University/School Amateur Radio club licensing

This discussion pertains to United States of America Federal Communications Commission Part 97 regulations on Amateur Radio.

FCC 47 CFR § 97.5(b)2 lays out the structure for a club station license. In practical terms, this gives amateur radio clubs a memorable callsign of note they can rally around, to build branding, etc. The club station license does not confer operating privileges, but the trustee must hold an amateur radio license.

The trustee will receive FCC official mail, and ARRL LoTW (Logbook of the World) will only sign up clubs through the trustee. Thus clubs should ensure the trustee is someone who actually checks their physical mail, that is on campus at least several times a month on average. The trustee does not have to be be a school employee. However, some club constitution or bylaws require the trustee to be a school employee.

Control Operator vs. Club Trustee

§97.103(b) notes that by default, the station licensee (here, the school club trustee) is the control operator. Even if another person is the control operator, §97.103(a) holds the trustee and control operator equally responsible. Intuitively, §97.105 states the control operator is responsible for “immediate proper operation of the station, regardless of the type of control.”

Student operating privileges

Provided the control operator is in control, anyone operating (including non-licensed persons) may use the control operator’s license privileges. Ideally, the club control operator will have an Extra class ham radio license so that operators get to use maximum privileges. §97.115(b) notes that for third-party communications (someone besides control operator working the radio), the “control operator is present at the control point and is continuously monitoring and supervising the third party’s participation”. Many clubs take §97.115(b) to mean the control operator is physically on site, indeed in the radio room itself.

What happens if the control operator needs to use the restroom? The best practice would be for unlicensed third party operators to stop operating, and for licensed hams to fall back to their own operating privileges. However, what does “continuously monitoring and supervising” mean?

Language barriers

What if the third party is using a language unknown to the control operator? Best practice would be to have the radio operating within privileges of the operator themselves in the case where the control operator does not know the language. Common sense and sensitivity should be applied, particularly in a school setting. Perhaps a solution is to make a policy in the bylaws that in general, extended conversation that is relying on control operator privileges (where the operator is unlicensed or operating beyond their license class) should be in a language known to the control operator. That may help avoid an uncomfortable situation. From my long experience in amateur radio, virtually everyone is on the up-and-up. The problems come from the excessively rigid application of rules, scaring away new and potential hams.