[Elecraft] CE labels, band limits - no thanks!

[David Woolley]

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
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