the VECs have pursued the same objective. Quickie cram sessions are now replacing serious learning. Practically all of the
Technician Operator Class examinations administered by our VE team are successful. One examinee even passed after one-hour
of “study.”
LQS23. Here’s hoping that every person
on the planet for whom our spectrum is allocated goes on to qualify for an amateur operator license and utilizes our spectrum
for doing that for which it was allocated. LQS24. VEs and VECs are limited to accepting reimbursement by examinees for out-of-pocket
expenses incurred in preparing, processing, administering, or coordinating an examination for an amateur operator license.
There is, however, no limit on the fees charged by a renewal serviced provider for its non-examination services. None of these
fees, moreover, go to the FCC. Read Section 97.527.
OTA1. Making proper station identification announcements is the key to maintaining a legitimate
amateur radio service. Read BE Informed No. 14 About That Station Identification.
OTA2. Ham radio needs a set of good amateur practices; don’t count on the FCC telling us what they are.
OTA4. Don’t let your actions bolster the spectrum sharks’ arguments.
OTA3. The test of whether certain communications are appropriate for the amateur radio and amateur-satellite services is their
consistency with the service’s purpose of self-training, intercommunication and technical investigations carried out
by amateurs, that is, duly authorized persons interested in radio technique solely with a personal aim and without pecuniary
interest. Read Section 97.3(a)(4).
OTA5. Listen on a channel before causing or allowing the station to transmit thereon. Read Section 97.101.
OTA6. Our amateur service seems to best provide the public with emergency communications through our ad hoc networks using
our unique array of “abilities:” know-how capability, situational adaptability, technical flexibility, operator
availability, et al.
OTA7. RACES training drills and tests are not entitled to exclusive use of any spectrum. The participating stations have to
share with our amateur stations the spectrum allocated to our amateur service. Rather than load our allocation with government
communications, the wiser model to follow is that employed by the Military Affiliate Radio System wherein over 5,000 amateur
operators use their apparatus for transmitting on government channels.
OTA8. All repeater providers and users should participate actively in selecting the entity to do the coordinating for their
area.
OTA9. Our amateur service community seems to be having considerable difficulty in adapting to digital technology, particularly
with systems of stations. Read BE Informed No. 24 We Are Regulatable (Aren’t we?).
OTA10. No longer can any station licensee rely comfortably upon the fact that most of those receiving the transmissions are
capable of interpreting correctly Morse telegraphy signals into call signs. A good pre-programmed station “IDer”
device should do as well, if not much better, than any control operator could possibly do in timing and generating the station
identification announcements.
OTA11. Analyzing a system for compliance is the sole responsibility of each user of a system. That is why it is so vitally
important that every station licensee and every control operator participating in the system read the rules and heed the rules.
BE Informed No. 1, W3BE Checklist, explains the duties of each party and can help guide you through
the rules.
OTA12. Un-policed repeaters, unfortunately, seem to attract hams looking for a venue to receive gratification from provoking
a confrontation trap. Repeaters offer such anti-social nerds a wonderful opportunity to annoy more of us simultaneously than
most of our other communications systems. Expert judgment must be used in deciding whether or not an over-the air confrontation
will improve the circumstances. Often, just ignoring someone of that demeanor is the better approach.
OTA13. Your approval for the exclusive use of certain channels must come from the amateur operators otherwise entitled to
them. Our repeater system channeling arrangement, for example, is based upon such a near-unanimous concession. Read Section
97.101.
OTA14. The word “point” (as in “control point) usually refers to a narrowly localized place having a precisely
indicated position. In this context, the control operator must be situated such as to be able to exercise proper judgment
while doing those things that the control operator does: view and interpret all indicators showing the status of the regulated
transmitting parameters; manipulate appropriately the apparatus dials and switches controlling of these parameters; ensure
that the message content of each transmission is appropriate for the amateur service; making certain that the channel is not
already occupied before transmitting; etc.
OTA15. No amateur station shall transmit communications, on a regular basis, which could reasonably be furnished alternatively
through other radio services. The terms “on a regular basis” and “reasonably,” require us to make
the judgments about how each communication our stations transmit reflects upon the legitimacy of our radio service. It is
risky to venture outside the purpose of our hobby by misusing our allocation to compete with the legitimate providers, many
of whom have paid billions of dollars for their spectrum allocation. Don’t compromise our argument for being allocated
free spectrum for our hobby. If telephone-type is the only communications that you do, then amateur radio is not for you.
Read BE Informed No. 3 Section 97.113 Smell Test.
OTA16. Steer clear of all use of the term broadcast. Section 97.3(a)(10) defines “broadcasting” to mean “transmissions intended for
reception by the general public, either direct or relayed.” Section 97.113(b) says that an amateur station shall not engage in any form of broadcasting. Adopt
the hamslanguage “hamcasting” to describe those one-way transmissions necessary to disseminate information bulletins
to amateur operators.
OTA17. It is only for the purpose of over-the-air station identification that the FCC assigns call signs – in accord
with international arrangements - and maintains the ULS data base from which our Official Observers and other listeners can
ascertain the identity of the station licensee and verify the class of operator license.
OTA18. Transmitting a proper station identification announcement is especially critical to our uniquely unstructured radio
service when it comes to creating and maintaining a culture of observing the FCC rules and using good amateur practices. Having
that capability is our major deterrent to would-be rule violators. It facilitates self-policing and discourages interference-causing
transmissions and annoying mischief-making because it exposes personal identities. It should never be compromised. It is basic
to our maintaining a high level of rule compliance and promoting proper and efficient use of our allocated spectrum.
OTA19. When you are the station control operator, don’t allow your third party message stating participant (TPMSP) to
key the mike, tap the keyer, use VOX, etc., unless you are convinced absolutely your TPMSP will do exactly as you intend.
The FCC granted the license to you because you qualified by passing the necessary examinations. You are the one with the privileges.
You cannot delegate your accountability for performing your SCO duties. When things go sour, you cannot pass the buck to the
TPMSP. Read BE Informed No. 69 Visiting Operator Rules.
OTA20. Our amateur service spectrum should not be used as a substitute for the spectrum allocated to the land mobile services
administered under Part 90; it should only be used for the purpose for which it was allocated.
OTA21. Although non-repeater transmissions are authorized in the various repeater sub-bands, it is good amateur practice for
such transmissions to generally give way to a repeater.
OTA22. Be extra careful when selecting your simplex channel within the repeater segments. To conduct simplex intercommunications
on a repeater input channel such that it creates interference is not cooperating in selecting transmitting channels and in
making the most effective use of our amateur service frequencies. Read Section 97.101(b).
OTA23. Every auxiliary station and every repeater should be coordinated.
OTA24. Every station should transmit its call sign early on during an inter-communication with an unfamiliar station. This
protocol assures the SCO of the other station that it is intercommunicating with another amateur station. Read Section 97.111(a)(1).
QTA25. To facilitate compliance, the control operator of one of the participating stations in a multi-station QSO should call
for a station break every 10 minutes to allow the stations to transmit their identification announcements.
OTA26. Know where the quiet zones are located and avoid transmissions being made by your amateur station from within those
zones where the rules indicate they could have a possible impact on the operations of radio astronomy or other facilities
that are highly sensitive to interference.
OTA27. Keep over-the-air tune-ups to a minimum and never on a channel while it is being used by other stations. Tune the transmitter
into a non-radiating dummy antenna. Adjust an antenna using a very low power SWR analyzer.
RULE MAKING PROCESS
RMP1.
All FCC amateur service licensees should participate in the rulemaking process.
RMP2. “How-to-ism” rules are inappropriate for our amateur
service.
RMP3. The only thing
that we can blame upon the FCC is for giving us exactly that for which we asked.
RMP4. Taking away frequency privileges for incentive licensing was outrageously unfair.
Stemming from the false premise that hams only upgrade in order to gain additional frequency privileges, incentive licensing
stands out as a historic monument to the gaffe that it is. Few hams upgrade in order to obtain more frequency privileges;
most upgrade to gain the respect of their fellow hams. The shorter station call signs help call attention to the holders
being an Amateur Extra Class operator licensee.
RMP5. Our amateur service community was led down the rocky "let’s have the government divide
up the bands into sub-bands for us" path-with-no-end that we are now traveling. Pay attention to the rulemaking
petitions as they are filed and submit your comments for the official record.
RMP6. In your rulemaking comments, address only the issues in the proposal.
In doing so, make certain that you:
A. File your comments before the deadline.
B. Do not claim that no one told you what was going. That only proves that you do not know what is going on.
C. Carefully check your spelling and grammar.
One of the most often misspelled words found in comments is the word amateur. It’s hard to accept as an expert
on the amateur service someone who can’t even spell it correctly. A large number of our comments appear to indicate
that the writers are overly anxious to demonstrate that they know the word contains the letter “u”. So they
move it forward a position or two.
D. Do not open your comments with, “I haven’t read your proposal, but… .” Be sure to
read the proposals carefully before commenting on them.
E. Do not restate the FCC proposals incorrectly. Although this approach
might appear to you as a clever way of moving the discussion to matters other than the actual proposals, it will probably
be ineffective.
F. Do not annoy
the FCC mailroom employees with QSL cards. Should the cards arrive in sufficient quantity to delay the distribution
of mail throughout the entire agency, you might succeed in annoying staff persons whose favorable attention the amateur service
might need some day. Employees do change positions, moving to other Bureaus in their climb up the career ladder.
G. Do not use a hysterical approach.
It doesn’t add to your credibility to describe how angry you are or to threaten to turn in your license.
H. Do not introduce your comments with salty,
uncomplimentary names for the FCC Commissioners or staff.
I. Do not include extraneous comments. The record
in an amateur service proceeding is not the place to let off steam about how you feel about taxes, potholes, speed limits,
etc.
●▬ ▬
●●●▬ ▬ ▬●●● ●
LICENSE QUALIFICATION SYSTEM
LICENSE QUALIFICATION SYSTEM
December 16, 2011
Supersedes
all prior editions