In reply comments filed July 31 on an FCC proposal to alter its Part 2 equipment certification process, the ARRL suggests that the Commission not be so quick to delegate greater authority to private telecommunication certification bodies (TCBs). The FCC’s equipment authorization program aims in part to ensure that RF devices imported, marketed and used in the US comply with Commission rules and not cause harmful interference. The ARRL said it agrees with the National Association of Broadcasters (NAB), which expressed concern about the current level of TCB performance and advised against outsourcing all equipment authorization functions to TCBs. At present, the FCC still conducts evaluations for initial approval of devices requiring certification. It also approves certain “exempt” equipment, including devices that operate in UHF bands on which Amateur Radio is secondary.
“This is not a docket proceeding that directly affects the Amateur Service,” the ARRL said in its reply comments. “However, the track record for TCB certification of RF devices in terms of errors and ill-advised grants of certification is abysmal. FCC lab staff constantly has to review and set aside TCB grants of RF equipment.”
As an example the League cited the TCB grant of the ReconRobotics Recon licensed, non-broadcast video transmitter. “The inadequacies of the TCB’s evaluation of this device were visited on the Amateur Service,” the ARRL told the FCC. The ARRL reminded the FCC that the League subsequently discovered several errors in the authorization application and the TCB grant of certification. The Commission is still reviewing the League’s complaint, three years after it was filed.
The League also said it agrees with the NAB that the TCB certification process is less transparent than it should be. “The public is not informed about TCB equipment authorization grants until after the fact, at which time an equipment manufacturer may have already sold large numbers of a non-conforming product if a TCB made an error in the grant,” the League said. Further, the League said, the public should be informed regarding TCBs’ level of accuracy and reliability.
The League said that, as a general matter, Commission enforcement of equipment authorization rules “is the proper task of the Commission’s staff,” and urged that the FCC, not a TCB, to resolve complaints.
“ARRL is concerned that the reliability of TCBs exhibited heretofore is not sufficiently high to justify the proposed extensive delegation of the evaluation of more complex types of equipment authorizations, where interference potential is significant or where RF exposure is an issue,” the League concluded.