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W6VHU > ARRL 22.07.98 09:02l 78 Lines 3544 Bytes #-10190 (0) @ WW
BID : ARL_V17.28B
Read: DJ7XU DG3LRL GUEST
Subj: ARRL Letter V17 28B
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The ARRL Letter Online -
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[B]
Volume 17, Number 28 (July 17, 1998)
ARRL SAYS SCANNER PROPOSALS COULD HURT HAMS
The ARRL has told the FCC that some of its recent proposals
to tighten scanning receiver rules "constitute severe regulatory
overkill" and could harm law-abiding amateurs. The League made
the comments in response to last month's FCC Notice of Proposed
Rulemaking (ET Docket 98-76).
The ARRL said it's "sensitive" to the FCC's concern that
devices not be able to readily intercept cellular calls. But, the
League added, some of the FCC's proposals could result in
"insufficiently defined regulations" that would prohibit or
unreasonably restrict the making and selling of ham and test
gear. Some product lines could become prohibitively expensive or
prohibited altogether by the proposals, the League asserted.
Among other things, the League asked the FCC to avoid
requiring scanning receivers in ham equipment to block access to
frequency-control circuits, and to not entirely prohibit
frequency converter or transverter kits for use in the Amateur
Service. The League said the net effect of the kits ban would be
to prohibit any frequency converters, even though they would not
be used or useful for cellular reception, and asked the FCC to
create an exception for Amateur Service frequency converters.
The League also asked that amateur receivers not be required
to undergo potentially expensive direct-pickup immunity testing,
and it urged the Commission to more clearly define its proposed
rules to avoid unintended consequences that could adversely
affect hams.
The League agreed that some extended coverage ham
transceivers have image responses that make them able to receive
cellular signals. But the League said this is not widespread and
"largely not an issue in the Amateur Service," because the
transceivers are not made, marketed, bought, or used for cellular
image reception. Manufacturers could configure products to
preclude cellular image frequency reception, the ARRL said.
The League said that current language banning the manufacture
or sale of scanning receivers that are "capable of readily being
altered" is sufficient. But the ARRL said requiring tuning and
control circuits be made inaccessible would be "an overbroad
requirement," and that potting or encapsulating frequency-control
hardware "is simply unnecessary for most amateur equipment." The
League said such a requirement would limit the ability of hams to
legitimately experiment with or to even repair their own
equipment and could needlessly drive up the cost of ham gear and
make repair expensive or impossible. "The potting requirement is
severe regulatory overkill and should not be enacted," the League
said. "There are sufficient, less burdensome regulations now in
effect and as proposed."
The League also called the FCC's proposed definition of test
equipment "unreasonably limiting" and advised the Commission to
correct the problem by eliminating the word "professional" from
its definition.
A copy of the League's full comments is available at
http://www.arrl.org/announce/ET98-76-cmt.pdf.
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[Continued in Part C]
[ Received via HF CLOVER at W0RLI]
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