FCC Denies Petition to Increase Size of Amateur Radio Question Pools

I got this via an ARRL maililng list.

We can argue about whether or not the tests should be more difficult, and I think a case could be made that the Extra Class test should be tougher, but I’m a bit aghast that the FCC says in this denial that,

the purpose of the examinations is not to demonstrate an applicant’s comprehension of certain material, but rather to determine whether he or she can properly operate an amateur station.

If that were the case, then why even bother with having three different classes of license? This just doesn’t make any sense to me. How about you?


ARRL Bulletin 16 ARLB016
From ARRL Headquarters
Newington CT March 20, 2009
To all radio amateurs

ARLB016 FCC Denies Petition to Increase Size of Amateur Radio Question Pools

In April 2008, Michael Mancuso, KI4NGN, of Raleigh, North Carolina, filed a petition with the FCC, seeking to increase the size of the question pools that make up the Amateur Radio licensing exams.Mancuso sought to increase the question pool from 10 times the number of questions on an exam to 50 times more questions. On March 19, 2009, the Commission notified Mancuso that it was denying his petition.

In his 2008 petition, Mancuso claimed that the current question pool is too easy to memorize and “that there has been a significant increase in the number of Amateur Radio operators receiving their licenses over at least the last decade or more who do not appear to possess the knowledge indicated by the class of license that they have received. Most discussion about this topic, both on the air and on Internet forums, generally refers to these widespread observations as the ‘dumbing down’ of Amateur Radio. It has been widely assumed that the cause of this observed situation is based upon the subject material addressed by the license examinations, that the material requirements specified for the examinations does [sic] not meet some minimum level of knowledge expected by some or many in the Amateur Radio community.”

The FCC pointed out to Mancuso that each applicant for a new or upgraded Amateur Radio operator license “is required to pass a written examination in order to prove that he or she possesses the operational and technical qualifications required to perform properly the duties of an amateur service operator licensee, i.e., that he or she is qualified to be an amateur service licensee.”

The Commission summed up Mancuso’s petition, saying, “You argue that the current question pool size is no longer adequate, because online practice examinations enable examinees to memorize a question pool without fully comprehending the subject matter being tested. Consequently, you propose to increase the size of the question pools, in order to hinder memorization.”

The Commission concluded that Mancuso did not present grounds for the Commission to amend its rules: “As noted above, the purpose of the examinations is not to demonstrate an applicant’s comprehension of certain material, but rather to determine whether he or she can properly operate an amateur station. Moreover, your contention that there has been ‘a significant increase in the number of Amateur Radio operators…who do not appear to possess the knowledge indicated by their class of license’ is not supported by any data or facts.”

The FCC pointed out to Mancuso that the Commission’s Rules only dictate the minimum number of questions for each question pool for the three Amateur Radio license classes. This, the Commission told Mancuso, “does not prevent the National Conference of Volunteer Examiner Coordinators (NCVEC) from increasing the number of questions in a question pool should it decide that this is appropriate. We conclude, therefore, that the petition presents no evidence of an existing problem or other reason for a rule change.”


  1. The connection between the content of the testing pool and the ability to operate an amateur radio station is extremely tenuous at best. If we were serious about testing whether or not someone can operate an amateur radio station, there’d be a practical test: put the examinee at the controls of a (simulated) station and see if they can successfully operate it.

    I have to admit that the knowledge I use in the operation of my station doesn’t intersect all that often with the knowledge I memorized in order to gain my license. I mostly operate on 2 meters, so the knowledge I use most has to do with things like the effects of weather, terrain, and antenna placement on propagation, and the common courtesies and practices when operating simplex vs. repeater and two-way QSO vs. informal roundtable vs. formal net. None of this is directly tested by any of the question pools; it has to be learned by the licensee separately, and usually on the fly after the license is granted.

    Different modes of operation have different common courtesies and practices, and learning them all takes quite a while. Which ones should we test, and how?

  2. Bryan K4AVE says:

    On amusing aspect I’ve run into recently is that A) on one hand the old timers feel the new guys don’t know anything and just because they have a license doesn’t mean they don’t need additional training and B) these same old timers don’t want to be required to take the FEMA/NIMS training courses because they took a test 20 years ago so they know what they are doing. lol!

  3. Dan KB6NU says:


    I don’t know that I’d say that it’s “extremely tenuous,” but if that really is the purpose of the amateur radio examinations, then perhaps more attention needs to be given to those topics. It sounds to me that it might be worthwhile for the NCVEC to sit down with the FCC and discuss the objectives and methods of the testing program.

    Having said all that, is this really a big problem? Yes, some licensees got their licenses by memorizing the answers, but so what? They’re not causing rampant interference or harming anyone. And if they were, we could step up our self-policing activities.

  4. David Brodbeck N8SRE says:

    I think the best point in the FCC’s response is actually the last one — that they only dictate the MINIMUM number of questions. If the NCVEC decided they wanted a bigger pool, they could do it without the FCC getting involved. To my mind this is a good response because it fits nicely into the self-regulating nature of amateur radio.

    People who feel the questions need to be harder or more numerous should take their concerns to the NCVEC, not pester the FCC.

  5. Earl kc2ulm says:

    I’m a newbie to ham radio, and prior to studying for the Tech exam, knew absolutely zero about the hobby. And yes, I did basically memorize the questions for the Tech exam. So what? The exam process forces you to go over several hundred questions, peaks your interest, and gives you the fundamentals. You gotta start somewhere.

    There’s so much diversity to amateur radio that the real education comes after you’ve passed your test. A majority of hams I’ve met are enthusiastic and eager to learn more. I consider the exam as a starting point only.

    So instead of petitioning to make it more difficult to access a hobby, be an Elmer, share your (vast) knowledge, and help get folks excited about it.

  6. Dan KB6NU says:

    I agree, Earl, and that’s the philosophy behind our One-Day Tech Class. I think by the time you go for your General, and certainly by the time that you go for your Extra, that actually knowing the material is a good thing. Not so much because you need to prove yourself, but rather that you’ll have a lot more fun if you know what you’re doing.

  7. rick ''ryan'' garvin says:

    i have been studing for my test for sometime now…a former broadcast newsman, i want to understand the questions and not just the final answers…its the applied way to learn for me…the hardest part is the voltage,current,ohms part…..the rest is not at all hard….if anyone has any ideas please reply….thanks……rick in fayetteville,nc

Speak Your Mind