The FCC rules explicitly state that the control op must be present at "the
control point" unless the station is automatically controlled (e.g., a beacon.)
The wording makes it clear that the control op must be in a position to ensure
proper operation at all times and to take immediate control of the station if
and when needed.
I'm not sure how the rules worked in the distant past, but I believe that at
one time the "station license" and "operator license" were separate things, and
the station license specified a fixed location. I believe somewhere along the
line the FCC merged these concepts such that both licenses are granted to a
person, and the station location was no longer fixed. This freed us to
designate any set of equipment at any location in the USA as "my station",
without having to use the /P suffix.
The distinction between the station licensee and the control operator licensee
is still important. If you do a guest op at my station, I would be the station
licensee and I would designate you as the control operator. In that case you
must identify the station with my call sign, WC1M. But it's also legal for you
to be both the station licensee and control operator, essentially taking over
the equipment at my location as "your station". In that case, you must use your
own call sign identification.
I believe in the first case, my station log must indicate that you are the
designated control operator. That's not hard -- the Cabrillo file has separate
fields for the station call sign and operator call sign, and I believe most
guest ops fill them in properly. I wouldn't be surprised if the FCC considered
that sufficient, so I don't think Marty is correct that the rules have been
violated by most guest ops over the past 30 years. In the second case, you
would use your own station log. I think technically you need to note the new
QTH of your station, and there's a Cabrillo fields for that. It's not clear,
however, whether enough information is put in that field to satisfy the FCC.
You could use the Address fields, but the contest sponsor will send your plaque
Now, the case where an operator, licensed or not, is using the control
operator's privileges requires a special note in the log. This common
occurrence at multi-op stations is rarely, if ever, documented in the log. I
don’t think there are any fields in the Cabrillo file that would suffice.
While we're on the subject, FCC rules also require that the station "must
transmit its assigned call sign on its transmitting channel at the end of each
communication". It's not clear to me whether "communication" in this context
means after every "over" or at the end of the contact. I think it's the latter
because there's also a requirement to transmit your station call sign at least
every 10 minutes. Either way, I think most US stations respect this rule during
contests, but I sure wish DX stations would do so as well. I wonder how many
licensing authorities require an ID on each contact, and whether any contest
sponsors would be interested in cracking down on DX stations that violate that
73, Dick WC1M
> -----Original Message-----
> From: email@example.com [mailto:firstname.lastname@example.org]
> Sent: Monday, June 25, 2012 7:58 AM
> To: Ron Notarius W3WN
> Cc: 'Dick Green WC1M'; email@example.com
> Subject: RE: [CQ-Contest] KP2MM Disqualified in ARRL CW 2012
> Good morning Ron...thanks for the follow up.
> Lets see...Monday morning...check
> Ok...I can now play Monday morning quarterback... <grin>
> I guess one of the things I was trying to point out (maybe not too
> successfully) was the similarity of the FCC rules as they are written...
> (97.103 Station License vs. 97.105 Control operator function)
> Specifically pointing to 97.103 a&b...
> The way "I" interpret those rules is that even if a guest op has the
> necessary license (Extra in the US for FULL band privileges) the rules
> state that the station owner AND the operator (who is the guest) are
> both EQUALLY responsible for the proper operation of the station...
> So, while an Extra guest op may have the necessary license to operate
> anywhere in the US bands...if he is operating as a guest at another
> station it is STILL the duty of the station owner to ENSURE the proper
> operation of the station while said guest op is actively using the
> station. To me that would indicate that the station owner would need to
> be PRESENT at the station and physically in close proximity to the
> station equipment (read in the room) to ENSURE that the station is being
> operated correctly. OR...as part 'b' of the rule goes on to state, the
> station license is presumed to also be the control operator of the
> station UNLESS he/she designates another as the control operator...
> Hence my comment (somewhat tongue-in-cheek) that I hoped ALL of the
> former Single Op efforts that were Guest Op's had documentation that the
> station licensee had 'designated' the guest op as the CONTROL op for the
> duration of the contest...something tells me there wouldn't be a whole
> lot of documentation of the sort to be found...at least not in the last
> 30 some odd years...
> Fundamentally, my issue is that there are two trains of thought (in this
> thread) on whether a Control Op constitutes a 2nd operator...AS DEFINED
> by the CONTEST RULES. Unless or Until a control op needs to take control
> of the station due to some mistake or other 'misdeed' by the guest op I
> don't see the control operator as an OPERATOR...he/she is simply a
> As for Yuri's specific predicament...if the ARRL chose to reclassify as
> a Multi-Op, I think the ONLY class that would work would be M/M because
> M/M places no bandchange or timelimit rules on the operation...M/S and
> M/2 both do...and as such wouldn't work.
> ---- Ron Notarius W3WN <firstname.lastname@example.org> wrote:
> > Marty,
> > I appreciate your comments. Clearly we all don't see eye-to-eye on
> > exactly when a control operator is or is not considered an operator
> > for the purposes of the contest.
> > I respectfully disagree with the notion that one can be a Control
> > Operator under FCC rules, yet not be considered an operator of the
> > station while it is in the contest. The key, to me, is that the
> > Control Op (in not so many
> > words) must be PRESENT, AND must be in CONTROL. To my thinking, the
> > combination implies... in fact, pretty much demands... that the
> > Control Op MUST be considered a station op for the contest, otherwise,
> > the under-licensed op can not operate outside of his or her license
> > In any event, after reviewing the first link in Brett (ex)VR2BG's
> > earlier post... well, I've said all along that we don't know
> > everything. Now I understand why Yuri's log may have received
> > additional scrutiny... because it would certainly appear from that
> > link (scroll down to the FCC enforcement
> > section) that this very situation HAS happened before.
> > It certainly does make me wonder why Yuri says he didn't understand
> > why KP2MM was DQ'd, considering what happened with KF0R in the 2004
> > ARRL DX CW contest (I believe I have the year right, as it's not
> > explicitly mentioned in the article).
> > So... well, I think I've made my position on the rules interpretation
> > I may be wrong (certainly wouldn't be the first time!) but I don't
> > think I am. So I am going to bow out of further beatings of the
> > deceased equine at this time.
> > 73
> > -----Original Message-----
> > From: email@example.com
> > [mailto:firstname.lastname@example.org] On Behalf Of Martin Durham
> > Sent: Sunday, June 24, 2012 9:39 PM
> > To: Ron Notarius W3WN
> > Cc: Dick Green WC1M; <email@example.com>
> > Subject: Re: [CQ-Contest] KP2MM Disqualified in ARRL CW 2012
> > Not 'quite' Ron......Not a lot of difference between control op and
> > station licensee requirements when it's your station.
> > Per the part 97 rules from the current ARRL FCC rules page:
> > §97.105 Control operator duties.-
> > (a) The control operator must ensure the immediate proper operation of
> > the station, regardless of the type of control.
> > (b) A station may only be operated in the manner and to the extent
> > permitted by the privileges authorized for the class of operator
> > license held by the control operator.
> > <http://www.arrl.org/part-97-amateur-radio> §97.103 Station licensee
> > responsibilities.-
> > (a) The station licensee is responsible for the proper operation of
> > the station in accordance with the FCC Rules. When the control
> > operator is a different amateur operator than the station licensee,
> > both persons are equally responsible for proper operation of the
> > (b) The station licensee must designate the station control operator.
> > The FCC will presume that the station licensee is also the control
> > operator, unless documentation to the contrary is in the station
> > (c) The station licensee must make the station and the station records
> > available for inspection upon request by an FCC representative. When
> > deemed necessary by a District Director to assure compliance with the
> > FCC Rules, the station licensee must maintain a record of station
> > operations containing such items of information as the District
> > Director may require in accord with § 0.314(x) of the FCC Rules.
> > One could arguably make the case that whether the station is being
> > operated by a lower class licensee or an Extra class licensee who is
> > not the primary station licensee, the primary station licensee
> > (presumed control operator) should be present when the station is in
> > operation… LOTS of SO efforts in the records that were by ‘guest op’s…
> > I ‘suppose’ if you want some wiggle room…97.105 a) says “Immediate
> > proper operation” whereas 97.103 a) says “proper operation”.
> > Hmmm…station owner turns on the equipment and gets everything ‘all
> > tuned up’ and ready to go before the guest op arrives…is THAT
> > I remember back around the first year I was a ham (30+ years ago)…my
> > elmer explaining to me what a control operator was supposed to ‘do’
> > (you won’t find this in the FCC rules or ARRL contest Rules…but I
> > think we’d all agree that this is the intent)…a control operator is
> > supposed be close enough at hand to be able to take over/stop the
> > transmitter/or disable the transmitter should the person who is
> > operating it under the control operators ‘watchful’ guidance do
> something against the rules.
> > You have FCC rules which are THE rules…that must be followed…then the
> > contest rules…which must be followed AS LONG AS they don’t cause you
> > to break any of the FCC rules (this is for US amateurs)
> > So…does a CONTROL operator really constitute a 2nd operator if all
> > they do is ‘monitor’ the operation of the PRIMARY operator at the
> > radio controls…to ensure that the FCC rules are followed? The control
> > operator doesn’t
> > (presumably) log, doesn’t (receive to aid the PRIMARY operator), and
> > doesn’t transmit. What exactly did the CONTROL operator due that a
> > station operator wouldn’t do to ensure that the station is operated
> within the rules?
> > This is all based on the ARRL contest and the specific KP2MM
> > scenario…WW contests add in the whole 3rd party issue which is a whole
> > ‘nother’ discussion…
> > 73,
> > Marty
> > W1Minutuae Discriminator
> > Sent from my iPad
> > On Jun 24, 2012, at 4:13 PM, "Ron Notarius W3WN" <firstname.lastname@example.org>
> > > If you come over to my house to operate, as an Extra Class operator,
> > > I do not need to be present as a control operator. So in the
> > > unlikely event
> > that
> > > this would happen, yes, my presence would not necessarily indicate
> > > that I
> > am
> > > there to be a legal control operator.
> > >
> > > On the other hand, when my friend Ben KB3ERQ comes over to my house
> > > to operate, as a Technician Class operator, I MUST legally be
> > > present as a control operator, UNLESS he is operating within the
> > > limits of a Tech. (Or someone of a higher license class must be
> > > present as the designated
> > control
> > > op, if you really want to split hairs that thinly.) Therefore, my
> > > presence WOULD indicate that I am there as a legal control operator
> > > (when Ben is operating outside of Tech privileges). Not, to me, a
> > > hypothetical
> > situation
> > > either, since Ben is a member of my multi-single team for multiple
> > contests.
> > >
> > > So, Dick, with all due respect, you can split the proverbial hairs
> > > however you like. I really don't feel like playing arm-chair lawyer
> > > (that's what
> > I
> > > have K3AIR for, anyway). To me, the unfortunate situation is
> > > cut-and-dried... Yuri operated KP2MM outside of General privileges.
> > > So either he was in violation of the rules for doing so; or if he
> > > did so with
> > a
> > > legal control operator (Herb) present, then he was legally operating
> > > Multi-Single & entered in the wrong entry class. It's either one or
> > > the other, and no arm-chair lawyering will change that.
> > >
> > > And again, we don't know the full story. Yuri hasn't amplified his
> > original
> > > public post that I am aware of (outside of some indicated PM's which
> > > have remained private), nor is the ARRL Contest Committee saying
> > > anything (not that I would have expected them to). So there may be
> > > more to the story
> > that
> > > we are not aware of.
> > >
> > > Granted, it's no fun to have your fingers burned in a situation like
> > > this, which is why he has my sympathies.
> > >
> > > 73, ron w3wn
> > >
> > > -----Original Message-----
> > > From: Dick Green WC1M [mailto:email@example.com]
> > > Sent: Sunday, June 24, 2012 2:43 PM
> > > To: 'Ron Notarius W3WN'; firstname.lastname@example.org
> > > Subject: RE: [CQ-Contest] KP2MM Disqualified in ARRL CW 2012
> > >
> > _______________________________________________
> > CQ-Contest mailing list
> > CQ-Contest@contesting.com
> > http://lists.contesting.com/mailman/listinfo/cq-contest
CQ-Contest mailing list