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BE Informed No. 1.7

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Can I Use

Imported Radios?

John B. Johnston W3BE

Q. When the battery in my $300 belt-clip VHF/UHF radio died, rather than buy its replacement, I went online and found it was much less expensive – under $25 - to buy a new radio imported from China. It came with a battery & charger and works just fine. Am I being rule compliant when I use it on our ham bands?   

A. You should be OK whenever 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.

Q. Are they qualified to do that?

A. Amateur operators listed on the ULS have been certified by our Section 97.509 administering VEs as possessing the operational and technical qualifications required to perform properly the duties of an amateur service licensee. It is a fundamental precept that each and every amateur service licensee possess and apply the ability to determine whether or not an amateur station’s transmissions are compliant with the technical standards codified in Part 97 Subpart B Technical Standards Section 97.301 through Section 97.313. This provides the assurance that the transmitting apparatus can be exempt from FCC equipment authorization oversight without unwanted consequence.

Q. Why so?

A. Our regulator does not review amateur station transmitter types. We are supposed to do that. 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. It is the transmitting on our ham bands that we don't want causing disruption. 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. 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 uncertificated 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 Section 97.103 station licensee of the offending station. When that isn't effective, report the particulars to our Maintenance Monitors.  

Q. Can an amateur operator without a commercial license work on an imported programmable radio certified under Part 90?

A. Yes. Holding a Section 97.5(b)(1) operator/primary station license does not disqualify the holder from properly “working on,” i.e., servicing/maintaining/programming, a Part 90 Land Mobile Radio Services transmitter.

Q. But, don’t technicians who work on Part 90 radios have to have a commercial license?

A. No. There are twelve types of commercial radio operator licenses, certificates and permits. Employers and others, however, sometimes accept the possession of a Section 13.5 Commercial Radio Operator License as proof of competence for their own reasons. Some radio- aficionados simply bag them as Government-sponsored trophies.

Q. What then is the regulatory purpose of a commercial radio license?

A. Section 13.5 says there are two radio services requiring FCC station licensees to have certain transmitter operation, maintenance, and repair duties performed by a commercial radio operator. They are Part 80 stations in the maritime services and Part 87 stations in the aviation services.

Q. Who can program a Part 90 Land Mobile Radio Services transmitter?

A. For programming to transmit on amateur service channels, anyone capable of programming the transmitter to be consistent with Part 97, Subpart D Technical Standards.

   For programming to transmit on assigned Part 90 Land Mobile Radio Service channels, anyone capable of programming the transmitter to be consistent with Section 90.203(a): Except as specified in paragraphs (b) and (l) of this section, each transmitter utilized for operation under this part and each transmitter marketed as set forth in §2.803 of this chapter must be of a type which has been certificated for use under this part.

   Section 90.203(e), (f), and (g), however, say:

   (e) Except as provided in paragraph (g) of this section, transmitters designed to operate above 25 MHz shall not be certificated for use under this part if the operator can program and transmit on frequencies, other than those programmed by the manufacturer, service or maintenance personnel, using the equipment's external operation controls.

   (f) Except as provided in paragraph (g) of this section, transmitters designed to operate above 25 MHz that have been approved prior to January 15, 1988, and that permit the operator, by using external controls, to program the transmitter's operating frequencies, shall not be manufactured in, or imported into the United States after March 15, 1988. Marketing of these transmitters shall not be permitted after March 15, 1989.

(g) Transmitters having frequency programming capability and that are designed to operate above 25 MHz are exempt from paragraphs (e) and (f) of this section if the design of such transmitters:

      (1) Is such that transmitters with external controls normally available to the operator must be internally modified to place the equipment in the programmable mode. Further, while in the programmable mode, the equipment shall not be capable of transmitting. The procedures for making the modification and altering the frequency program shall not be made available with the operating information normally supplied to the end user of the equipment; or

      (2) Requires the tramsitter (sic) to be programmed for frequencies through controls normally inaccessible to the operator; or

      (3) Requires equipment to be programmed for frequencies through use of external devices or specifically programmed modules made available only to service/maintenance personnel; or

      (4) Requires equipment to be programmed through cloning (copying a program directly from another transmitter) using devices and procedures made available only to service/maintenance personnel.

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 raises our receiving noise floor.

A. Precisely. A high noise level degrades reception for listeners. Helping keep all superfluous noise to a tolerable 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 complies.

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September 23, 2017

Supersedes all prior editions