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 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.”