Federal Communications Commission DA 07-4349
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
THOMAS A. WOOLLEY
First Class Radiotelegraph Operator's Certificate 
T100000003
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ORDER OF MODIFICATION
Adopted: October 18, 2007 Released: October 19, 2007
By the Deputy Chief, Mobility Division, Wireless Telecommunications Bureau:
1. Introduction.  In this Order of Modification, we modify the commercial operator license of 
Thomas A. Woolley (Woolley) by modifying his radiotelegraph operator’s certificate from First Class 
Radiotelegraph Operator’s Certificate T100000003 to Second Class Radiotelegraph Operator’s 
Certificate T200000027.  As explained below, we take this action pursuant to an earlier order proposing 
to modify Woolley’s license.1  
2. Background.  To qualify for a First Class Radiotelegraph Operator's Certificate (T1), one 
must pass certain written and Morse Code examinations, and "have one year of experience in sending and 
receiving public correspondence by radiotelegraph at a public coast station, a ship station, or both."2 On 
November 24, 2003, Woolley, who held Second Class Radiotelegraph Operator’s Certificate 
T200000027,3 filed an application for a T1.  The application did not indicate that Woolley had satisfied 
the one-year experience requirement.  Nonetheless, the application was granted on December 11, 2003, 
and Woolley was issued First Class Radiotelegraph Operator’s Certificate T100000003.  Because no 
person may hold more than one unexpired radiotelegraph operator’s certificate at the same time,4
Woolley’s T2 was terminated when his T1 was granted.
3. The Commission subsequently received a complaint that Woolley was not qualified to hold a 
T1.5  In response to an inquiry from the Wireless Telecommunications Bureau, Mobility Division,6
Woolley indicated that he did not meet the one-year experience requirement.7  It thus appears that 
  
1 See Thomas A. Woolley, Order Proposing Modification, 22 FCC Rcd 13609 (WTB MD 2007) (Order 
Proposing Modification).
2 See 47 C.F.R. § 13.201(b)(1)(iv).  
3 To qualify for a Second Class Radiotelegraph Operator's Certificate (T2), one must pass certain written and 
Morse Code examinations, but there is no experience requirement.  See 47 C.F.R. § 13.201(b)(2).
4 See 47 C.F.R. § 13.11(a)(1).
5 See Letter dated August 2, 2005 from Richard Monjure to Federal Communications Commission.
6 See Letter dated January 30, 2007 from Scot Stone, Deputy Chief, Mobility Division, Wireless 
Telecommunications Bureau to Thomas A. Woolley.
7 See Letter dated April 27, 2007 from Thomas A. Woolley to Ghassan Khalek, Mobility Division, Wireless 
Telecommunications Bureau.  He stated that he had filed the T1 application because a Commission employee told 
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Federal Communications Commission DA 07-4349
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Woolley should not have been granted a T1.  Consequently, we proposed to modify his radiotelegraph 
operator’s certificate from First Class Radiotelegraph Operator’s Certificate T100000003 to Second 
Class Radiotelegraph Operator’s Certificate T200000027.8
4. Discussion.  The Order Proposing Modification was released on July 25, 2007.  Woolley did 
not protest the proposed modification of his license within the requisite thirty-day time frame.9  
Accordingly, Woolley is deemed to have consented to the proposed modification.10 Based on the record 
before us, we conclude that it is in the pubic interest to modify Woolley’s radiotelegraph operator’s 
certificate from First Class Radiotelegraph Operator’s Certificate T100000003 to Second Class 
Radiotelegraph Operator’s Certificate T200000027. 
5. Conclusion.  Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) and 316(a) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 316(a), and Section 1.87 of 
Commission’s Rules, 47 C.F.R. § 1.87, the license for First Class Radiotelegraph Operator’s Certificate 
T100000003 BE MODIFIED to Second Class Radiotelegraph Operator’s Certificate T200000027.  
6. IT IS FURTHER ORDERED that this Order of Modification shall be sent by certified mail, 
return receipt requested, to Thomas A. Woolley, 14779 E. Nanry St., Whittier, CA  90605-1851.  
7. This action is taken under delegated authority pursuant to Sections 0.131 and 0.331 of the 
Commission’s Rules, 47 C.F.R. §§ 0.131, 0.331.
FEDERAL COMMUNICATIONS COMMISSION
Scot Stone
Deputy Chief, Mobility Division
Wireless Telecommunications Bureau
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him that the requirement would be waived, in light of the lack of current opportunities to gain the required 
experience.  Id.  To the extent Woolley was told that the one-year experience requirement would be waived, he was 
misinformed.  See Robert E. Griffin, Letter, 22 FCC Rcd 3696, 3696-97 (WTB MD 2007) (denying a request for 
waiver of the one-year experience requirement, notwithstanding the lack of current opportunities to gain the 
required experience).  Moreover, erroneous advice from the staff does not bind the Commission to take an action 
contrary to its rules.  See, e.g., San Diego MDS Company, Memorandum Opinion and Order, 19 FCC Rcd 23120, 
23126 ¶ 13 (2004); Allen Leeds, Order on Reconsideration, 22 FCC Rcd 1508, 1513 ¶ 11 (WTB 2007), review 
pending.
8 See Order Proposing Modification, 22 FCC Rcd at 13610 ¶ 5.
9 See 47 C.F.R. § 1.87(g)(1).
10 See 47 C.F.R. § 1.87(h).