In comments filed November 5, the ARRL has recommended that the FCC continue to provide paper license documents to Amateur Radio licensees who want them. The League’s remarks were in response to an FCC Public Notice (in WT Docket 14-161) that proposed to cease the routine issuance of hard-copy license documents to all Wireless Service licensees, including radio amateurs. While having a paper license document from the FCC to post on the wall of the ham shack has been a tradition, the Commission for several years has considered the “official” Amateur Radio license to be the virtual document residing in its Universal Licensing System (ULS) database.

“The FCC is willing to continue to mail paper licenses to those who request them,” ARRL General Counsel Chris Imlay, W3KD, has explained. “However, they are making available to licensees — starting right now — the actual license to print via the FCC ULS, and it is allowing hams now to opt out of receiving paper licenses from the FCC directly.” (See ULS menu image.)

Under the FCC-proposed process, once a license application is granted, the ULS will generate an official electronic license but will no longer mail a hard copy license unless notified that the licensee wishes to receive an official paper license document. Until new procedures are final, however, the Commission will continue to print and mail official paper licenses, unless notified to stop.

“Should the Commission proceed with the Notice proposals,” the League said in its comments, “it is ARRL’s strong recommendation that the Commission give serious consideration to continuing a default provision for sending an initial paper license document to new licensees in the Amateur Radio Service, along with detailed, simple instructions for how to make the elections set forth in the notice relative to future modified or renewed licenses.”

The ARRL pointed out that not everyone has easy access to, or is comfortable using, the ULS and that Amateur Radio licensees may occasionally need an official license document — for example, when applying for a license upgrade at a VEC exam session or for vehicle call sign license plates.

“If there is not a license printed on distinctive license stock by the Commission, authentication issues arise and the possibility of electronic alteration of a license document is created,” the League.

The ARRL also suggested that requiring individuals to go online in order to obtain a license document may prove to be a roadblock to some applicants.

“It is not acceptable to erect barriers to entry for anyone to obtain an Amateur Radio license or to modify a license,” the League commented. “ARRL is concerned that there should be, especially for newcomers, an easy, intuitive path to make the election for license delivery method that does not involve ULS access at the outset.”

The Notice also proposes, alternatively, that the FCC send the official electronic license via e-mail upon grant of an application, if the applicant has provided a valid e-mail address on the application form. Licensees not wanting to provide an e-mail address could obtain an official electronic license document directly from the ULS. The Notice further proposes that licensees could notify the Commission that they wish to receive or continue receiving official authorizations on paper.

The ULS License Manager online system now includes a setting that allows licensees to notify the FCC that they want to receive official licenses on paper. Licensees could change the default setting online, so that once an application has been granted, the FCC would mail an official paper license.

The deadline to file comments is November 10.