W3BE'S BE Informed!
STATION IDENTIFICATION ANNOUNCEMENT
 
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BE Informed No. 4.0

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Which Call Sign?

Your options and accountability

when someone uses your station apparatus

or vice-versa

John B. Johnston W3BE

Q. When my ham friend operates my amateur station, which call sign should he use, his or mine?

A. The only person eligible to answer your question authoritatively is...YOU! The call sign transmitted in the Section 97.119(a) station identification announcement must be that assigned to the station. It is for you - as the person having the Section 97.5(a) physical control of station apparatus - to answer the basic question: "Under the authority of which of our station licenses am I going to allow my station apparatus to transmit on amateur service spectrum?" Your answer will establish which call sign must be used. It will also determine the extent of your accountability. Make your choice carefully.  

Q. What are my choices?

A. You have two options: 

   Choice One: The station transmits your primary station call sign in the station identification announcement. This establishes you as the Section 97.103(a) station licensee, responsible for the proper operation of the station. You and your friend are both accountable for the duties of its Section 97.105 control operator being performed properly. Note that Section 97.103(b) says that the FCC will presume that you - the Section 97.103(a) station licensee - are also the designated Section 97.7 control operator unless there is documentation to the contrary. 

   Choice Two: Relinquish Section 97.5(a) physical control of station apparatus to your friend. The station transmits your friend's primary station call sign in the identification announcement. This establishes your friend alone as being responsible for performing properly the duties of both the station licensee and its control operator. You are not accountable. 

Q. Which is the better, Choice One or Two?

A. That depends upon your reason for allowing your friend to use your station apparatus. For instance, if you want to add QSL cards to your station's collection or improve your station's contest score, your better choice would be Choice One. Otherwise, with Choice Two, any resulting QSL cards will be addressed to your friend's station and contest points will be attributed there. 

Q. How do I turn Section 97.5(a) physical control of my station apparatus over to my friend?

A. You could sell it to him, rent it to him, or loan it to him. That is a matter for you and your friend to arrange. Just make certain that you both agree to the transaction details. Documentation would be prudent.

Q. My friend is authorized for Section 97.107 alien operation. Which is the better choice when he operates my station?

A. Withhold the use of your station and its apparatus until you are confident that it will be used properly. Keep in mind that persons authorized for alien operation do not have to prove to our VEs that they possess the Section 97.503 operational and technical qualifications required to perform properly the duties of an amateur service licensee in places where the FCC regulates our amateur service.

   Further, there is no database of the alien operators. Otherwise, Choice Two would be preferable to Choice One because - in view of a somewhat greater chance of a violation of the rules occurring - you would not be at risk. Your friend would bear complete responsibility for all violations. The worst choice would be Number One because you would be fully responsible even though you are not the control operator. Section 97.103(b) says that even where the control operator is a different amateur operator than the station licensee, both persons are equally responsible for proper operation of the station. 

Q. If my friend causes my station to transmit on a frequency channel outside the ham bands, who will the FCC consider to be in violation of its rules?

A. The licensee of the station whose call sign was transmitted in the Section 97.119 station identification announcement would be accountable. Under Choice Number Two, therefore, your friend alone would be accountable. Under Choice Number One, you alone would be accountable unless you show proof that that your friend was the control operator at the time of the infraction. In that instance, you would be accountable. 

Q. What form of proof is required?

A. There are no how-to rules for that. Protect yourself. Get it in writing.

Q. My ham friend's station is very much more effective when working DX than is my modest station. Can I use his station with my call sign to work those rare countries that probably would not respond to my station?

A. As far as Part 97 is concerned, yes. He would, in effect, turn his station apparatus temporarily over to your Section 97.5 physical control. Under you would then become the station licensee of record. 

Q. He also has much more time to spend on hunting DX that I do. Could I designate him as the control operator of his station when it is using my call sign even though I am not actually there at the station?

A. As far as Part 97 is concerned, yes. It then would, however, be your station during whatever periods of time that you agree upon for you having physical control of the station apparatus. Under Section 97.103(b), it would be you - the station licensee, albeit temporary - who must designate the station control operator.

Q. How many other hams could make the same arrangements with him?

A. As many as he is willing to enter into similar arrangements.

Q. He is an Extra and I am a General. While he is using my call sign, which frequencies can he use?

A. Because he would be the control operator who has been granted an Amateur Extra Class operator license, Section 97.301 makes available to the station all of the possible transmitting frequency bands. Because his operator class exceeds your General Class, - for which certain frequency segments are not available - Section 97.119(e) comes into effect: an indicator consisting of his station's call must be included after your call sign (your call/his call) in the station identification announcements. This procedure serves to alert our Maintenance Monitors and other observers that your station is authorized to transmit on spectrum not otherwise authorized to your General Operator class of operator license grant.

Q. After I was elected our club station license trustee, I obtained a club station license via one of the club station call sign administrators and swapped its call sign for a vanity. One of our members spotted it on the ULS and - without my knowledge or consent - he went on the air with it. Was that identity theft?

A. You might take that up with your legal counsel. In the meantime, provide him with some remedial instruction about the requirements of Section 97.119(a),with emphasis on the prohibition codified in last sentence: No station may ... transmit as the station call sign, any call sign not authorized to the station. His station, therefore, was improperly transmitting the Section 97.119 station identification announcements without the authorization of the station licensee (you).

Q. How should we go about it whenever I want a club member to use the club station call sign?

A. Firstly, the apparatus comprising any station transmitting your club station call sign in the Section 97.119 station identification announcements must be under your physical control. In a typical scenario, you and the other club member would make arrangements for his/her station apparatus to be under your temporary supervision during the applicable time periods.

  Next, under the authority of Section 97.103(b), designate the club member - assuming he/she is otherwise eligible - as the Section 97.105(b) control operator of that club station.

   Finally, cross your fingers and hope all goes well. Section 97.103 says:

   (a) The station licensee (you) is responsible for the proper operation of the station in accordance with the FCC Rules. When the control operator is a different amateur operator (him) than the station licensee (you), both persons (him and you) are equally responsible for proper operation of the station.

   (b) The station licensee (you) must designate the station control operator (him). The FCC will presume that the station licensee (you) is also the control operator, unless documentation to the contrary is in the station records.

   (c) The station licensee (you) must make the station and the station records available for inspection upon request by an FCC representative (our regulator).

   Documentation of any such arrangements is advised. Read Club Station ID at My QTH BE Informed No. 4.8.                              

Q. Whenever I am the net control for our club's weekly net using my home station, I temporarily become the club's call sign KB3(suffix). Another member says I am W3(suffix) and, therefore, cannot switch to KB3(suffix). Is he right?

A. No one can be a call sign. A call sign is assigned to an amateur station to transmit in the Section 97.119 station identification announcements for the purpose of clearly making the source of the transmissions known to those receiving the transmissions. It enables listeners to ascertain the name and contact information by consulting the ULS.

   As far as switching to the club station call sign in the Section 97.119 station identification announcements, that all depends upon the arrangement that you have made with the club station license trustee.

W3BE-O-GRAM Special Alert

   Every signal transmitted on our amateur service bands should be coming from a readily discernable station. When your station transmits a Section 97.119 station identification announcement, you are informing its listeners that its signal is emanating from a FCC-authorized station. The call sign transmitted can lead a listener to the ULS where the name and address of the Section 97.103 station licensee are shown. This practice should promote more responsible usage of a valuable public resource and discourage pirates from encroaching into our radio spectrum. It is a major deterrent to would-be rule violators. It aids self-policing and discourages interference-causing transmissions and annoying mischief-making because it reveals personal identities. 

  Transmitting properly the station identification announcement is especially critical to our uniquely unstructured radio service when it comes to creating and maintaining a culture of observing the FCC rules and using good amateur practices. It is the reason that there is a call sign system. It should never be compromised. It is basic to our maintaining a high level of rule compliance and promoting proper and efficient use of our allocated spectrum.

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September 4, 2016

Supersedes all prior versions