Callsign letter to FCC

[price at cod.nosc.mil]

Not to resurrect a dead horse, but it's taken me a while to get around to
this.  I'm planning to send the following to the FCC as comments on the
"vanity" callsign NPRM that we discussed at length a while ago.

Is there still some specific format that these letters have to be in or
will the following be OK?  I have this recollection that some years ago
comment letters to the FCC had to be spaced just so, so many lines from the
top, had to say "in the case of blah, blah," had to have double underscore
lines drawn 3 inches from the top, and all that.

73--Jim, K6ZH
---------


From:

James N. Price, K6ZH
4953 Lorraine Drive
San Diego, CA 92115


To:

Federal Communications Commission
Washington, DC 20554


In regard to:  PR Docket No. 93-305


Follows my comments on the subject NPRM regarding amateur radio vanity call
signs.

First, let me say that I am extremely pleased that you are proposing this
program.  I have felt for years that not being able to buy callsigns, even
for major special events like the U.S. Olympics in 1984, is an
international embarrassment for this country.  My comments are relatively
minor, detailed issues--the overall program looks great!


GENERAL COMMENTS

1.  I suggest using a different term than "vanity" callsigns.  This term
brings with it some negative connotations which, I believe, might diminish
the enthusiasm for the program.  I would favor a more general term like the
"Call Sign Selection System" or "Specific Call Sign Selection Program."

2.  I would like to see each ham have a callsign that indicates his/her
class of license.  Since the mechanism is in place for a specific pattern
of callsigns per class of license, let's use it.  This would apply
immediately to requests for specific calls, and eventually to everyone upon
renewal of their present license.

3.  I would like to see hams returned to having callsigns that are
reflective of their call district, i.e. if you move, modify.  Again, this
could start with the specific callsign selection program, and eventually to
everyone upon renewal.

4.  Anyone in any class of license should be able to buy a specific call
(if available), subject to its being appropriate to the operator's class of
license.  Initially, length of time in a given license class should be the
primary determining factor for who can apply first for a given callsign. 
Note that I did NOT say length of time being an amateur radio operator. 
One might also consider letting the Extra Class license holders go first,
but that may not be necessary.  

5.  Some specific call signs should be reserved for radio clubs (e.g.
deceased members), descendants of deceased amateurs who are also hams, and
calls formerly held by an individual.  Perhaps these can be factored into
the priority scheme suggested in 4. above.

6.  Make a specific provision for Special Event callsigns.  A bonifide
"big" event, like the Boy Scouts Jamboree, the Olympics or whatever, should
be allowed to select ANY available callsign that is allowable in the U.S.
callsign allocations, even if its pattern might not be "standard."  For
example, allow the issuance of a call like W1A, or NA6ZZZ, or even W7ABCD.

7.  $70 for a 10 year license is certainly reasonable.  If it could be done
legally, I suggest the FCC could make some real money by auctioning certain
callsigns.  I would bet that someone would be willing to pay $1000 for
W6DX, for example.  But I suppose that would be discriminatory.

8.  After you get this initial program going, I strongly suggest you start
back-filling calls for new licensees.  All new Group B (???) licensees, for
example, should be able to get 1x3 calls, even if all the N#XXXs are gone. 
Start backfilling with available K, N, and W 1x3s.  Offer anyone who is
eligible for a Group B (???) 1x3 but who has a 2x3 the opportunity to get a
1x3 call for a very nominal fee, or the full fee if a person wants a
specific call.


SPECIFIC COMMENTS ON THE NPRM

1.  Section II, 2nd sentence--see my general comment 2 above.  The callsign
can and should indicate operating privileges in order to help amateur radio
self-police more effectively.

2.  Section III, para 6--I suggest you provide a single on-line terminal to
the ARRL and let them keep track of available callsigns.  They in turn can
post requested information on ham radio computer bulletin boards and/or
mail lists of available calls to interested parties as they did in 1976/77.
 Since the ARRL essentially administers the ham radio licensing program,
via the VECs, they can certainly handle callsign database information
requests.

3.  Section III, para 7--is the system that you're installing being
designed with bulletin board/e-mail access in mind?  Very inexpensive
software exists today for computer bulletin boards and it seems that such
programs could be used to provide remote links into your system very
affordably.  

4.  Appendix, para 3 (f), Section 97.19--I would suggest that a vacated
callsign also be subject to the two year exclusion that is indicated for
expired calls and those of deceased hams.  Especially for active hams, it
would take quite a while for various parts of the "system" to catch up with
who the "new" W6AA (or whatever) is.  Examples are QSL bureaus, magazine
subscriptions, databases maintained by retail stores, etc.