Kristen, et al: To amplify Dan's response just a little, we received a product review of one of the goTenna products last week and red flags were raised here at HQ. We're going to involve the Lab and Chris Imlay in our review of the product and carefully consider what we want to publish, once we complete our work. 73, Barry J. Shelley, N1VXY Chief Executive Officer ARRL, Inc. The national association for Amateur Radio (860) 594-0212 www.arrl.org -----Original Message----- From: arrl-odv [mailto:arrl-odv-bounces@reflector.arrl.org] On Behalf Of Henderson, Dan N1ND Sent: Friday, March 16, 2018 11:28 PM To: McIntyre, Kristen, K6WX <kristen@alum.mit.edu>; arrl-odv <arrl-odv@reflector.arrl.org> Subject: [arrl-odv:27132] Re: goTenna Pro: How It Works HQ is working on this... Dan Henderson, N1ND Assistant Secretary, the American Radio Relay League, Inc. Regulatory Information Manager ARRL - the national association for Amateur Radio Phone: 860-594-0236 ________________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org] on behalf of McIntyre, Kristen, K6WX Sent: Friday, March 16, 2018 8:30 PM To: arrl-odv Subject: [arrl-odv:27130] goTenna Pro: How It Works Has anyone looked at this yet? It was brought to my attention today. Seems like it could easily violate Part 97 in multiple ways. It's not clear that it's for sale yet. https://www.gotenna.com/pages/gotenna-pro-technology https://www.gotenna.com/tools/proxy/assets/images/goTenna-PRO-specs.pdf -Kristen (K6WX) "Your eyes ... it's a day's work just looking into them" Laurie Anderson (--... ...-- -.. . -.- -.... .-- -..-) _______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org https://reflector.arrl.org/mailman/listinfo/arrl-odv

Thank you for the details Chris. I really appreciate knowing what’s been investigated. Yes, I have a set of the 900 MHz devices for experimentation, so I’m aware of their prior products. This new device seems very different. I was wondering about the certification, encryption, published modulation schemes (are they published?), and satisfying the ID requirement when I first looked at the “Pro” version. It didn’t seem to me like a Part 90 certification would work at all. It will be interesting to see what they ultimately do, but it’s good to know that HQ is on the case. I would hate to see this pass certification based on lax gatekeeping, and then end up with harmful interference from unlicensed transmitters in our spectrum.

On Mar 20, 2018, at 11:22 AM, Christopher Imlay <w3kd.arrl@gmail.com> wrote:

Kristen, Jim Boehner et al:

Please keep this information Board-confidential.

This is a matter we are digging into. There are apparently multiple versions of this device. HQ reviewed for QST a 900 MHz version of it which would appear to be legal and the device seems to have a TCB certification (under Part 15) and an FCC ID number etc., though we are checking those. It is unclear whether all versions of the device have encryption capability, though some models do, and of course using them in that mode pursuant to an Amateur License with the encryption on would clearly violate Amateur rules. Nor are these devices marketed to amateurs. The product review is on hold pending a determination of legality of the particular device reviewed.

There are also apparently other models of the device which operate from 142-174 MHz and 420-512 MHz or similar. These devices are definitely equipped with encryption capability and are advertised as such. And they operate at a series of power levels, from 10 mW to 5 watts. They are not because of that subject to Part 15 certification.They are marketed to the general public, however. Since those devices are user-tunable, they cannot be certified under Part 90 for PLMR use. They would be usable for Amateur purposes at VHF and UHF but again, they are not being marketed to Amateurs. They are being marketed to the general public.

Longstanding FCC policy is that a device which operates on frequency bands that are allocated to different services must be certified for all radio services which have allocations on frequencies or bands on which the devices are capable of operation. So, the VHF and UHF version of the GoTenna cannot apparently be certified, nor legally marketed at all to anyone, or used except by amateurs, with the caveat that if an Amateur uses the device the encryption capability must be turned off at all times.

But we are still checking on this.

73, Chris W3KD

On Fri, Mar 16, 2018 at 11:28 PM, Henderson, Dan N1ND <dhenderson@arrl.org <mailto:dhenderson@arrl.org>> wrote: HQ is working on this...

Dan Henderson, N1ND Assistant Secretary, the American Radio Relay League, Inc. Regulatory Information Manager ARRL - the national association for Amateur Radio Phone: 860-594-0236 <tel:860-594-0236> ________________________________________ From: arrl-odv [arrl-odv-bounces@reflector.arrl.org <mailto:arrl-odv-bounces@reflector.arrl.org>] on behalf of McIntyre, Kristen, K6WX Sent: Friday, March 16, 2018 8:30 PM To: arrl-odv Subject: [arrl-odv:27130] goTenna Pro: How It Works

Has anyone looked at this yet? It was brought to my attention today. Seems like it could easily violate Part 97 in multiple ways. It’s not clear that it’s for sale yet.

https://www.gotenna.com/pages/gotenna-pro-technology <https://www.gotenna.com/pages/gotenna-pro-technology>

https://www.gotenna.com/tools/proxy/assets/images/goTenna-PRO-specs.pdf <https://www.gotenna.com/tools/proxy/assets/images/goTenna-PRO-specs.pdf>

-Kristen (K6WX)

"Your eyes ... it's a day's work just looking into them" Laurie Anderson

(--... ...-- -.. . -.- -.... .-- -..-)

_______________________________________________ arrl-odv mailing list arrl-odv@reflector.arrl.org <mailto:arrl-odv@reflector.arrl.org> https://reflector.arrl.org/mailman/listinfo/arrl-odv <https://reflector.arrl.org/mailman/listinfo/arrl-odv>

-- 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> -Kristen (K6WX)

"Your eyes ... it's a day's work just looking into them" Laurie Anderson (--... ...-- -.. . -.- -.... .-- -..-)