Kristinn Andersen wrote:
Regarding the CE issue I believe that radio amateurs, who need to pass
tests for their license to operate, construct and modify their own
A number of questions asked on this list about the K2 indicate that
there are people building the K2 who are unable to read and interpret a
circuit diagram. Even I wouldn't be able to deduce all the design
decisions that went into making the equipment compliant, and they are
not documented in the public domain, so I can't look them up.
framework of the Constitution and Convention of the ITU [8], unless
the equipment is available commercially. Kits of components to be
Elecraft products are available commercially.
My interpretation of components is "electronic components", i.e.
resistors, capacitors, transistors, etc. Elecraft interpret it as being
a noise word, with only kit being effective (although they would acccept
that a combination of base unit, PA and ATU isn't a kit for that
legislation. (I once read something to the effect that, when reading
legal documents, every word counts.)
I think that the legislators are thinking more in terms of making it
possible for me to order all the components for a published design by
ordering the RadCom XYZ component set, rather than having the supplier
send me the exact same set of components because I had enumerated them
individually (however note that the UK licence does give an advantage to
those cases where the kit is supplied as a whole, with the design).
assembled by radio amateurs and commercial equipment modified by and
Commercial equipment would have been compliant in its original use.
for the use of radio amateurs are not regarded as commercially
available equipment."
I think it is very important that we amateurs don't give in on this
issue. Our privileges are hard earned through our testing and
The danger is that if commercial sellers try to find loopholes, in
closing the loopholes the legislators may restrict things that were not
previously restricted. In many cases the commercial vendor has made
their profit before the legislation gets fixed, so their cash flow is good.
licensing process, they are actually recognized in international
regulations, and if the officials who execute the laws don't know
better, they need to be informed and put back on track.
They are only there because the people who make the laws believe that
there is a benefit to the public in amateur radio. I don't think that
is based on a simple freedom argument, I think it is based on
encouraging people into engineering and technical careers, general self
education, the ability to provide emergency communication, and providing
a potential source of military operators. I'm not sure that the last
one is so valid these days. Historically, a lot of the basic radio
propagation research was done by amateurs, but I think that is becoming
less relevant to the economy.
As such, from the legislators point of view, there is no fundamental
need to protect amateur radio operators from legislation, so they will
always be making cost benefit tradeoffs.
Regarding band limits, I think we should not be required to limit our
equipment there, either. Nor should we by any means ask for such
In the UK, only those with full licences are permitted to use
unrestricted equipment, and I am not aware that the ban on the import
and sale of certain equipment that could be used illegally on CB
frequencies has been removed. Other classes of licensee are allowed to
use commercial kits, like the K2, provided they are frequency
restricted. (The current UK licence drafting is confusing in this
respect, but I don't believe any change in effect was intended from the
previous, more direct, wording.)
The US has a particular limitation on receive capabilities, although it
doesn't affect Elecraft products, in that reception on the cellular
radio frequencies is prohibited in commercial products which are not
standard cellular phone products.
However, the real issue with the current question was that it is a
serious criminal offence to possess equipment operating outside of the
amateur frequencies in some countries to which people often want to take
equipment on holiday. That's typically because there is some separatist
organisation that uses radio to coordinate military operations.
limitations ourselves! By the nature of our hobby we are trusted to
build our radio oscillators, amplifiers and other equipment, which
In the UK, only full licensees are so trusted, and I think it might be
better to say that we are trusted to know our own limits. The
examinations show that we understand the issues, but don't make us fully
fledged RF designers.
technically may be able to radiate all over the spectrum, but it is
our responsibility - and we should live up to that responsibility - to
make sure that our emissions are within the regulations in effect in
our countries.
Not everyone has access to spectrum analyzers. When we build something
like the K2, we rely on the type, in the type approval sense, being
intrinsically compliant when set up with simple tools. In principle,
that is the same for a black box product that has type approval. Only
one instance need be actually tested. It is then just necessary to
demonstrate that manufacturing variations will not result in other
instances being outside the specifications.
--
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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