Ian J Maude wrote:
David Pratt wrote:
The Interface Requirement for UK Amateur licences is available at
http://www.ofcom.org.uk/radiocomms/ifi/tech/interface_req/ir2028.pdf
I am confused. Where does it state that a Foundation licensee cannot
*build* a transceiver or transmitter? Whether they can use it on air is
moot as far as I am concerned. The receiver part would still be usable.
As it happens, it looks like I rushed the checking of sources too much
when doing it from the office at lunch time and managed to confuse the
licence levels. Foundation users do have conditional permission to
transmit using kits, so could, presumably use a transceiver kit as their
construction project. I couln't find an actual syllabus to see if that
imposed extra constraints.
However, I'm fairly sure that wasn't always the case, especially as the
kit exception seems to have been bolted onto the licence clause, and
looks to me to be badly drafted. I do seem to remember seeing it
mentioned in RadCom, in the past that transmitters weren't acceptable.
Unfortunately, my older licence copies only have the Full licence rules.
The reasons why a kit that was capable of transmitting would be
discouraged, if it could not be immediately used, would be that the
setup procedure might well assume going on air; the reason the operator
would not have been allowed to use kits is basically that they would not
be deemed to have the knowledge to set them up properly and might not be
competent in the use of dummy loads. (I would also suspect that a lot
of people would apply the "thou shalt not get caught out rule" and
transmit anyway.)
As to IR 2028, I said "some form of type approval", rather than "CE"
approved, because I was having difficulty working out what restriction
IR 2028 actually imposes. It seems to me that IR 2028 doesn't actually
impose any constraints on equipment at all, but simply specifies the
technical parameters (frequency, modulation, and power) in which radio
amateurs can use the spectrum.
However, on further consideration, I would say that the intent of the
licence was definitely to require CE (or CE! - "!" means capable of
transmitting out of band) approval. I assume it originally (possibly
unpublished) only referred to pre-built equipment, in which case the
fact that it has to be available commercially means that it must be CE
approved, as equipment cannot be sold commercially otherwise (except,
maybe, for grand fathering). Moreover, the only reason that the IR
series documents exist is to provide a definition of a particular
service in relation to the main CE marking legislation, that covers many
services; they are part of the CE marking documentation system.
I think what was originally intended was that the equipment be CE marked
in connection with use that fell under IR 2028, i.e. amateur radio, i.e.
that, when used within the frequency, mode and power limits in IR 2028,
it would meet the "essential requirements" for CE marking, namely that
it was safe and did not cause undue interference.
My guess is that they were convinced that it was in the public good
(self education) to permit kits, but wanted them to meet the CE
requirements as well, and copied the language from the pre-built
equipment sentence without realising that the primary CE marking
legislation exempts kits of parts intended for radio amateurs from CE
marking.
Certainly, as currently written, it doesn't seem to make sense, because
IR 2028 doesn't impose constraints on equipment.
As to the idea that someone buying the kit can decide whether or not the
supplier complies, I don't really believe that that would ever be
intended. As it is, I believe it is relatively easy for a supplier to
self certify; they just have to document why they think that it complies
and not have someone challenge the claim. (Kits may be more difficult,
as you presumably have to show it will comply even when built sloppily.)
Sorry guys, this is getting a little OT
The charter of this list is "The Elecraft list is a forum for the
discussion of topics related to Elecraft products and more general
topics related ham radio.". It seems to me that the legality of
legitimate radio amateurs using Elecraft kits is very much on topic!
--
David Woolley
Emails are not formal business letters, whatever businesses may want.
RFC1855 says there should be an address here, but, in a world of spam,
that is no longer good advice, as archive address hiding may not work.
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