Yes, John, please do. If we’re overlooking something we need to know sooner rather than later. Dave From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of John Robert Stratton Sent: Thursday, September 10, 2015 2:03 PM To: arrl-odv Subject: [arrl-odv:24667] Re: Fwd: [exec-com:7826] FCC Docket 15-170; FCC Equipment Authorization Proposed Rule Changes Dave The Broadband-Hamnet group has been asked to review 15-170 and comment. May I share your comments below with them? 73 ----------------------------------------------------- John Robert Stratton N5AUS Office telephone: 512-445-6262 Cell: 512-426-2028 PO Box 2232 Austin, Texas 78768-2232 ----------------------------------------------------- On 9/10/15 12:30 PM, Sumner, Dave, K1ZZ wrote: 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<mailto:w3kd.arrl@gmail.com>> To: exec-com <exec-com@arrl.org<mailto:exec-com@arrl.org>> CC: "Gruber, Mike W1MG" <mgruber@arrl.org<mailto:mgruber@arrl.org>>, "Price, Brennan, N4QX" <bprice@arrl.org<mailto:bprice@arrl.org>>, "<ehare@arrl.org<mailto:ehare@arrl.org>>" <ehare@arrl.org<mailto:ehare@arrl.org>>, "Carlson, Kermit, W9XA" <kcarlson@arrl.org<mailto: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. -- 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<mailto: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<mailto:exec-com@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/exec-com ===== e-mail: k1ki@arrl.org<mailto: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<mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv