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BE Informed No. 1.7

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Can I Use

Chinese Radios?

John B. Johnston W3BE

Q. Those less-expensive belt-clip Chinese VHF/UHF radios seem to be too good to be true. Am I being rule compliant when I use them on our ham bands?   

A. You should be if the particular model is already being used in places where the FCC regulates our amateur service. Here, each Section 97.103 Station licensee is supposed to have made certain that the signal radiated from their station is in complete harmony with the technical standards codified in Part 97, Subpart D, Section 97.301 through Section 97.313.

   Our regulator does not review amateur station transmitter types. Rather, the examination that you passed proved that you possess the operational and technical qualifications that our VEs judge necessary to perform properly the duties of an amateur service licensee. You are the only one accountable for your amateur station being compliant with the pertinent technical standards in Part 97.

   Your Section 97.17(a) amateur operator/primary station license grant authorizes you to cause or allow a Part 97-amenable amateur station to transmit using apparatus from China – or anywhere else. Anyone may design and construct amateur station apparatus. In fact, building one’s station apparatus was the accepted practice during much of the early years of ham radio. Still another rewarding activity for acquiring amateur station apparatus is kit-building. In the 1950s-1960s, the offerings from Heath, EICO, Knight, et al, delighted an entire generation of hams. They educated us on the inner-workings of our apparatus, and familiarized us with the assembly practices of the day. They helped us maintain amateur service community peer respect while bridging the gap between rolling our own or buying a factory-made transmitter.     

   Adapting radio apparatus that was originally produced for other applications is also an allowable amateur practice. World War II surplus apparatus was a bonanza for a host of projects because much of it was designed for use on our amateur service spectrum. That inexpensive mother lode turned out to be our unexpected payback for relinquishing our spectrum for the duration. Later on, modifying castoff Part 90 private land mobile transceivers opened the door to our pioneering VHF repeaters and hand-held radios. 

Q. How well does that self-policing arrangement work in practice?

A. So far, it has worked amazingly well. Experts worldwide from many diverse fields are attracted to our amateur service because its open system architecture and idealized technical standards encourage the making practical of cutting-edge technology. Their curiosity-driven endeavors characteristically bring us the very best radio techniques obtainable. That - and our capacity to rapidly interchange hands-on performance reports - assures that inferior apparatus is expelled promptly from our airwaves. 

Q. An advertisement states that a Chinese radio model is FCC Part 90 type accepted. I have just assumed that anything good enough for the private land mobile service Part 90 must certainly be good enough for our amateur service Part 97. But, I realize now, that was just my intuition, not a provable observation. Do you know of any study that compares them requirement-by-requirement?

A. No, nor also any comparisons with the transmitter certification requirements for Part 80 Stations in the Maritime Service or for Part 95 Personal Radio Services. Expectations from some experts, however, are that any such analysis would likely come down to a comparison between the simplified amateur service emission standards codified in Section 97.307 and their more sophisticated counterparts codified in the private land mobile general technical standards, Sections 90.201 – 90.219

Q. What is Part 90?

A. Part 90 codifies the rules for the private land mobile radio services. Those rules establish a public safety radio pool and provide for the licensing of non-federal governmental entities - including law enforcement and fire protection – as well as medical services, rescue organizations, veterinarians, persons with disabilities, disaster relief organizations, school buses, beach patrols, establishments in isolated places, communications standby facilities, and emergency repair of public communications facilities. 

Q. For one thing, private land mobile service Part 90 includes standards regarding transmitted bandwidth and frequency stability that do not likewise appear in our amateur service Part 97.

A. Correct. Those precautions are obviously needed to facilitate transmitter usage by unlicensed operators and provide the adjacent channel protection required for the Part 90 assigned-channel band-plans. For amateur radio, that concern is addressed by Section 97.101 where it says:

   (a) In all respects not specifically covered by FCC Rules each amateur station must be operated in accordance with good engineering and good amateur practice.

   (b) Each station licensee and each control operator must cooperate in selecting transmitting channels and in making the most effective use of the amateur service frequencies. No frequency will be assigned for the exclusive use of any station.

   (c) At all times and on all frequencies, each control operator must give priority to stations providing emergency communications, except to stations transmitting communications for training drills and tests in RACES.

   (d) No amateur operator shall willfully or maliciously interfere with or cause interference to any radio communication or signal.

Q. It is our own amateur service community that suffers degraded reception due to high noise levels created by overly broad signals transmitted by other amateur stations. What is our recourse?

A. First, enlighten the control operators of the offending stations. When that isn’t effective, report the particulars and the station call sign to our Maintenance Monitors. 

Q. A modern ham transceiver is usually more than just a transmitter. It often also includes a receiver, an antenna, a power source and control circuitry. So, there can be unintentional radiation emitted from a poorly-designed unit that acerbates our receiving noise background.

A. Precisely. Helping keep all superfluous noise to a reasonable level is one of the purposes of Part 15. It contains the technical specifications, administrative requirements and other conditions relating to the marketing of radio frequency devices. Oftentimes, when a claim is made that a device is FCC approved, it means that it is compliant with Part 15.

Q. What is the meaning of the term radio frequency device?

A. It is an apparatus which, in its operation, is capable of emitting RF energy by radiation, conduction or other means in sufficient degree to cause harmful interference to radio communications. There are intentional radiators and there are unintentional radiators. But, for various reasons, a radio frequency device doesn’t make the final cut in being classified as a full-fledged transmitter that would involve user FCC licensure. Electronic devices, rather, are reviewed for compliance with Part 15 standards before they can be advertised or sold in the United States. Read SEC. 302 of the Communications Act.

Q. How does Part 15 apply to amateur operators?

A. It primarily brings us benefits from lowered radio reception noise levels. The burden for Part 15 compliance is on the device advertiser/seller. We rely upon acquiring a device from a trustworthy seller as our assurance that it is in compliance.

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January 20, 2017

Supersedes all prior editions