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BE Informed No. 61 Let's Go VE Green! John B. Johnston W3BE Q. Our VE system is woefully outdated. It is a paper-bound clerical-intensive artifact that wastes the time, talent and postage of our 32,000 volunteers. It is not representative of our technical expertise. It makes absolutely no use whatsoever of our ham radio knowhow. What rule changes are needed to go VE green, save some trees and free up the VEs so that they can get back to ham radio? A. The FCC is way ahead of us on this one. We already have all the authority we need to go paperless VE green. Q. What is the bottleneck? A. It is our own inertia. There is a prevailing misconstruction amongst our VEs that they must immerse themselves in an ocean of paper. In particular, they seem to believe that they must obtain for the FCC - on paper - the signature of each examinee, attesting to certain certification statements. Not so. The VEs don't have explicit FCC authority to do this. In fact, the FCC has not even accepted any such statements from our VEs or VECs for many years. The FCC VEC Electronic Batch Filing User Guide (BE Informed No. 63) specifies the data that the coordinating VEC must forward electronically to the FCC to satisfy the requirements of Section 97.519(b)(3). It establishes the scope of the necessary information to be collected by the VEs to satisfy the data forwarding requirements of Section 97.17(b)(1) and Section 1.913(f). The FCC Guide does not even make mention of the certification statements appearing on the widely-used NCVEC Form 605. Those papers, in actuality, simply dead-end with the coordinating VEC who is under no obligation to do anything with them. Q. How did that happen? A. Initially - circa 1983 - each examination candidate was required to sign similar certifications statements on FCC paper Form 610. When the examination was successful, the paper form was forwarded to the coordinating VEC who mailed it via the U.S. Postal Service to the FCC for staff review, and - if in proper order - processing took place and a license was granted. After about a decade of this snail-mail procedure - upon prodding from the VECs - the FCC initiated discussions with the VECs about forwarding only an electronic image of the form that would be reviewed and processed by the FCC staff the same as the paper form. The FCC, however, decided to forgo the review by its staff. Again at the urging of the VECs, the FCC implemented the current batch filing protocol whereby only the minimal data specified in the FCC Guide is compressed and forwarded by the VEC electronically to the FCC for license autogrant (posted to the ULS without FCC staff review). The certification statements obtained by those VEs who choose to use NCVEC Form 605 are not among those data specified in the FCC Guide or is it accepted by the FCC. For well over a decade, the system has apparently worked satisfactorily. There is clearly no specific direction from the FCC for the VEs to collect any certification statements. The FCC, in fact, will not accept them. Licenses are auto-granted to the ULS without them being reviewed by the FCC. Q. What must be done to go VE green with the application form? A. At each test session, the VEs should use personal computers to collect only the necessary information authorized for collection as stipulated by Section 97.17(b)(1) and the FCC Guide. The information should be formatted to the specifications in the FCC Guide for auto-transmittal to the coordinating VEC for auto-forwarding to the FCC. Key-stroking should be done at the source - while the examinee is at hand - rather than at the VEC, thus reducing the chance of errors.  The Dayton Amateur Radio Association LARC-VEC VE Team went green with laptop computers for compiling necessary data for 394 examinees at the 2010 Dayton Hamvention. One VE loaned four laptops to the team. Five examinees brought their own, including the one shown in the middle. Q. On the electronic batch filing there is a field, 605 signed, that we have to enter Y or N. I've never tried filing one with a N. What would happen if I do? A. It will probably bounce. Q. The question sets now require us to transport and safeguard boxes of paper. They limit the number of unique question sets that we can administer, and they consume much of our VEs' time to grade manually. How about going VE green with the question sets? A. That capability is available. For a preview of how it can, should, and likely will eventually be done, check out the numerous practice examinations available on internet sites that feature auto-assemblage of unique question sets taken from the question pools and instant auto-grading. W3BE-O-GRAM: For a report on the current process, read BE Informed No. 62, SO, I'M A VE, NOW WHAT? Q. Could our VE team administer a unique question set offered by a practice exam website - our 3 VEs would be present and observing - with the examinee using a pc connected to the internet? A. That's up to your coordinating VEC. Section 97.507(c) says that each question set must be prepared, or obtained from a supplier, by the administering VEs according to instructions from your coordinating VEC. Note also that Section 97.509(f)says that no examination that has been compromised shall be administered to any examinee. The same question set may not be re-administered to the same examinee. W3BE-O-GRAM: They should affirm that there is sufficient number of different question sets administrable so as to preclude your examinees from knowing in advance the exact set of questions they will be asked, or learn the answer key. Section 97.523 says that each question pool must contain at least 10 times the number of questions required for a single examination. There should be, therefore, sufficient questions to prepare at least 10 totally unique question sets. Q. Shouldn't the National Conference of Volunteer-Examiner Coordinators cooperate in maintaining a series of question sets on its website similar to those practice exams? A. Sounds like a great idea. It would help free up the VEs from so much clerical paper shuffling. Q. Could we use the auto-grade feature in the website exam question sets? A. Only where your team's administering VEs are in agreement with the correct answers used by the auto-grader. Section 97.509(g) says the administering VEs are responsible for determining the correctness of the examinee's answers. Section 97.523 says that all VECs must cooperate in maintaining one question pool for each written examination element. The VECs have chosen to use a multiple-choice format; they provide the correct answer and 3 incorrect answers for each question. Thus, the administering VEs do not have to rely upon their own ham radio expertise. W3BE-O-GRAM: No question set should contain defective questions. There is no legitimate justification for administering defection questions. Q. There is still that paper CSCE. What about getting rid of that? A. That would require rulemaking to delete Section 97.509(l) and amend Section 1.913(f). They say that the administering VEs must issue a CSCE to an examinee who scores a passing grade on an examination element. W3BE-O-GRAM: The usefulness of the CSCE for examination credit ended along with the CW requirement. Its usefulness in enabling operation with higher privileges while waiting for the license grant to appear on the ULS has diminished with the dramatic increase in speed of service. If deleted, many VE teams would probably continue to celebrate each successful examinee's achievement with some sort of recognition. Q. Why do some VEs believe they have to obtain the examinee's signature on the certification statements? A. Similar statements appear on FCC Form 605 which the FCC does accept and review. This FCC form, however, cannot be used in our volunteer examiner system. The lookalike, non-government, NCVEC Form 605 - that the FCC does not accept or review - somewhat parrots FCC Form 605. Q. What are those certification statements on NCVEC Form 605? A. There are six: I waive any claim to the use of any particular frequency regardless of prior use by license or otherwise. This statement is apparently based upon SEC. 304. [47 U.S.C. 304] of the Communications Act of 1934, as amended, which says that no station license shall be granted by the FCC until the applicant therefore shall have waived any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise. This statute is implemented in Section 97.303, frequency sharing requirements and in Section 97.101(b): No frequency will be assigned for the exclusive use of any station.W3BE-O-GRAM: The written examination is the appropriate method of determining whether or not the examinee is knowledgeable of these rules. All statements and attachments are true, complete and to the best of my knowledge and belief and are made in good faith. W3BE-O-GRAM: Having no statements or attachments render this text unnecessary. I am not a representative of a foreign government is apparently based upon SEC. 310. [47 U.S.C. 310] of the Communications Act of 1934, as amended. Paragraph (a) therein says that the station licensee required under this Act shall not be granted to or held by any foreign government or the representative thereof. This statute is implemented by Section 97.5(b)(1). It says that, except for a representative of a foreign government, any person who qualifies by examination is eligible to apply for an operator/primary station license grant. This is a matter between the FCC and said foreign representatives; most likely an extremely rare occurrence.I am not subject to a denial of Federal benefits pursuant to Section 5301of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 862 is one that probably should be codified in Part 97. This is a matter between the FCC and those subject to such denial; most likely an extremely rare occurrence. The construction of my station will NOT be an action which is likely to have a significant environmental effect (See 47 CFR Sections 1.1301-1.1319 and Section 97.13(a)) is likely based upon Section 97.13(a), although the latter does not mention Sections 1.1301, 1.1302, 1.1303, or 1.304. Section 97.13(a) says that before placing an amateur station on land of environmental importance or that is significant in American history, architecture or culture; the licensee may be required to take certain actions prescribed by Sections 1.1305-1.1319. W3BE-O-GRAM: An amateur station does not have a location of record on the ULS. Rather, restrictions on station location are regulated throughout its 10-year license term by Section 97.13 on a site-by-site basis. The written examination is the appropriate method of determining whether or not the examinee is knowledgeable of this rule. I have read and WILL COMPLY with Section 97.13(c) of the Commission's Rules regarding RADIOFREQUENCY (RF) RADIATION SAFETY and the amateur service section of OST/OET Bulletin Number 65 is probably based upon the assertion, on pages 15-18 in OST/OET Bulletin No. 65, that the FCC adopted a proposal from our amateur service community for amateur operators being required to certify, as part of their license application process, that they have read and understand our bulletins and the relevant FCC rules. There is, however, no such requirement codified in Part 97; Section 97.13(c)(2) simply makes reference to OET Bulletin No. 65. OST/OET Bulletin No. 65 is not a FCC Order. It is a highly technical dissertation containing analytical charts, graphs and formulas, necessitating that the reader have an extensive knowledge of theoretical physics and higher mathematics in order to read and understand it. To comply, one needs to know the definition and meaning of the terms ERP, PEP, W, watts, occupational/controlled MPE limits, general public/population/uncontrolled limits, and certain generic equations described in the Bulletin. W3BE-O-GRAM: The written examination is the more meaningful method of confirming that the examinee has practical working knowledge of RF radiation safety. There is no age limit to being an amateur radio operator. Persons as young as 5 years have passed the examination. It is foolhardy, therefore, to expect young children to certify to such a profound statement - or to anything else - for that matter. Q. Where will all of the personal computers come from? A. There should be an abundance of desktop, laptop, and netbook computers available within our techie amateur service community. The workload for these computers is decreasing dramatically as e-mail and hundreds of apps are being switched over to those ever more capable hand-held gadgets. It's likely that many of the examinees have access to a laptop or netbook that they could bring to the examination session. Wi-fi hotspots are becoming more and more prevalent. Q. Section 97.509(m) says that after the administration of a successful examination for an amateur operator license, the administering VEs must submit the application document to the coordinating VEC according to the coordinating VEC's instructions. Can't the VEs simply forward electronically directly from the exam room the information to the FCC? A. Not the VEs, as such; that forwarding to the FCC can only be done by the coordinating VEC. A VEC is, however - according to Section 97.521(a) - an organization that exists for the purpose of furthering the amateur service that has entered into an agreement with the FCC. An on-site designated member of the VEC organization, therefore, could avoid delay by forwarding electronically to the FCC the information as it becomes available. Q. Section 97.9(b) says the person named in an operator license grant of Novice, Technician, General or Advanced Class, who has properly submitted to the administering VEs a FCC Form 605 document requesting examination for an operator license grant of a higher class, and who holds a CSCE indicating that the person has completed the necessary examinations within the previous 365 days, is authorized to exercise the rights and privileges of the higher operator class until final disposition of the application or until 365 days following the passing of the examination, whichever comes first. Doesn't that prove that the examinee has to present a paper application to the VEs? A. No. That rule has to do with authorizing additional rights and privileges to a qualified control operator during the waiting period until an upgraded license is granted. See Section 97.119(f). The operative rule for filing an application for a new license grant is Section 97.17(b)(1). It says that each candidate for an amateur radio operator license which requires the applicant to pass one or more examination elements must present the administering VEs with all information required by the rules prior to the examination. The VEs may collect all necessary information in any manner of their choosing, including creating their own forms. W3BE-O-GRAM: That reference to FCC Form 605 in Section 97.9(b) probably needs an editorial amendment. Q. The term application is used in Sections 97.3, 97.9, 97.17, 97.19, 97.21, 97.207 and 97.509. That surely means that the VEs must use paper application forms. A. Not necessarily. The term application is used therein in the context of asking for permission in the form of a license grant. In Section 97.21, for example, it says expressly that for modification or renewal of a club, military recreation or RACES station license grant, the application must be presented in document form to a Club Station Call Sign Administrator who must submit the information thereon to the FCC in an electronic batch file. Similarly, in Section 97.509(j), it says that when the examinee does not score a passing grade on an examination element, the administering VEs must return the application document to the examinee and inform the examinee of the grade. In Section 97.509(m), it says that after the administration of a successful examination for an amateur operator license, the administering VEs must submit the application document to the coordinating VEC according to the coordinating VEC's instructions. These two rules, however, are obviously inconsistent with Section 97.17(b)(1) and Section 1.913(f). They both say that each application for a new amateur service license grant must be filed with the FCC as follows: Each candidate for an amateur radio operator license which requires the applicant to pass one or more examination elements must present the administering VEs with all information required by the rules prior to the examination. The VEs may collect all necessary information in any manner of their choosing, including creating their own forms. The other rules do not likewise specify a paper form. When the FCC's meaning is confined to a paper document, its rules so specify. Only for modification or renewal of a club or military recreation station license grant, therefore, is a paper document application required. Q. Doesn't Section 1.913 require there always a paper application form? A. No. That rule has to do with application and notification forms; electronic and manual filing. Section 1.913(f) specifically addresses applications for amateur licenses: Each candidate for an amateur radio operator license which requires the applicant to pass one or more examination elements must present the administering Volunteer Examiners (VE) with all information required by the rules prior to the examination. The VEs may collect the information required by these rules in any manner of their choosing, including creating their own forms. Upon completion of the examination, the administering VEs will immediately grade the test papers and will then issue a certificate for successful completion of an amateur radio operator examination (CSCE) if the applicant is successful. The VEs will send all necessary information regarding a candidate to the Volunteer-Examiner Coordinator (VEC) coordinating the examination session. Applications filed with the Commission by VECs must be filed electronically via ULS. All other applications for amateur service licenses may be submitted manually to FCC, 1270 Fairfield Road, Gettysburg, PA 17325-7245, or may be electronically filed via ULS. Feeable requests for vanity call signs must be filed in accordance with Section 0.401 of this chapter or electronically filed via ULS. (Emphasis supplied.) W3BE-O-GRAM: Let's go VE green. Free up our VEs to get back to ham radio and enjoying those improving sunspot cycle 24 HF propagation bands rather than shuffling and signing lots of paper. Remember: paper cuts can be painful!
December 20, 2010 Supersedes all prior versions |
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