Currently, there must be three VEs at an exam session and they must observe the examinee(s) throughout the entire examination. The VEs are responsible for the proper conduct and necessary supervision of each examination. The VEs must grade the examinee’s answers immediately upon completion of each examination. When the administering VEs determine that the examinee has passed the examination elements required for the operator license sought, they must certify that the examinee is qualified for the license grant and that they complied with the administering VE requirements.
“Questions regarding whether three VEs are necessary to administer an examination sometimes come before the Commission in the context of claims that three VEs are not available at a particular location or time that an examinee would like to take an examination, or that an examinee must travel a great distance to a location where three VEs are available,” the FCC stated in the NPRM. “This requirement can also cause VEs to incur travel expenses that amateur examinees may have to reimburse. We note that unavailability of examination opportunities compromises one of the bases and purposes of the Amateur Service rules: To expand the existing number of trained operators, technicians and electronics experts.”
Upon establishing the VE system in 1983, the FCC noted that “[t]he use of three examiners provides for cross-checking to assure the correctness of answers to examination questions, to assure proper completion of license applications, and to minimize the likelihood of any possible fraud or abuse.” Since the VE system was established, the FCC pointed out that procedures have been developed by the VEs and VECs “that have almost eliminated examination grading and application completion errors and that fraud or abuse has been minimal. The VECs have VE manuals that provide specific procedures to be followed in preparing for, conducting, and reporting the results of an examination session. It is by hewing to these procedures that fraud and errors are avoided. We tentatively conclude that the required number of administering VEs can now be reduced without jeopardizing the integrity of the amateur operator license examination system.”
In order to increase the availability of examination opportunities, the FCC is proposing to reduce the number of VEs required to administer an examination to two: “We believe that reducing the number of required VEs can increase the availability of examination opportunities (by enabling VEs to offer more frequent examination sessions, or examination sessions at more locations, or both), while not compromising the reasons the Commission decided that more than one VE is necessary. This in turn would reduce the difficulty and expense that some examinees and VEs experience in traveling to an amateur radio license examination session.”
Remote Testing
In the years since the VE system was established, methods that would allow a VE to observe an examinee from afar have been developed, such as audio and video links, either hard-wired to a site or available through the use of wireless Internet or satellite technologies. The FCC noted that such methods are commonly used by colleges to provide courses at locations around the globe and by businesses for teleconferencing among numerous locations simultaneously.
On very rare occasions, the FCC has permitted VEs to use such means to remotely observe examination sessions that are held at isolated locations. With this in mind, the FCC is seeking comments on whether or not to amend Section 97.509(c) “to provide that, at the option of the administering VEs and the VEC coordinating the examination session, the VEs may be ‘present and observing’ an examinee for purposes of the rule when they are using an audio and video system that can assure the proper conduct and necessary supervision of each examination. Commenters should address what, if any, specific requirements should be incorporated into the rule (such as requiring one VE to be physically present at the examination session) and whether remote testing should be permitted everywhere, or only for examination sessions at less accessible locations (and how to define such locations). We believe that permitting remote examination administration can increase the availability of examination opportunities, which would reduce the difficulty and expense that some examinees and VEs experience in traveling to an amateur radio license examination session.”
Emission Types
Emission Designators
Part 97 of the Commission’s Rules specifies the emission types that may be transmitted on amateur frequencies. For data (telemetry, telecommand and computer communications), emission types may have A, C, D, F, G, H, J or R as the first symbol, 1 as the second symbol and D as the third symbol [Editor’s note: See Footnote 53 in the NPRM: “Certain other data emission types are also permitted under particular circumstances.”]. For telephony (speech and other sound emissions), emission types may have A, C, D, F, G, H, J or R as the first symbol with 1, 2 or 3 as the second symbol and E as the third symbol.
An emission designator describes an emission’s characteristics. A minimum of three symbols is used to describe the basic characteristics of the radio emission. The first symbol designates the type of modulation. For example, F is used for frequency modulation. The second symbol designates the nature of the signal modulating the main carrier. For example, 7 is used for two or more channels containing quantized or digital information. The third symbol designates the type of information to be transmitted. For example, D is used for data transmission, and E is used for telephony.
In its Petition, the ARRL stated that Amateur Service licensees have recently established numerous narrowband UHF repeater facilities using multiple time-slot Time Division Multiple Access (TDMA) repeaters and single-slot TDMA handheld digital transceivers, principally in the 70 cm (420-450 MHz) band.
“Specifically, the ARRL notes that a Motorola system used by some Amateur Radio operators uses two-slot TDMA technology for the repeater and single-slot TDMA emissions for the associated portable and mobile transceivers and that the system ‘specifies emission designators 7K60FXE in voice operation and 7K60FXD for data,’” the FCC noted. “The present rules, however, do not appear to permit amateur stations to transmit single-slot TDMA emissions on Amateur Service channels above 30 MHz. Part 97 does not specifically authorize any phone or data emission designators with X as the second symbol. Consequently, the ARRL requests that the Commission amend its rules to revise Section 97.3(c) to include emission type FXE in the definition of a phone emission, and to revise Section 97.307(f)(
to allow amateur stations to transmit data emission type FXD.”
The FCC pointed out that one of the purposes of the Amateur Service is to contribute to the advancement of the radio art. “Allowing amateur stations to use communication technologies that are used in other radio services, such as TDMA technologies, allows Amateur Service licensees to experiment with and improve these technologies and, therefore, is consistent with the basis and purpose of the Amateur Service. For this reason, we agree with the ARRL that the current rules allowing the use of multiple time-slot TDMA repeaters, but not permitting amateur stations to transmit single-slot TDMA emissions, may be unnecessarily impeding Amateur Radio operators in advancing the radio art.
“Another purpose of the Amateur Service is to assist the public as a voluntary and noncommercial communications service, particularly with respect to providing emergency communications. Allowing amateur stations to use equipment that is in use in other radio services allows Amateur Service licensees to put, in this case, modern repeater systems on the air, thereby benefiting the public if these systems are needed to provide emergency communications.”
In seeking to change the rules for these emission types, the FCC noted that the purpose of specifying emission designators for the Amateur Service “is to relegate the transmission of certain inharmonious emission types to different segments of the frequency bands, while still allowing great flexibility in the types of emissions that may be transmitted by amateur stations. We do not believe that this purpose is served by excluding FXE and FXD emissions. Accordingly, we propose to amend Section 97.3(c)(5) to allow emission type FXE as a phone emission and to amend Section 97.307(f)(
to allow emission type FXD as a data emission. We believe that this proposed rule change would encourage individuals who can contribute to the advancement of the radio art to more fully utilize TDMA technologies in experimentation and promote more efficient use of the radio spectrum currently allocated to the Amateur Service.” The FCC also seeks comments on whether any other specific emission types, such as F7E, should be permitted.
Part 97 Waiver Request
At the time that the ARRL filed its Petition, it also filed a request for a waiver to permit amateur stations to transmit emission types FXD and FXE, pending the outcome of the rulemaking proceeding. The FCC’s Mobility Division staff reviewed the waiver request and concluded that it was deficient “because the requested relief would not solve the problem that the ARRL sought to address unless it also sought a waiver to permit amateur stations to transmit emission type F7E (because granting a waiver to permit FXE emissions but not F7E emissions would create a situation where voice operation was permitted on mobile units but not on the associated repeaters). In July 2011, ARRL informed Mobility Division staff through its counsel that ARRL would amend the waiver request accordingly, but ARRL has not done so. Accordingly, we deny the waiver request.”
“Apparently, there was a misunderstanding,” commented ARRL Chief Executive Officer David Sumner, K1ZZ. “The defect noted by the Mobility Division is easily remedied. The ARRL will file an amended waiver request immediately in the hope that it can be quickly granted in light of the strong support for the ARRL’s Petition that is reflected in the comments filed on RM-11625.”
