SB QST @ ARL $ARLB030   
   ARLB030 ARRL Asks FCC to Clarify that Hams May Modify Non-Amateur Gear for   
   Amateur Use   
      
   ZCZC AG30   
   QST de W1AW   
   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."   
      
   NNNN   
   /EX   
      
   )\/(ark   
      
   ... If you're interested, I'll be in my quarters, covered in maple syrup.   
   ---   
    * Origin:  (1:3634/12.73)