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ARRL General Bulletin ARLB030 (2015)

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ARLB030 ARRL Asks FCC to Clarify that Hams May Modify Non-Amateur
Gear for Amateur Use

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ARRL Bulletin 30  ARLB030
From ARRL Headquarters  
Newington CT  October 14, 2015
To all radio amateurs 

SB QST ARL ARLB030
ARLB030 ARRL Asks FCC to Clarify that Hams May Modify Non-Amateur
Gear for Amateur Use

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 NPRM can be
found on the web in PDF format at,
https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-92A1.pdf .

"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 ARRL's
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."

Equipment Authorization

The League also has called on the Commission not to combine the
Declaration of Conformity (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 ARRL's 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 Commission's conducted emission
limits." The ARRL said the solution is "not to loosen but to tighten
the procedural controls over the testing and affirmative
confirmations of compliance" to ensure greater compliance in
conducted limits and other technical parameters that determine how
much such devices contribute to ambient noise levels.

The League said some RF devices, such as RF "grow lights," now
subject to the more informal Verification process should be subject
to Certification, owing to their substantial interference potential.
The ARRL noted that it has received and investigated "numerous
reports of interference" from devices subject only to Verification.
"A number of interfering devices, when tested by the ARRL
Laboratory, have been found to exceed the FCC limits, sometimes by
an alarming amount," the League said.

Improved Labeling for Part 15 and Part 18 Devices

The ARRL also said there is "an urgent need" for improved labeling
requirements for certain Part 15 and Part 18 devices. "Necessitating
change, notably, is the fact that there are many industrial Part 18
devices sold that are neither intended nor designed for use in
residential environments, but because there is no external
labeling...the end user consumer is left without guidance," the ARRL
said, noting that, in most cases, equipment retailers are not
providing any either.

In July, the ARRL complained to the FCC about the marketing
practices of various "big box" retailers, where non-consumer-rated
lighting ballasts have been mixed in with consumer ballasts and
other consumer products on display with no explanatory signage.
Ballasts intended for industrial applications have higher permitted
conducted emission limits in the Amateur Radio HF spectrum. The
League called on the FCC to include a definition in Part 18 for the
term "consumer RF lighting device," to provide a way to
differentiate consumer devices from those intended for industrial or
commercial environments.

The League also said the FCC should consider reducing its Part 15
limits for lighting devices to correspond with the Part 18 lighting
device limits between 3 and 30 MHz to reduce the RFI potential of
LED bulbs now being widely marketed, "before they become an
aggregate problem." LED lamps operate under Part 15 rules.

The ARRL said the FCC should adopt the League's new
equipment-labeling proposals with respect to certain Part 15 and
Part 18 equipment "in order to stop the flood of such devices
intended for commercial or industrial areas only into residential
areas."
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