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[AMPS] FCC certification - how do they do it?

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Subject: [AMPS] FCC certification - how do they do it?
From: (Tom Rauch)
Date: Wed, 26 Jul 2000 16:14:51 -0400
> If FCC 97.315 allows an amateur to modify an amplifier and the power
> limits expressly presented in FCC 97.313 are not exceeded where does this
> "Instructions for operation or modification of the amplifier a
> manner contrary to FCC rules" come into play"?
> In the discussions I have had with the "Engineer in Charge" of the FCC
> Boston office years ago it was made very clear that amplifiers could be
> modified on a limited basis, using one's own technical abilities or
> following instructions provided by the holder of the "type certificate".
> This "limited basis" was outlined in 97.315

I go by what the people in charge of enforcement tell me. They can 
understand the gibberish in the rules better than I can.

What I've learned is doing what they want is easier and cheaper 
than arguing with them, and insures that when I file a TA 
application it speeds right through.
> Anywhere in any regulation there is always room for interpertation. I
> highly doubt is any amateur has ever had any action taken regarding a
> modification in accordance with 97.315 or a manufacturer had action taken
> because he proivided the technical information to allow modifications.

That's correct. They care less about the end-user who is a licensed 

My point is a manufacturer is not allowed to sell an amp to a 
amateur with ten meters in it. Helping the amateur modify the amp 
is one thing. Selling or shipping equipment that violates part 97 
type acceptance is another, even if it is to a ham. 
> The FCC inforces rules with respect to the intent of the rule. In another
> area of contention which pops often regarding the FCC rules and their
> actions the matter of antennas always comes up.

The FCC visited every manufacturer in Dayton in 1999, and their 
first question was "Where is the type-acceptance number and what 
keeps someone from operating this amplifier on ten or 11 meters?" 

I'm glad the FCC does not enforce the exact letter of the law, and 
to make sure they follow that path it is a good idea to not test 
them. Shipping amplifiers that violate the terms of type-acceptance 
is asking for problems. If the ham is too dumb or lazy to modify an 
amp himself, he doesn't deserve to have one.

73, Tom W8JI

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