Board of Directors
HEADS SHOULD ROLL AT ARRL
Last year, the ARRL board of directors declared that 97.113 bars government employees from participating in amateur radio emergency exercises because doing so gives rise to an unlawful pecuniary interest by virtue of the employee being on a government payroll. ARRL’s nonsensical declaration, which lacks any practical or legal basis was quickly embraced by the FCC’s enforcement counsel. ARRL’s interpretation and FCC counsel’s irrational acceptance of it so outraged the ham radio community that FCC legal bigwigs got an ear full. ARRL mysteriously created a problem where there was none and soon the issue was the subject of the FCC rulemaking process to amend 97.113. In comments filed with the FCC, OEM pointed this out. Judging from the ARRL’s latest article, it clearly is dissatisfied with OEM’s view, and it now attempts to recharacterize its conduct. It can neither change the 2009 declaration nor recast its prior statements – all of which are available for review in many Internet forums. Review the ARRL statements and draw your own conclusions.
ARRL has devoted considerable resources, on its web site and in the pages of QST magazine, to convince the amateur radio community that ARRL is an authority in the area of emergency communications. ARRL sells Amateur Radio Emergency Service (ARES) merchandise and books and on-line courses. However, the ARRL fulfills no supervisory role over ARES volunteers or ensures that ARES members satisfy training benchmarks. ARRL section managers and emergency coordinators provide some supervision, but their effectiveness is arguably marginal in some jurisdictions.
In its June 10 article, ARRL wrongly asserts that “Amateur Radio’s role in emergency communications is to protect against immediate threats to life and property, not for long-term logistical responses to impacted areas after communications infrastructure is restored.” Amateur radio’s role will be defined by the characteristics and impact of each emergency. The detonation of one or more nuclear bombs or biological or chemical weapons in the U.S., a devastating earthquake along the San Andreas or New Madrid fault, or another Katrina-type hurricane, would indeed require long-term involvement of amateur radio operators. ARRL’s failure to recognize this clearly demonstrates that ARRL management is not competent to define amateur radio’s role in emergency communications in any theater.
In our view, ARRL has demonstrated that it is not qualified to render a credible opinion on the subject of emergency communications and has no business telling the FCC how auxiliary communications services (ACS) should be established, promoted, or sponsored. Further, it reveals an ARRL management group so desperate to be perceived as relevant on the issue of emergency communications that it is willing to pursue misguided actions that threaten to gut a viable element in emergency communications – employees of government agencies who hold ham radio licenses.
Why did ARRL issue the declaration on 97.113 in the first place? Was the ARRL general counsel consulted, and if so, how did he advise ARRL on this matter? Perhaps the ARRL concluded that creating a problem where none existed would present a problem it could propose to fix through the rulemaking process, demonstrating that the League is advocating for hams in Washington, D.C. Perhaps there were other motives. Nearly a year after the ARRL board’s declaration, the ARRL has not answered any of these questions.
It is our opinion that placing the 97.113 issue before the FCC in the rulemaking context – as ARRL has done, where no identifiable problem exists, is reckless and reveals a level of incompetence at ARRL’s management level that is potentially destructive. While the FCC has signaled that it will keep the 97.113 issue from exploding in our faces, what will the ARRL administration do next that will place amateur radio in jeopardy? What other section of Part 97 might ARRL place in the rulemaking context, available for comment by any organization or commercial entity whose interests are adverse to our own as amateur radio operators?
ARRL is the largest and perhaps most influential entity representing amateur radio interests in Washington, D.C. Many of us have been ARRL members for many years and we believe in its mission. However, ARRL management, including ARRL directors who supported the 2009 declaration concerning 97.113 have, in our opinion, clearly lost site of their responsibilities to amateur radio, ARRL members, and a core element of amateur radio's public service role. We are of the opinion that no organization that purports to represent its constituents before federal regulators in Washington should engage in what we view as reckless conduct in the regulatory arena - not to mention conduct that has caused uncertainty in the amateur radio community.
Therefore, we call on every member of the ARRL's Executive Committee and all board members who supported ARRL's 2009 declaration on 97.113 to immediately resign. The alternative is for ARRL members to understand how their ARRL director voted on the 97.113 issue and to remember this episode if the director seeks reelection.
In the meantime, the ARPSC and the dedicated amateur radio operators who are Arlington County RACES operators will take their guidance on the issue of amateur radio involvement in emergency communications from the FCC and the Arlington County Office of Emergency Management.
Board of Directors
Arlington Radio Public Service Club, Inc.
July 4, 2010