I'm specifically focusing this question on methods to get official clarification where one doesn't currently exist. I am not asking this audience for interpretations.
As part of my volunteer work with CERT, we're exploring a number of communication scenarios in training, exercises, and responses in conjunction with the city government apart from when we have ARES/RACES available. As you might guess from the above, our situation is touched on by several Part 97 rules, but not exactly on-point at least as far as we're able to interpret.
I've exhausted, to the best of my ability, web searches including documents at the FCC.gov and ARRL, and documents like the National Interoperability Field Operation Guide (NIFOG) and the National Telecommunications and Information Administration (NTIA) Red Book. Posting our specifics may get a variety of armchair interpretations (with all due respect, we have plenty), but we're looking for authoritative sources.
Where would I go next? Examples of someone's experience doing this and tips would be great. Even this may be overly opinion based, but here goes.
- Directly to FCC? Start with 888-CALL-FCC?
- ARRL, then possibly FCC? I don't see ARRL as authoritative, but may be a resource for helping obtain an authoritative answer that would benefit other groups across the nation.
- A lawyer who would then assist in one of the above?
- Make a good faith attempt to document how we non-lawyerly types have interpreted the rules, and then engage in the conversation if someone comes knocking if we put it into practice? (I've got a long list of "not quite the answer" links so far on for our situation, but this doesn't seem like a long-term solution.)
To give a flavor of some of the complication of our situation, without asking for your help interpreting the rules:
- CERT is primarily volunteer, but we operate under mission numbers from the state. There's a big intersection here between government and amateur, and there may be specific rules that apply.
- FCC 97.403 is the most directly on point for our main mission, but it does not directly address training and exercises.
- 90.407 is even more specific, but for a different radio service.
- 90.411 mentions civil defense activities, including simulated emergency, including drills and tests. However, this is a different radio service.
- 97.111 touches on aspects of us, given this is about relief actions (2), emergency communications (3), and our missions would be on behalf of local government - though section (4) mentions RACES.
- And then we stray into limited use of amateur radio stations in emergency situations, exercises/drills, or training by non-HAMs. Typically these are HTs in a defined and controlled location, with licensed Hams on-channel and in charge as part of incident command. This is open to interpretation whether in the specific circumstances they can be considered control operators, very broadly covered in (97.7 and 97.105) and station control (97.109).