From the ARRL: FCC Invites Comments on Amateur Radio-Related Petition for Rule Making

The ARRL posted this article on its website yesterday in reference to a petition from an Ohio amateur radio operator to change station identification requirements during emergencies and exercises for emergencies. I’ll post my comment on it first followed by the ARRL article.

I’ve had to use FCC station IDs for over twenty years as both an amateur radio operator and as a communications professional. At one point during my career, I used radios systems that didn’t automatically identify, so I had to use our FCC callsign on transmissions. At no point did I find the use of our FCC callsign to be burdensome or a hindrance as this petition states they could be. Prior to my career in emergency communications, I volunteered with ARES during Hurricane Floyd. While providing ARES communications during Floyd, I never found using my callsign to be a burden or found it to hinder communications. In both my amateur radio experience and my work experience, I have found that the use of callsigns becomes a habit, something that I do without even thinking about it. If amateur radio operators use their callsigns during rag chew, normal operations, special events, public service events, drills, and exercises, the use of those callsigns will become a habit they carry over to emergency operations without thinking about them. Callsign use won’t be and isn’t a burden or a hindrance; this petition is a request for an unnecessary change to Part 97 rules.

FCC Invites Comments on Amateur Radio-Related Petition for Rule Making


The FCC has invited public comments on a Petition for Rule Making (RM-11826) from an Ohio radio amateur seeking to amend the Part 97 station identification rules to better accommodate and simplify station identification during an emergency net, drill, or activation. ARRL member Robert A. Dukish, KK8DX, filed the petition in December, and the FCC put it on public notice this week. Dukish seeks a change to Section 97.119(a) of the rules, which requires an amateur station to transmit its “assigned call sign on its transmitting channel at the end of each communication, and at least every 10 minutes during a communication.”

He noted that during emergency networks, requiring participating stations — often portable — to use their assigned call signs during each transmission could prove “burdensome and can hinder the flow of emergency traffic on the channel.”

Specifically, he is suggesting that a simple approach would be to permit the net control station or other designated participant to announce from a single point the call signs of every station taking part in the net or exercise, when tactical call signs often are in use, at 10-minute intervals, using automatic CW identification.

Dukish suggested amending Section 97.119(a) to add, “except during a local emergency network activation or drill,” and providing that in such situations, a net control or designations station would be “authorized to announce all participating stations’ assigned call signs at no more than 10-minute intervals while the net is in progress.” The amendment would provide that participating stations “be within a 50-mile distance of the identifying station, and each individual station must self-identify by transmitting its assigned call sign at least once per hour.” CW transmission could be no faster than 25 WPM if sent automatically to satisfy the suggested amendment.

In his petition, Dukish noted petitions filed in 2005 and 2006 seeking changes to the Amateur Radio station identification rules. The FCC did not adopt either proposal.

Interested parties may comment via the FCC Electronic Comment Filing Service (ECFS).

Categories: Amateur Radio, ARES, ARRL, Emergency Communications, Public Service

Tags: , , , ,

2 replies

  1. I think you’ve hit on the best description of this yet – a solution looking for a problem.

  2. I’m a Net Control Operator for our Southeast ARES District VHF Net, and I don’t see how the change(s) Mr. Dukish is requesting would relieve what he describes? Stations are currently required to ID every 10 minutes during an ongoing contact, and then again at the end of the contact as the station returns comms “Back to Net Control”, resumes monitoring, or goes “clear” of the frequency.

    In an Emcomm situation, this ID procedure (like the more formal use of “over” to end each transmission) provides confirmation to other stations that the contact has ended, and they can call Net Control if needed without interrupting. It also tells any station entering the net between periodic station check-ins which other stations are active.

    Changing the current ID requirement may give established nets some flexibility in how they operate, but having the Net Control station to transmit the ID of _every_ station in the net _every_ 10 minutes via CW seems like an even greater burden and less-efficient use of valuable air-time, especially for nets with large numbers of active stations.

    I’m all for giving Emcomm operators flexibility in how they run their nets, but so far, I can’t think of a problem for KK8DX’s solution to solve.


    – Steve / KN4GOV

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