I have spent some time this week
reviewing the NPRM and comparing it to the existing rules. I
am attaching the NPRM because the Federal Register summary
of the NPRM is sometimes cited rather than the NPRM itself,
which can lead to confusion.
What is giving rise to at least some of
the concerns being expressed are existing provisions in the
rules that are simply being rearranged and are not new at
all. For example, Section 2.1033(b)(13) now reads:
(13)
Applications for certification of U-NII devices in the
5.15-5.35 GHz and the 5.47-5.85 GHz bands must include a
high level operational description of the security
procedures that control the radio frequency operating
parameters and ensure that unauthorized modifications cannot
be made.
This is identical to proposed Section
2.1033(b)(10):
(10)
Applications for certification of U-NII devices in the
5.15-5.35 GHz and the 5.47-5.85 GHz bands must include a
high level operational description of the security
procedures that control the radio frequency operating
parameters and ensure that unauthorized modifications cannot
be made.
Similarly, proposed Section 2.1042(e) has
been cited as a cause for concern. It reads:
(e) Manufacturers of any radio
including certified modular transmitters which includes a
software defined radio must take steps to ensure that only
software that has been approved with a particular radio
can be loaded into that radio. The software must not allow
the installers or end-user to operate the transmitter with
operating frequencies, output power, modulation types or
other radio frequency parameters outside those that were
approved. Manufacturers may use means including, but not
limited to the use of a private network that allows only
authenticated users to download software, electronic
signatures in software or coding in hardware that is
decoded by software to verify that new software can be
legally loaded into a device to meet these requirements.
However,
existing Section 2.944 reads:
§2.944 Software
defined radios.
(a)
Manufacturers must take steps to ensure that only software
that has been approved with a software defined radio can be
loaded into the radio. The software must not allow the user
to operate the transmitter with operating frequencies,
output power, modulation types or other radio frequency
parameters outside those that were approved. Manufacturers
may use means including, but not limited to the use of a
private network that allows only authenticated users to
download software, electronic signatures in software or
coding in hardware that is decoded by software to verify
that new software can be legally loaded into a device to
meet these requirements and must describe the methods in
their application for equipment authorization.
(b)
Any radio in which the software is designed or expected to
be modified by a party other than the manufacturer and would
affect the operating parameters of frequency range,
modulation type or maximum output power (either radiated or
conducted), or the circumstances under which the transmitter
operates in accordance with Commission rules, must comply
with the requirements in paragraph (a) of this section and
must be certified as a software defined radio.
(c)
Applications for certification of software defined radios
must include a high level operational description or flow
diagram of the software that controls the radio frequency
operating parameters.
Paragraph 69
of the NPRM says, “…we believe modifications by third
parties should not be permitted unless the third party
receives its own certification.” That might well be a
concern, but we already have a rather generous provision
that allows amateurs to modify equipment for use in their
own stations. Existing 2.1043(e) reads:
(e)
Equipment that has been certificated or formerly type
accepted for use in the Amateur Radio Service pursuant to
the requirements of part 97 of this chapter may be modified
without regard to the conditions specified in paragraph (b)
of this section, provided the following conditions are met:
(1)
Any person performing such modifications on equipment used
under part 97 of this chapter must possess a valid amateur
radio operator license of the class required for the use of
the equipment being modified.
(2)
Modifications made pursuant to this paragraph are limited to
equipment used at licensed amateur radio stations.
(3)
Modifications specified or performed by equipment
manufacturers or suppliers must be in accordance with the
requirements set forth in paragraph (b) of this section.
(4)
Modifications specified or performed by licensees in the
Amateur Radio Service on equipment other than that at
specific licensed amateur radio stations must be in
accordance with the requirements set forth in paragraph (b)
of this section.
(5) The
station licensee shall be responsible for ensuring that
modified equipment used at his station will comply with the
applicable technical standards in part 97 of this chapter.
Paragraph 113
of the NPRM includes the following invitation: “We propose
to retain these provisions (relettered as Section 2.1043(h))
because they provide a means for non-manufacturer amateur
radio users to modify equipment that had previously been
certified or type accepted. We nevertheless seek comment on
whether the rule should be amended for clarity or to promote
better consistency between our Part 2 equipment
authorization provisions and our Part 97 service rules.”
An absolutely
thorough review would require checking the evolution of
Sections 2.1001 and 2.1043 (see footnote 95) and the various
citations to the Commission’s Knowledge Database (KDB),
which I have not attempted in depth. Also, while I have
decades of experience reading FCC regulations and proposals,
I do not have equivalent experience with mesh networking and
related technology. If someone with more experience in that
area can cite a specific proposed change in the rules that
would create difficulties, and will explain why, I’ll be
glad to take another look.
73,
Dave K1ZZ
From:
arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org]
On Behalf Of Frenaye, Tom, K1KI
Sent: Sunday, September 06, 2015 6:19 PM
To: arrl-odv
Subject: [arrl-odv:24659] Fwd: [exec-com:7826]
FCC Docket 15-170; FCC Equipment Authorization
Proposed Rule Changes
N5ZGT asked about FCC ET 15-170. Chris Imlay sent the EC a
memo about it on Friday which I've copied below (and
attached).
We do have a month to review and prepare comments.
-- Tom
Date: Fri, 4 Sep 2015 14:35:42 -0400
From: Christopher Imlay <w3kd.arrl@gmail.com>
To: exec-com <exec-com@arrl.org>
CC: "Gruber, Mike W1MG" <mgruber@arrl.org>,
"Price, Brennan, N4QX"
<bprice@arrl.org>,
"<ehare@arrl.org>"
<ehare@arrl.org>,
"Carlson, Kermit,
W9XA" <kcarlson@arrl.org>
Subject: [exec-com:7826] FCC Docket 15-170;
FCC Equipment Authorization Proposed Rule Changes
Greetings. Memo attached concerning this docket and the
opportunities available to us for comments. Please review.
The extended comment date in this proceeding is October 9,
2015 which offers us some time to prepare comments if you
choose to do so.
73, Chris W3KD
P.S. I will be on vacation and away next week, from
September 6 through 13. Please use my cell for any
contacts at 301-351-3795 or send an e-mail.Â
--
Christopher D. Imlay
Booth, Freret & Imlay, LLC
14356 Cape May Road
Silver Spring, Maryland 20904-6011
(301) 384-5525 telephone
(301) 384-6384 facsimile
W3KD@ARRL.ORG
Content-Type: application/pdf; name="Memorandum re NPRM
Docket 15-170.pdf"
Content-Disposition: attachment;
filename="Memorandum re NPRM Docket 15-170.pdf"
X-Attachment-Id: f_ie5zg0uf0
_______________________________________________
exec-com mailing list
exec-com@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/exec-com
=====
e-mail: k1ki@arrl.org ARRL New
England Division Director
http://www.arrl.org/
Tom Frenaye, K1KI, P O Box J, West Suffield CT 06093
Phone: 860-668-5444
_______________________________________________
arrl-odv mailing list
arrl-odv@reflector.arrl.org
https://reflector.arrl.org/mailman/listinfo/arrl-odv