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The ARRL has asked the FCC to make clear that Amateur Radio
licensees may modify non amateur equipment for use on Amateur Radio
frequencies. Some hams have expressed concerns that recently
proposed rules would inhibit post sale modification of Wi Fi
equipment, now sometimes altered for use on Amateur Radio
frequencies. The ARRL made its point in comments filed on October 8
on a Notice of Proposed Rule Making, NPRM, in ET Docket 15 170 and
RM 11673. The proceeding mostly addresses proposed amendments to FCC
rules regarding authorization of RF equipment.  The Commission
should clarify that the ability of licensed radio amateurs to modify
and adapt non amateur equipment for use in the Amateur Service is
beneficial, is permitted, and is not restricted by any rule of
general applicability adopted in this proceeding, the League said in
its comments. The ARRL said proposed rules requiring manufacturers
to include security features to prevent network devices from being
modified were problematic, to the extent that they would preclude
hams from adapting network equipment for ham radio applications.
The Amateur Radio Service has a very long tradition of modification
and adaptation of commercial communications equipment, the ARRLs
comments pointed out. Amateur licensees should be permitted to
modify any previously authorized equipment for use under Amateur
Service rules, the League asserted. The proceeding attracted many
comments regarding this aspect of the proceeding, although the
proposed rules differ only slightly from the current rules.  The
ARRL also urged the FCC not to apply any limitations proposed for
Software Defined Radios to SDRs intended for use exclusively in the
Amateur Radio Service, as has been the policy for the past 10 years.
On equipment authorization, the League also has called on the
Commission not to combine the Declaration of Conformity, or DoC, and
Verification equipment authorization procedures into a single, self
approval program. The League said the proposal could lead to abuse
by unscrupulous importers and manufacturers of unintentional
emitters. Under the proposed rules, the FCC would do away with its
DoC authorization program by combining it with equipment
Verification to form a so called Suppliers Declaration of Conformity
category of equipment authorization. Testing in an accredited
laboratory would not be required, nor would database registration or
third party review.  The ARRL expressed concerns that the new regime
would encourage and facilitate the introduction into the US of non
compliant unintentional emitters and offer no oversight.  The ARRLs
comments said, the only opportunity to preclude widespread sale and
deployment of non compliant RF devices, including unintentional
emitters, is via the equipment authorization process.  The League
said hams and AM broadcasters have been victims of interference from
such unintentional emitters as RF lighting ballasts that routinely
exceed the Commissions conducted emission limits.

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