Greetings. I have just now filed the attached reply comments in the FCC's docket proceeding dealing with revision of rules for equipment authorization. This subject was discussed in my Board report for the meeting just passed, as follows. Thanks to the Executive Committee for putting up with my deadlining them yet again, and thanks also for helpful edits and typo fixes, especially those offered by President Craigie, CEO Sumner, Vice President Frahm and Director Vallio. 73, Chris W3KD Christopher D. Imlay Booth, Freret, Imlay & Tepper. P.C. 14356 Cape May Road Silver Spring, Maryland 20904-6011 (301) 384-5525 telephone (301) 384-6384 facsimile W3KD@ARRL.ORG 2. ET Docket No.13-44, Amendment of Parts 0, 1, 2, and 15 of the Commission’s Rules regardingAuthorization of Radiofrequency Equipment; Amendment of Part 68 regardingApproval of Terminal Equipment by Telecommunications Certification Bodies. In thisNPRM released February 15, 2013, FCC proposes changes to its equipmentauthorization processes (Part 2 of FCC Rules) in several respects. It addressesthe role of Telecommunication Certification Bodies (TCBs) in certifying RFequipment and post-market surveillance, as well as the Commission’s role inassessing TCB performance. It alsoaddresses the role of test laboratories in the RF equipment approval process,including accreditation of test labs and the Commission’s recognition oflaboratory accreditation bodies, and measurement procedures used to determineRF equipment compliance. Finally, itproposes to recognize the National Institute for Standards and Technology(NIST) as the organization that designates TCBs in the United States and tomodify the rules to reference the current International Organization forStandardization and International Electrotechnical Commission (ISO/IEC) guidesused to accredit TCBs. This is nota docket proceeding that directlyaffects the Amateur Service. However, the track record for TCB certification ofRF devices in terms of errors and ill-advised grants of certification isabysmal. FCC lab staff constantly has to review and set aside TCB grants of RFequipment. The best example of the inadequate performance of TCBs in recentmemory is with respect to a TCB grant of the ReconRobotics Recon Scout device.The inadequacies of the TCB’s evaluation of this device were visited on theAmateur Service. ARRL has some countervailing considerations inthis Docket, however. On the one hand, we want RF devices in other serviceswith whom we share spectrum (or where the other service is adjacent to Amateurspectrum) to be carefully evaluated by a competent reviewer at the equipmentauthorization stage. On the other hand, we don’t want small manufacturers ofsmall quantities of Amateur Radio equipment to be burdened by the very highcost of the FCC’s equipment authorization process. An example of the latter isa small manufacturer of Amateur equipment that incorporates a scanning receiver.Those receivers have to be certified according to FCC rules. This involves aprivate laboratory and a TCB certification, which is expensive and which detersmanufacturing of RF equipment in small quantities for, as an example, theAmateur market. This proceeding could be used to request exemption of certaintypes of equipment intended exclusively for Amateur Radio use, so as to makesure that it is available at a reasonable cost. FCCproposes that the Commission no longer conduct evaluations for initiallyapproving RF equipment requiring certification. Instead, TCBs would approve all such equipment in the firstinstance, including equipment on an “exclusion list” that now, only theCommission may approve. Equipment on the exclusion list includes MedRadiotransmitters designed to operate in 413-419 MHz, 426-432 MHz, 438-444 MHz,451-457, and 2360-2400 MHz bands (Part 95 Subpart I). Surely, we want theCommission to continue to certify these devices. FCC also proposes to clarifyand modify the rules on TCB responsibilities. Specifically, FCC proposes to codify the “permit-but-ask” procedure thatTCBs must use when certifying new technologies when testing protocols have notbeen established, clarify the responsibility of TCBs to perform post-market surveillanceof products they have approved, and specify steps that can be taken if a TCB’sperformance were found to be deficient. FCC also proposes to require accreditation of all laboratories that testequipment subject to the Part 2 certification procedure, and to codify theexisting procedure through which the Commission can recognize new laboratoryaccreditation bodies. Finally, FCC proposes to incorporate the latest versionsof the industry standards for measuring equipment into the rules and address howto update these standards more quickly in the future. Finally, FCC proposes to modify the rules toreference the current ISO/IEC standards used to accredit TCBs that approve RFequipment under Part 2 of the Commission’s rules. Its intention is to enablenew and innovative products to be brought to market as quickly as possible,promoting competition in the provision of RF equipment, while at the same timeprotecting against interference among radio services and devices using the RFspectrum. However, FCC says that it recognizes that certain proposed changes,such as requiring laboratories to become accredited, would result in someincreased costs.