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Old June 22nd 16, 05:36 PM posted to rec.radio.amateur.moderated,rec.radio.amateur.policy,rec.radio.info
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Default FCC Daily Digest 06/22/2016


(Moderator's Note: Only FCC Part 97 Amateur Radio related actions are shown below.)

Daily Digest

Vol. 35 No. 118 June 22, 2
016



[...]

MARK F. KROTZ. Dismissed the Petition. (Dkt No. RM-11760 ). Action by:
Deputy Chief, Mobility Division, Wireless Telecommunications Bureau. Adopt
ed: 06/21/2016 by ORDER. (DA No. 16-707). WTB https://apps.fcc.gov/edocs
_public/attachmatch/DA-16-707A1.docx
https://apps.fcc.gov/edocs_public/at...A-16-707A1.pdf

(Moderator's Note:

Amateur or Part 97 match found in contents linked at URL:

Petition for proposed changes in 47 CFR Part )
§ 97.25 License term for Amateur Radio )


[...]

1. Introduction. We have before us a petition filed by Mark F. Krotz1 requesting a change
to Section 97.25 of the Commission's Rules, which governs the term of an amateur radio license.2 The
petition requests that the rules be amended to grant amateur licenses for the lifetime of the holder. For the
reasons below, we dismiss the petition.

2. Background. Section 97.25 of the Commission's Rules states that an amateur radio
license "is normally granted for a 10-year term."3 Krotz argues that extending the term of amateur
licenses to the lifetime of the holder will relieve administrative burdens on licensees and Commission
staff, and align the term of amateur radio licenses with that of most commercial radio operator licenses.4
Commenters--consisting of individual amateur licensees--were evenly divided between those supporting
the proposal and those opposing it.5

[...]

discloses sufficient grounds for the requested rule change. Krotz's primary argument is that extending the
term of amateur licenses to the lifetime of the holder would reduce the Commission's administrative and
personnel costs, but it is not clear to us that the proposal actually would enhance administrative
efficiency. The vast majority (approximately 97%, according to a recent review) of amateur license
renewal applications are submitted via the Commission's Universal Licensing System (ULS), either by

[...]

We note, however, that the Commission recently reaffirmed9 its earlier conclusion10 that requiring
amateur licensees to renew does not impose an unreasonable burden. In that proceeding, the Commission
amended the amateur rules to grant partial examination credit for certain expired amateur operator
licenses, but declined to extend the validity of a certificate of successful completion of examination to the

[...]

that the Commission recently eliminated the regulatory fee for vanity licenses, no payment is required to
renew any amateur license,12 so the financial strain on licensees is minimal.

5. One of the reasons that the Commission granted only partial examination credit for
expired amateur operator licenses, and still requires former licensees to pass Element 2 in order to be
relicensed, was to address the concerns of commenters in that proceeding that a licensee who has not

[...]

to operate under that person's license.14 These concerns, also raised by commenters in this proceeding,15
also weigh against doing away with amateur license renewal.

6. Lastly, Krotz notes that the Commission already issues commercial operator licenses for
the holder's lifetime. We agree, however, with the numerous commenters16 who note that the amateur


[...]

8
See Amendment of the Amateur Service Rules Governing Vanity and Club Station Call Signs, Report and Order, 25
FCC Rcd 16351, 16353, para. 8 (2010).
9
See Amendment of the Amateur Service Rules Governing Qualifying Examination Systems and Other Matters, et
al., Report and Order, 29 FCC Rcd 6311, 6314, para. 8 (2014) (2014 Element Credit Report and Order) (citing
Amendment of the Amateur Service Rules Governing Qualifying Examination Systems and Other Matters, et al.,
Notice of Proposed Rulemaking and Order, 27 FCC Rcd 12582, 12584, para. 6 (2012)).
10
See Amendments to the Amateur Service Rules Including Amendments for Examination Credit, Eligibility for a
Club Station License, Recognition of the Volunteer Examiner Session Manager, a Special Event Call Sign System,

[...]

applications,"18 which, as noted above, is no longer the case.19 Consequently, it does not follow from
lifetime licensing of commercial operators that lifetime licensing is appropriate for amateur radio stations.


[...]

Another reason noted by the Commission was to eliminate the need for licensees to pay a renewal fee. See id. As
noted above, this also is not a consideration with respect to amateur licensing.


)

[...]

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