ARRL

ARRL General Bulletin ARLB050 (1998)

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ARLB050 ARRL says scanner proposals could hurt hams

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ARRL Bulletin 50  ARLB050
From ARRL Headquarters
Newington CT  July 15, 1998
To all radio amateurs

SB QST ARL ARLB050
ARLB050 ARRL says scanner proposals could hurt hams

The ARRL has told the FCC that some of its recent proposals to
tighten scanning receiver rules ''constitute severe regulatory
overkill'' and could harm law-abiding amateurs.  The League made the
comments in response to last month's FCC Notice of Proposed
Rulemaking, FCC 98-100 (ET Docket 98-76).

The ARRL said it's ''sensitive'' to the FCC's concern that devices not
be able to readily intercept cellular calls.  But, the League added,
some of the FCC's proposals could result in ''insufficiently defined
regulations'' that would prohibit or unreasonably restrict the making
and selling of ham and test gear.  Some product lines could become
prohibitively expensive or prohibited altogether by the proposals,
the League asserted.

Among other things, the League asked the FCC to avoid requiring
scanning receivers in ham equipment to block access to
frequency-control circuits, and to not entirely prohibit frequency
converter or transverter kits for use in the Amateur Service.  The
League said the net effect of the kits ban would be to prohibit any
frequency converters, even though they would not be used or useful
for cellular reception, and asked the FCC to create an exception for
Amateur Service frequency converters.

The League also asked that amateur receivers not be required to
undergo potentially expensive direct-pickup immunity testing, and it
urged the Commission to more clearly define its proposed rules to
avoid unintended consequences that could adversely affect hams.

The League agreed that some extended coverage ham transceivers have
image responses that make them able to receive cellular signals.
But the League said this is not widespread and ''largely not an issue
in the Amateur Service,'' because the transceivers are not made,
marketed, bought, or used for cellular image reception.
Manufacturers could configure products to preclude cellular image
frequency reception, the ARRL said.

The League said that current language banning the manufacture or
sale of scanning receivers that are ''capable of readily being
altered'' is sufficient.  But the ARRL said requiring tuning and
control circuits be made inaccessible would be ''an overbroad
requirement,'' and that potting or encapsulating frequency-control
hardware ''is simply unnecessary for most amateur equipment.''

The League said such a requirement would limit the ability of hams
to legitimately experiment with or to even repair their own
equipment and could needlessly drive up the cost of ham gear and
make repair expensive or impossible.  ''The potting requirement is
severe regulatory overkill and should not be enacted,'' the League
said.  ''There are sufficient, less burdensome regulations now in
effect and as proposed.''

The League also called the FCC's proposed definition of test
equipment ''unreasonably limiting'' and advised the Commission to
correct the problem by eliminating the word ''professional'' from its
definition.

A copy of the League's full comments is available at
http://www.arrl.org/announce/ET98-76-cmt.pdf
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