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[Discuss-gnuradio] Part 15 and Gnuradio...

From: Tim Pozar
Subject: [Discuss-gnuradio] Part 15 and Gnuradio...
Date: Tue, 17 Dec 2002 08:05:51 -0800
User-agent: Mutt/

Some thoughts...

I was talking to John Gilmore last night at the Creative Commons
shindig and mentioned to him about seeing Eric's presentation at
the TAC (Nice suit Eric.) John brought up the concern how the FCC would
restrict the distribution and use of the Gnuradio as a transmitter.
One way they could would be through equipment certification as it
would be considered an "intentional radiator" (15.3(o)).

At this point anything that radiates RF if "intentional" (handie-talkies)
or "unintentional" (ie computers) and is to be "marketed" in the
Unitied States" has to go through an equipment certification process.
The process means that he equipment would go to a lab that the FCC
recognizes, and be measured to see if it doesn't put out any more
RF than what is allowed by Part 15 or other applicable parts of the
FCC's rules.  For instance, if you wanted a device that was limited
to the FM band and was designed for broadcasters, there is one set
of rules that apply to you (part 73).  If you want a transmitter
that can do just about any frequency with limits to power, then
part 15 may be the answer.

But this means that for every version of a device that this group
comes up with, it would have to go through a rather finite and
expensive certification process (lab costs can be $2K - $5K).  There
is an exception...

   15.23  Home-built devices. 

   (a)  Equipment authorization is not required for devices that
   are not marketed, are not constructed from a kit, and are built
   in quantities of five or less for personal use.

   (b)  It is recognized that the individual builder of home-built
   equipment may not possess the means to perform the measurements
   for determining compliance with the regulations.  In this case,the
   builder is expected to employ good engineering practices to meet
   the specified technical standards to the greatest extent
   practicable.  The provisions of 15.5 apply to this equipment.

15.5 just means "thou shall not interfere, and thou shall accept
all interference".  This section was meant exactly for the the

So, the group of developers that want the design to fall under this
section of the rules, may think about not market or producing it
as a kit.  Certainly they could produce papers on the design much
like the ARRL does on equipment for HAMs.  


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