Hello back, 

I've been in direct contact with the FCC regarding the legal 
operation of wide band type certified in narrow band service 
both before and after the "narrow band mandate". 

The key issue seems to be the mention of any "hardware" 
modifications to the existing equipment, which are interpreted 
as a no-go, an answer I would expect when the majority of 
questions are submitted in a hardware modified context. 

However, no clear interpretation is given for equipment 
operation without physical hardware modifications. As an example 
a type accepted wide band transmitter already operating narrow 
band as originally installed and done so without and hardware 
or software modifications. 

For the sake of this thread, I don't include receiver operation, 
an example being an IF Crystal Filter kit change (IE not normally 
considered a transmitting device).

So the only way to get a real-deal answer is to return to the FCC 
with an official inquiry... of which I have now completed and as 
submitted I/we should receive an official answer/reply within 3 
business days. 

By hopefully asking the right questions without all the sidebar 
information, we can receive an honest interpretation direct from 
the horses mouth. 

cheers, 
s. 

> wd8chl <wd8...@...> wrote:
>
> BTW, here's a link to a web site done by a DC comm's lawyer. Yes, he has 
> the 'disclaimers' not to use it as 'legal advice', but you can beturbut 
> it's right.
> <http://www.narrowbandinglaw.com/faqs.html>
> It's the second last question.
> There is a link in the answer to the FCC order involved, but of course 
> it's filled with typical legal-ese...
> 
> One thing I am not sure about-I do remember now that there was a 
> narrowband only version of the TK-x20 mobiles, along with a few other 
> Kenwoods of that vintage-the model number had an 'N' on the end. I don't 
> remember a TKR version, but there may have been. Those should of course 
> be fine, because they started life NB.
> 
> Also rx's are not an issue. Narrowbanding, say, an MII rx is fine, since 
> the FCC doesn't care about rx's. It's only tx's that need to be properly 
> type accepted.
> 
> Jim Barbour
> Transcore
> 
> On 3/20/2010 12:21 AM, wb6dgn wrote:
> >
> >
> >> Except for one thing-the x20 series radios weren't type accepted
> >> for narrowband, and the FCC has already said that if that's the
> >> case, it won't fly.
> >
> > The "last time around", when a manufacturer wished to provide a
> > "narrow banding kit" for a previously type accepted radio, they
> > applied to the FCC for a "supplemental type certificate" (STC)
> > covering the modification kit installed in the subject equipment.
> > This STC number was attached to the radio ID plate in addition to or
> > in place of the original type acceptance number.  This kit was then
> > dealer or service shop installed in accordance with the
> > manufacturer's instructions.  This then provided an updated type
> > acceptance ID for that subject radio model series with the kit
> > installed.  It was not up to the user, nor the user's local radio
> > shop to apply for this.  This program and the rather extensive
> > engineering data required was originated and and undertaken by the
> > original equipment manufacturer BUT installed by a local radio repair
> > facility.  While receiver modifications were not required nor covered
> > by the STC, they were also supplied in every case that I am aware of,
> > as part of the "narrow banding kit".
>


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