[AMPS] RF Electronics shut-down and more info

Scott Townley nx7u@arrl.net
Thu, 04 Oct 2001 07:42:39 -0700

ARRL web story

The cited rules:

47CFR97.315 "Certification of External RF Power Amplifiers"

47CFR2.815 (Subpart I Marketing of Radio-frequency Devices) "External
radio frequency power amplifiers"

An Observation:
In the past three years the FCC has been moving a lot of "boilerplate"
regulations to part 2, like license renewal procedures, general
technical requirements (like this), etc.  Therefore in many cases it is
no longer sufficient for amateurs to only be familiar with Part 97 but
also with many portions of Part 2.

Having dealt somewhat with the FCC professionally, I can relate that the
best way to respond to them is "Yes Sir Right Away Sir".  Very few cases
are won on the "so prove me wrong" stance.  

As to the question from RF Electronics as to why Communications Concepts
is allowed (thus far) to remain in business, I can only conjecture that
the FCC doesn't consider CC as selling a "kit".  On their website it's
clear you get parts but no instructions outside of the applicable
Motorola Application Note.  And having seen those, I couldn't call them
kit instructions.

As to the other peripheral comments about future sales of parts/tubes,
etc., read the WHOLE rule set.  Making decisions based on partial
exerpts is inevitably out of context and largely meaningless (all the
peripheral concerns I've seen thus far are in fact addressed in the
whole of the rules).

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