OOC Comments

The ARRL Official Observer Program
ARRL South Texas Section
Mark Stennett - NA6M
Official Observer Coordinator
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The Official Observer (OO) program sponsored by the ARRL is one of the "behind-the-scenes" programs that many HAMS don't even know exists or may not have a good understanding of the work of an Official Observer.

All South Texas Section OOs must be either a General Class or Extra Class licensed amateur radio operator. OOs are also required to have been licensed for at least four years and must maintain membership in the ARRL. South Texas Section Official Observers must have the capability to receive, monitor and record conversations on the HF bands.

An OO's monitoring activities isn't confined to the ARRL Section in which he or she is appointed. OOs monitor all United States and its territories amateur frequencies and bands and, at times, interact via a advisory postcard sent to various HAMS throughout the U.S. and it's territories. OOs do not confront or engage in a QSO when he or she is monitoring as an OO.  Any cards sent to fellow amateur operators are intended to be friendly and assist an operator who may have inadvertently violated one of the FCC Rules and Regulations. (This is often the case with newly licensed HAMS.) The great part of the work is when an OO hears a fellow HAM who is exhibiting outstanding amateur radio practices. In these cases, a "Good Operator Card" is mailed to the HAM to affirm their contribution and commitment to high quality in amateur radio on-the-air operations. The work of an OO isn't to talk, but to listen. Most people who talk with an OO on the air are usually not aware that the person is an OO. One of the guidelines for OOs is that they don't send a fellow HAM a card about a possible FCC violation that may have occurred while the OO was in a QSO with the person.

All applicants to be an OO complete the on-line application and then the ARRL sends the application to the Official Observer Coordinator (OOC) of the ARRL Section in which the HAM lives. It is the Official Observer Coordinator's responsibility for the Section to recommend approval or disapproval for the candidate to be allowed to take a very comprehensive examination on FCC Rules and possible OO actions in various situations. As the South Texas Section OOC, I personally always call all applicants on the telephone to talk for a while about what the program is and is not. These phone conversation usually are about 15 to 30 minutes long.  Being an OO isn't for everyone. It takes a lot of patience and an ability to make informed decisions. OOs have NO ENFORCEMENT authority! Candidates for the program must understand that OOs are NOT radio cops.

After an affirmative recommendation by the OOC, the ARRL Field Services Offices sends the applicant an up-to-date FCC Rule book, the ARRL Official Observer Manual and a comprehensive examination. Many applicants start the examination and do not complete it because they find that there is a lot of knowledge required to be an OO and they don't want to go to that much effort. Because it is so comprehensive, unfortunately, there are many who do not pass the OO examination. If the applicant passes the examination, they are then appointed by the ARRL as a Certified Official Observer. At that point they are sent additional material they will need to function as an effective OO as well as an OO Appointment Certificate signed by the Field and Education Services Manager and the Section OOC. After signing, I send the certificate and a letter of congratulations to the newly certified OO. All OOs (including the OOC) must file a monthly monitoring activity report. These monthly reports are sent by email as attachments each month to the OOC, who in turn forwards them with any other necessary information to the ARRL Field Office.

In the South Texas Section, all newly appointed OOs are in a probationary period for six months after appointment by the ARRL. During this time, the OOC carefully monitors the new OOs activities and any OO cards that are mailed to fellow HAMS to ensure that the OO understands the proper procedures for handling monitored situations in which another HAM may have inadvertently violated an FCC Rule. There are times, unfortunately, when an OO may consistently try to exceed his or her authority and create more problems for the program and fellow HAMS through ignorance of proper procedures or refusal to accept recommendations from their OOC about their operations as an OO. In these few cases, the OO Manual is clear that the OOC has the authority and responsibility to decertify and remove any OO who cannot or will not follow the established guidelines by ARRL.

When a HAM receives a card from an OO, no response is ever needed. When someone receives a card from an OO indicating that someone using that HAM's call sign has possibly violated an FCC Rule the receiving HAM can throw the card in the trash can if desired because OOs have NO ENFORCEMENT AUTHORITY. Most of the time, however, the HAM simply didn't know that certain things are not permissible by the FCC on amateur frequencies and they appreciate the educational value of the card. This happen a lot with newly licensed amateur radio operators. At times an OO may receive a request to take some sort of action about a situation. A solid rule of procedure for OOs is that if they didn't personally hear it, it didn't happen. Complaints from HAMS about other HAMS often want intervention by an OO. An OO can take the information and monitor the air ways for the situation, but an OO card will not be sent or reported up the chain unless the OO personally hears a violation by the alleged violator(s).

Of course, regrettably, there are those times when some violations are intentional and further action is needed. OOs do a lot on recordings of on-the-air QSOs which are usually erased. However, when a fellow HAM has been sent a reminder about a possible violation of an FCC Rule and the HAM continues to intentionally violate an FCC Rule or Regulation, an OO then sends a recording of the QSO to the OOC, who then must make a determination of whether or not a violation may have occurred. If the OOC concurs with the OO's findings, he then forwards the recording and other pertinent details to the ARRL Field Office for their determination and possible forwarding of evidence to the FCC Enforcement Bureau. There are times when the FCC attorney whose full time job is working with amateur radio enforcement issues will communicate with an OOC by email or telephone on certain situations to gain any clarifications needed. Laura Smith is the FCC's Special Counsel for Enforcement of Part 97 of the FCC Rules. She is a strong supporter of the ARRL's OO program and is available to any HAM via email or telephone (however, it may take her several days to reply due to her workload).


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Q. What is the Amateur Auxiliary?
A. The Amateur Auxiliary is composed of approximately 700 ARRL volunteer-appointees, known as "Official Observers" or "OOs," across the country who monitor the bands and notify amateurs of technical and operating discrepancies as a service to their fellow hams. OOs are helper-advisors, not "band cops." In cases involving serious rule violations such as malicious interference, however, they are trained and certified to gather and forward evidence that can be used by the FCC in enforcement actions.
The program is based on a formal agreement between the FCC and the ARRL.

Q. What are its objectives?
A. The general objectives of the program are to:
1. Foster a wider knowledge of and better compliance with the FCC rules;
2. Extend the concepts of self-regulation and self-administration in the Amateur Service;
3. Enhance the opportunity for individual amateurs to contribute to the public welfare; and
4. Enable the Enforcement Bureau of FCC to efficiently and effectively utilize its limited manpower and resources.

Q. So, the OO is there to help me?
A. Yes! The role of the Amateur Auxiliary is to provide an unbiased forum for technical and operational advice and other assistance to amateurs who are receptive. The task is not to find fault or lay blame! It is to identify cause and effect, many of which are not based upon technical but behavioral or social issues, and to find ways to achieve solutions to promote good amateur operating and engineering practice on our bands.

Q. Are OOs allowed to enforce the rules?
A. No! The mission is NOT enforcement. Enforcement is a function reserved exclusively by the FCC. Because the boundary between observation and enforcement is not always obvious, mature judgment is clearly required of Auxiliary members and its leadership. The Auxiliary, to be viable and effective, must avoid the appearance of enforcement. It must also avoid the appearance of having a vested interest in any specific type of amateur operations or of being sympathetic to amateur groups which advocate specific activities or causes. OOs are not to be involved in cases where they have a personal interest. They must be totally objective.

Q. Do OOs deal with RFI problems?
A. No. The Amateur Auxiliary is designed to deal ONLY with amateur-to-amateur interference and improper on-air operation by amateurs. RFI complaints are not within the scope of the program.

Q. Do OOs deal with non-amateur intruders or "bootleggers"?
A. No and yes! Reports of non-amateur HF intruders (a foreign broadcast station, for example) are sent to ARRL HQ for referral to the ARRL Monitoring System, a separate program. Cases involving "bootleggers" on repeaters or elsewhere are within the scope of the Auxiliary program.

Q. How are repeater "jammers" handled?
A. A component of the Amateur Auxiliary program, Local Interference Committees (LIC) are commissioned by the ARRL Section Manager with an OO as chairman to track down and resolve repeater jamming problems. If the problem persists, the LIC may develop the package of evidence that the FCC can use to base an enforcement action. LIC members are experts in direction-finding techniques, use good judgment in the art of negotiation to bring about resolutions and often have a ham-attorney as a member.

Q. How are repeater-to-repeater interference and coordination disputes settled?
A. They are usually settled locally or regionally, by the parties to the dispute and the affected user community. Such matters, however, may come to the attention of the Amateur Auxiliary program when harmful interference is caused by a non-coordinated repeater to a coordinated repeater. The non-coordinated repeater bears the primary responsibility of cleaning up the interference, under the FCC Rules.

Q. Isn't the OO doing work that should more properly done by the FCC?
A. Amateur Radio monitoring and enforcement are low priorities at the FCC. Time and time again, the FCC has indicated that we're largely on our own in keeping our operating standards and spectrum in shape. The Amateur Auxiliary program and its OOs are the League's answer to this challenge.

Q. What can be done about interference on the HF bands?
A. Interference is a fact of life on today's crowded HF bands and most of it is of the "no-fault" kind that's better resolved by being flexible than by confrontation. Interference in and of itself is not illegal. Only malicious interference is actionable under the rules. It exists in its clearest form when the following conditions are met:
1) Two or more stations are in communication on a frequency.
2) Another station begins transmitting on the same or an adjacent frequency.
3) The original stations, acknowledging on-the-air that they cannot copy one another through the interfering station's transmissions, and decide to move to another frequency.
4) When they move, the interfering station follows and commences interfering transmissions again.
Additionally, it must involve an ongoing campaign on a regular, repeated basis: No one can reasonably expect the FCC and/or the Amateur Auxiliary to act on a one-time, isolated event.

Q. What can be done about hams that make rude remarks, racial slurs, or transmit obscene or indecent words?
A. Much of what is heard is inappropriate and violates standards of polite society, but it is not illegal. Only obscene or indecent transmissions are illegal. See the League's FCC Rule Book for a discussion of how the FCC defines the standards for obscenity and indecency. Serious cases can be referred to the Amateur Auxiliary for handling.
Language that's inappropriate, but not illegal, or isn't so serious that we can reasonably expect the FCC to devote resources to its correction, must be addressed by the amateur community itself. We must not let the bad behavior drive out the good: Each of us who cares about Amateur Radio must maintain the highest possible standards when operating, even in the face of provocation. We must let other amateurs know, as politely as possible, that we expect them to observe the same standards.

Q. I got an OO card in the mail! What do I do now?
A. First, don't worry: This is not a citation! The OO post card is simply a friendly note to alert you to possible equipment factors or operating practices that might have contributed to an apparent departure from a rule or the good amateur practice standard. Remember, OOs are friendly helper-advisors, not the "radio police"! Their mission is to assist those who are receptive to being assisted.

Q. Do I have to reply to the notice?
A. No reply is necessary! You may want to take a few minutes to determine what caused the apparent problem, and then take steps to fix it. Most likely, you're proud of your license and the work you've put into getting it--you want to have the same pride in the quality of your signal and operating practices. Your corrective actions might even head off an FCC "pink slip" down the road.

Q. The card seemed a little nit-picky to me. Do OOs send cards for discrepancies that lie in the gray area between black and white rules violations?
A. OOs are advised to avoid hair-splitting and to deal only with black-and-white rule discrepancies only. They should avoid the "gray areas" of the rules. OOs should not be nit-picky either. For example, an OO should not send a notice to someone who forgot to identify his station for ten minutes and eight seconds! If you feel that the OO sent you a notice that violates the principles of the program, send a copy to your Section Manager (if known) or to Headquarters for evaluation and possible action. Quality control is critically important in a program as sensitive as this one!

Q. Is a record of the notice kept anywhere?
A. Yes. A record of the notice is kept at ARRL Headquarters for a period of one year, after which it is destroyed. Records are kept so that if a case evolves into a serious, hard-core compliance issue, it may be used by the FCC as evidence, showing that voluntary measures of achieving resolution were ineffective. The information is also used to guide OOs in special monitoring efforts. Otherwise, the information is kept strictly confidential and is never released outside of the Auxiliary.

Q. Hey, I received a Good Operator Report. What's that for?
A. Congratulations! To emphasize the positive nature of the program, "Good Operator Reports" are sent to operators whose radio signals and/or operating practices are consistent with the highest standards and are a model for others to follow. Every amateur should strive to pattern their operating and signals after your example!

Training and Certification

Q. Are OOs trained and/or certified to perform their functions?
A. Yes! All OOs must pass a comprehensive examination based on a set of study materials, before they can be certified as members of the Amateur Auxiliary. These materials include an extensive training manual, The FCC Rule Book, and the ARRL Handbook. Many don't pass.

Q. How can I apply to be an OO?
A. It's not a job for everybody: An OO will observe some operating that will fill him or her with a sense of frustration. There's also no room in the program for "band cops." OOs gain their rewards when they're able to call an undesirable situation to the attention of someone who honestly wasn't aware of it, and who is genuinely appreciative of the assistance. To apply to become an OO in the South Texas Section, one can complete the on-line application at:
http://www.arrl.org/FandES/field/forms/fsd187/form.html