**Before the**

**Federal Communications Commission**

**Washington, D.C. 20554**

In the Matter of )

)

Changes in Part 97 With Regard to Amateur ) RM-11346

Radio Service Rules, 97.119(a) Station )

Identification )

)

Proposed Changes in 47 CFR Part 97 ) RM-11347

Section 97.119 )

)

Amendment of Part 97 of the Commission\'s )

Rules Governing the Amateur Radio Service )

to Provide for Recognition of Amateur )

Operators Who Have Served in the United )

States Military )

**ORDER**

**Adopted: July 6, 2007 Released: July 9, 2007**

By the Deputy Chief, Mobility Division, Wireless Telecommunications
Bureau:

**I. INTRODUCTION**

Number range level0Number range level1Number range level2Number range
level3Number range level4Number range level5Number range level6Number
range level71. We have before us three petitions requesting changes to
Section 97.119 of the Commission's Rules, which governs amateur station
identification.[^1] Two of the petitions request that the time interval
between required identification announcements be changed. The third
petition requests that certain combinations of letters be reserved for
use by current or former members of the armed forces when identifying
their amateur service stations. Because the petitioners seek to amend
the rules to permit activity that the current rules already permit, or
do not present sufficient evidence to justify altering the current
rules, we are dismissing all three petitions.

**II. DISCUSSION**

**A. Station identification interval**

2\. *Background.* Section 97.119(a) of the Commission's Rules provides
that an amateur station "must transmit its assigned call sign on its
transmitting channel at the end of each communication, and at least
every 10 minutes during a communication, for the purpose of clearly
making the source of the transmissions from the station known to those
receiving the transmissions."[^2] We have received two proposals to
amend this provision. On December 9, 2005, Murray Green filed a petition
for rulemaking, RM-11346, requesting that the Commission amend Section
97.119(a) to reduce the required frequency of station identification to
every thirty minutes during a communication, rather than once every ten
minutes.[^3] On May 19, 2006, Glen E. Zook filed a petition for
rulemaking, RM-11347, requesting that the Commission amend Section
97.119(a) to require that the call sign be transmitted at the beginning
and end of each single transmission, and at the beginning and end of a
series of transmissions between stations having established
communications when each transmission is less than three minutes in
duration.[^4]

3\. Green argues that the station identification requirement should be
relaxed because the current requirement "appears, perhaps out of an
abundance of caution, to have resulted in more frequent or
over-identification by Amateur Radio operators," and requiring
identification less frequently \"would harmonize the Amateur Radio
Service station identification requirement with that of other radio
services and should not hinder the Commission's enforcement of Amateur
Radio regulations.\"[^5] Zook, on the other hand, argues that the
station identification requirement should be tightened because "too many
amateur radio operators . . . do not identify during their first
transmission. In fact, a considerable number of these operators never
seem to get around to identifying even after 10 minutes of operation and
a 'fair' number never seem to get around to giving their call sign at
all."[^6] Each petition received approximately one hundred comments*.*
The commenters generally oppose both petitions.

4\. *Decision*. Based on our review of the record, we are not persuaded
that the requested rule changes are necessary or supported by the
amateur radio community. The purpose of the station identification rule
is \"to clearly make the identity of the station transmitting known to
those receiving the transmission.\"[^7] To achieve this purpose, the
rule requires that an amateur station transmit its call sign at the end
of each communication and at least every ten minutes during a
communication that lasts longer than ten minutes. The overwhelming
majority of commenters believe that the current rule properly balances
the burden of requiring the station to transmit its call sign with the
convenience of those receiving the transmissions to determine the
identity of the station making the transmissions.

5\. The commenters argue that the current requirement is not
burdensome,[^8] but rather \"is a good balance between operational
flexibility and ease of identification,\"[^9] and that the maximum ten
minutes between station identification (which has been in effect for
over fifty years[^10]) is short enough that those listening can discover
the source of a transmission in a reasonable time.[^11] We concur.[^12]
We also agree that a thirty-minute interval would be too long, because
interference and variations in propagation may not permit continuous
reception of a specific station for thirty minutes.[^13] In addition, we
share the commenters' concern[^14] that requiring a station receiving
another station\'s transmission to listen for up to thirty minutes to
determine the call sign of the transmitting station would compromise the
ability of the amateur service to self-police,[^15] especially in light
of the fact that other methods of identifying the station, such as
looking up the station call sign based on the operating frequency, are
not available because amateur stations do not operate on specifically
assigned frequencies. It therefore is reasonable to require amateur
station identification more frequently than is required of stations in
other services.[^16] We conclude, therefore, that proposing to increase
the time between required station identification transmissions would not
improve or enhance the operation of amateur service stations or
otherwise be in the public interest. Accordingly, we dismiss the Green
Petition.

6\. We also agree with the commenters that increasing the frequency of
station identification as proposed in the Zook Petition is unnecessary
and would be burdensome.[^17] It also could lead to congestion, such as
during a contest when many amateur operators are trying to contact a
distant station.[^18] Moreover, the petition does not demonstrate that
so revising the station identification requirement would address the
primary concern expressed by the petitioner -- that many amateur radio
operators do not identify their station timely or at all. Therefore, we
agree with the comments that say, in various ways, that the problem of
station operators not complying with the present rule is better
addressed by enforcement of the present rule, rather than a rule
change.[^19] Finally, we note that while the current rule does not
require identification at the beginning of a communication, many amateur
stations already routinely begin a transmission with their call sign.
Accordingly, we dismiss the Zook Petition.

**B. Unique indicators for licensees who are veterans**

7\. *Background.* Section 97.119(c) of the Commission's Rules permits
the inclusion of indicators with the call sign during station
identification, provided that no self-assigned indicator conflicts with
any indicator specified by the Commission's rules or with any prefix
assigned to another country.[^20] On December 1, 2006, the Quarter
Century Wireless Association (QCWA) filed a petition for rulemaking
requesting that Section 97.119(c) be amended to permit an amateur radio
operator who is a current or honorably discharged member of the United
States military to include a unique indicator with the station\'s call
sign identification announcement.[^21] In support of this proposal, QCWA
notes that many amateur radio operators are serving or have served in
the United States military, or became amateur radio operators during or
following their military training in communications and electronics, and
it states that this proposal would afford those individuals the option
to advise others of their military service when they identify their
amateur stations on the air.[^22]

8\. *Decision*. We are not persuaded that proposing the requested rule
change is warranted. Amateur radio operators who are current or
honorably discharged members of the United States military already are
permitted to identify their stations in the way QCWA suggests. As noted
above, the present rule permits a control operator to include an
indicator with the call sign, subject only to the limitation that a
self-assigned indicator not conflict with any other indicator specified
by the Commission's rules or with any prefix assigned to another
country. We note that the indicators QCWA suggests do not conflict with
other indicator specified by the rules or with another country's prefix.
They therefore may be included as an indicator with a presently-assigned
amateur station call sign. To the extent that QCWA seeks to regularize
the use of its proposed indicators to increase their recognition, the
amateur community may do so without any change to the amateur service
rules.[^23] For these reasons, we conclude that the rule change
requested by the QCWA is unnecessary, and we dismiss the QCWA
Petition.[^24]

**III. CONCLUSION AND ORDERING CLAUSES**

9\. On the basis of the above, we conclude that the requests in the
above-captioned petitions for rulemaking are unnecessary in light of the
existing rules, and do not warrant further consideration at this time.

10\. Accordingly, IT IS ORDERED, pursuant to Sections 4(i) and (j) and
303(r) of the Communications Act of 1934, as amended, 47 U.S.C. §§
154(i), (j), 303(r), and Section 1.401(e) of the Commission\'s Rules, 47
C.F.R. § 1.401(e), that the petition for rulemaking filed by Murray
Green, RM-11346, on December 9, 2005 IS HEREBY DISMISSED WITHOUT
PREJUDICE.

11\. IT IS FURTHER ORDERED that the petition for rulemaking filed by
Glen E. Zook, RM-11347, on May 19, 2006 IS HEREBY DISMISSED WITHOUT
PREJUDICE.

12\. IT IS FURTHER ORDERED that the petition for rulemaking filed by the
Quarter Century Wireless Association on December 1, 2006 IS HEREBY
DISMISSED WITHOUT PREJUDICE.

13\. This action is taken under delegated authority pursuant to Sections
0.131 and 0.331 of the Commission\'s Rules, 47 C.F.R. §§ 0.131, 0.331.

FEDERAL COMMUNICATIONS COMMISSION

Scot Stone

Deputy Chief, Mobility Division

Wireless Telecommunication Bureau

[^1]: 47 C.F.R. § 97.119.

[^2]: 47 C.F.R. § 97.119(a).

[^3]: *See* Petition for Rulemaking, Changes in Part 97 with Regard to
    Amateur Radio Service Rules, 97.119(a) Station Identification, at 1
    (filed Dec. 9, 2005) (Green Petition).

[^4]: *See* Letter dated May 10, 2006 from Glen E. Zook to Marlene H.
    Dortch, Secretary, Federal Communications Commission, at 3 (filed
    May 19, 2006) (Zook Petition). Zook also requests that we amend the
    rule to require that the call sign be preceded by the words "this
    is" or "from" when voice communications is being transmitted, and
    require that the call sign be preceded by the prosign "de" when
    telegraphy is being transmitted. *See id.* at 3-4. Zook notes that
    these identification procedures were required "in years past" and
    that his proposal incorporates the identification procedures that
    were under former Section 12.82 of the Commission's Rules, 47 C.F.R.
    § 12.82 (1956).

[^5]: Green Petition at 2 (citing 47 C.F.R. §§ 5.115 (Experimental Radio
    Service), 22.313 (Public Mobile Services)).

[^6]: Zook Petition at 2.

[^7]: Amendment of the Amateur Service Rules to Provide for Greater Use
    of Spread Spectrum Communication Technologies, *Report and Order*,
    WT Docket No. 97-12, 15 FCC Rcd 1481, 1488 ¶ 6 (1999).

[^8]: *See*, *e.g.*, James P. Miccolis Comments at 1; Wayne C. Greaves
    Comment at 1; Bill Noyce Comments at 1; Merle C. Bone, Jr., Comments
    at 1; John Elengo Comments at 1; Robert Witte Comments at 1; James
    Melton Comments at 1; Ken Holland Comments at 1; Dee D. Flint
    Comments at 1.

[^9]: James P. Miccolis Comments at 1.

[^10]: *See, e.g.,* 47 C.F.R. § 12.82(a)(1)(iv) (1956).

[^11]: *See*, *e.g.*, Bill Noyce Comments at 1; Merle C. Bone, Jr.,
    Comments at 1; John King Comments at 1; Cathy James Comments at 1.

[^12]: Because the present rule has not been shown to be burdensome or
    unreasonable, we are not persuaded by comments that support
    expanding the interval between required identification to fifteen or
    twenty minutes. *See* Donald B. Chester Comments at 3; Earl Paazig
    Comments at 1-2.

[^13]: Donald B. Chester Comments at 1; Wayne C. Greaves Comment at 1.

[^14]: *See*, *e.g.*, James P. Miccolis Comments at 1; James L. McCoy
    Comments at 1; John Elengo Comments at 1; David G. Borcher Comments
    at 1; Steven J. Robeson Comments at 1; Hershel L. Keris, Jr.,
    Comments at 1.

[^15]: We note that a hallmark of enforcement in the amateur service is
    \"self-policing,\" which depends on an amateur station hearing a
    message being able to determine the call sign of the transmitting
    station. *See*, *e.g.*, Waiver of Sections 97.80(b) and 97.114(b)(4)
    of the Amateur Rules to Permit the Retransmission of Third-Party
    Traffic in Certain Situations, *Order*, PR Docket No. 85-105, 59
    Rad. Reg. (P & F) 1326, 1326 ¶ 2 (PRB 1986).

[^16]: *See*, *e.g.*, Wayne C. Greaves Comment at 1; Bill Noyce Comments
    at 1; Robert Witte Comments at 1; Donald B. Chester Comments at 1;
    James L. McCoy Comments at 1.

[^17]: *See*, *e.g.*, Michael A. Voltz Comments at 1; Alan W. Jump
    Comments at 1; Donald B. Chester Comments at 2.

[^18]: Donald B. Chester Comments at 2.

[^19]: David M. Drumheller Comments at 1; John Elengo Comments at 1.

[^20]: 47 C.F.R. § 97.119(c).

[^21]: *See* Petition for Rulemaking, Amendment of Part 97 of the
    Commission's Rules Governing the Amateur Radio Service to Provide
    for Recognition of Amateur Operators Who Have Served in the United
    States Military, at 3 (filed Dec. 1, 2006) (QCWA Petition).
    Specifically, QCWA requests that the indicators AF, AA, NA, NM, and
    ACG be reserved for use by current or honorably discharged members
    of the United States Air Force, Army, Navy, Marine Corps, and Coast
    Guard, respectively.

[^22]: *Id.* at 1.

[^23]: *Cf.* Development of Operational, Technical and Spectrum
    Requirements for Meeting Federal, State and Local Public Safety
    Communication Requirements Through the Year 2010, *Fourth Report and
    Order and Fifth Notice of Proposed Rule Making*, WT Docket No.
    96-86, 16 FCC Rcd 2020, 2040 ¶ 59 (2001) (declining to mandate the
    use of a standard channel nomenclature for public safety
    interoperability channels, but encouraging the development of an
    industry standard).

[^24]: *See* Amendment of Part 97 of the Commission's Rules Governing
    the Amateur Radio Services, *Notice of Proposed Rulemaking and
    Order*, WT Docket No. 04-140, 19 FCC Rcd 7293, 7323 ¶ 66 (2004)
    (deeming it unnecessary to amend the amateur rules to authorize
    activity that is already permitted).