In a Petition for Rulemaking filed with the FCC on April 15 (see below for link), the Anchorage VEC -- one of 14 Volunteer Examiner Coordinators in the US -- asked the Commission to give permanent credit to radio amateurs for examination elements they have successfully passed. This would, in effect, create a license exam credit that would be valid throughout an amateurs’ lifetime, never expiring.

Currently, Amateur Radio licenses are good for 10 years. Hams may renew their license not more than 90 days before it is set to expire. If a ham fails to renew their license before it expires, but less than two years after it expires (called a grace period), they can reapply for their license and call sign and do not to retake any examination for the license. Under the current rules, hams may not apply to renew the license after the two year grace period. Instead, they must start all over and take new examinations to receive an Amateur Radio license.

In its Petition, Anchorage does not think that this is fair. “It does not matter that the person had at one time passed one or more examination elements,” it stated. “This fact is ignored. Does the passage of time somehow invalidate a person’s knowledge? We think not. We believe that any applicant who can demonstrate that they have passed certain elements at some previous date or who have held a license grant for a particular class of license, again on or before various applicable dates, should not have to be re-examined on those elements before a new license can be granted. It seems unfair to allow some applicants to claim element credit for items previously passed and not others.”

The Anchorage VEC also believes that if a person can show proof of having held a license grant for a specific class of license, they “[have] in fact demonstrated that they have earned credit for having passed the elements required for that class of license.” Anchorage’s plan calls for the 14 VECs to handle these applications.

Noting that the questions on the various exam elements have changed over the years to reflect changes in both technology and FCC rules, Anchorage maintained that a license granted in 1960 and a license granted today are both valid licenses “even though they were examined on material that anyone can see is significantly different. Again, we believe that an applicant for a re-issued license should receive credit for each and every element passed, without regard to when it was given. Requiring an applicant for a re-issued license to re-take an element just because it has changed in detail over the years is unfair, based on the fact that a license which has been continuously renewed and is still active implies that the long-term license holder does in effect receive credit for material passed long ago, and a person desiring to reactivate an expired license apparently does not.”

Anchorage, however, stated that even though an expired license is granted without examination after the two year grace period, the call sign need not follow the license. Noting that the call sign might not be available for a number of reasons, Anchorage proposed that applicants applying for their license after the two year grace period be granted “a new sequential call sign appropriate for the area where they currently reside. Once the new license grant has been issued, the applicant could then apply for a different call sign if they so desired, including a previously held call sign if it is available, by making use of the vanity call sign program.”

According to ARRL VEC Manager Maria Somma, AB1FM, the Petition filed by the Anchorage VEC does not address amateurs who had their licenses suspended or revoked. She said that if this Petition was looked upon favorably by the FCC, a provision should be made that no examination credit should be given if the operator license was ever suspended or revoked, or if the operator license was surrendered to avoid enforcement proceedings.

In January 1994, the ARRL filed a Petition (RM-8418), asking that a former licensee be allowed to obtain a new amateur operator license without passing the requisite qualifying examinations again. The objective was to encourage former amateur operators to become involved again in the opportunities provided by the amateur service. But in a Notice of Proposed Rulemaking in 1995, the FCC offered its own proposal, namely that the holder of an expired license could apply to a VE team for examination credit for the examination elements previously passed. The ARRL filed comments against this, arguing that the Communications Act of 1934, as amended did not allow the delegation of what amounted to the renewal of a license. In its Report and Order issued April 1, 1997 the Commission did not address that argument, but cited general opposition in deciding not to adopt its own proposal.

“We believe that our procedures provide ample notification and opportunity for license renewal,” the FCC put forth in the 1997 R&O. “The license expiration date is shown on our licensee data base, so that it can obtained through the Internet even if the license document is lost. Providers in the private sector often use this information to remind licensees that expiration is about to occur. For those persons who inadvertently fail to renew, a two-year grace period is allowed. At the conclusion of the grace period, the record of the former licensee is purged from the data base and the call sign becomes available for reassignment in the vanity call sign system. Further, we have made the license renewal process as simple as possible by expanding our electronic filing procedures to include license renewal. With respect to the lifetime operator license suggestion, the operator would still have to renew the station license every 10 years. We would, therefore, have to develop and maintain a separate data base specifically for the purpose of maintaining indefinitely records of amateur operators who allow their station license to expire. It would not be in the public interest to expend resources for such increased record retention.”