Re: UK Foundation License & Kits

[M0XDF]

We had a discussion on this at our club meeting last night (G4BRA) and one
of the trainers stated that there is no requirement to CE certify kits (he's
also the local RSGB EMC rep), so pre-empting a question, CE mark doesn't
come into it.
It was also stated that a kit can be built at Foundation level.

I just checked the latest UK license and section '7 Equipment'
Para 2, states:

7(2) [snip] Foundation Licence holders may also use Radio Equipment
constructed using commercially available kits which satisfy IR 2028.

Now I'm not sure what IR2028 states, but I bet Elecraft meet the
requirement.

On 14/6/07 00:42, "[hidden email]"
<[hidden email]> sent:

> Message: 42
> From: David Woolley <[hidden email]>
> The current UK licensing regime requires that a project be built before
> one can get from the 10 watt limited Foundation Licence to the 50 watt
> limited Intermediate Licence.  It can't be a transmitter though, as one
> cannot use kit built equipment until you have gained the intermediate
> licence (it looks like Intermediate Licensee transmitter kits must meet
> some type approval rules, whereas full licence ones look like they are
> exempt).  Assuming that there is some flexibility in what is built, I
> would presume that there would be some market for a K2 with build
> instructions modified to complete all the receiver bands before starting
> on the transmitter, for when the licensee upgraded; it might need
> appropriate type approval, though, for that market.  It would far exceed
> the construction experience required for the licence!

--
A bit of fragrance always clings to the hand that gives the rose.
-Chinese proverb


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[David Pratt-2]

The Interface Requirement for UK Amateur licences is available at
http://www.ofcom.org.uk/radiocomms/ifi/tech/interface_req/ir2028.pdf

It is an important document as far as UK licences are concerned.

73

David

In a recent message, "David Ferrington, M0XDF" <[hidden email]>
wrote ...
>7(2) [snip] Foundation Licence holders may also use Radio Equipment
>constructed using commercially available kits which satisfy IR 2028.
>
>Now I'm not sure what IR2028 states, but I bet Elecraft meet the
>requirement.
--
David G4DMP
Leeds, England, UK
------


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[Ian Maude]

David Pratt wrote:
> The Interface Requirement for UK Amateur licences is available at
> http://www.ofcom.org.uk/radiocomms/ifi/tech/interface_req/ir2028.pdf
I am confused.  Where does it state that a Foundation licensee cannot
*build* a transceiver or transmitter?  Whether they can use it on air is
moot as far as I am concerned.  The receiver part would still be usable.
Sorry guys, this is getting a little OT

Ian

--
Ian J Maude G0VGS
SysOp GB7MBC DX Cluster
Member of RSGB, ARRL, GQRP
K2 #4044 | K3 #?

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[David Woolley (E.L)]

Ian J Maude wrote:
> David Pratt wrote:
>> The Interface Requirement for UK Amateur licences is available at
>> http://www.ofcom.org.uk/radiocomms/ifi/tech/interface_req/ir2028.pdf
> I am confused.  Where does it state that a Foundation licensee cannot
> *build* a transceiver or transmitter?  Whether they can use it on air is
> moot as far as I am concerned.  The receiver part would still be usable.

As it happens, it looks like I rushed the checking of sources too much
when doing it from the office at lunch time and managed to confuse the
licence levels. Foundation users do have conditional permission to
transmit using kits, so could, presumably use a transceiver kit as their
construction project.  I couln't find an actual syllabus to see if that
imposed extra constraints.

However, I'm fairly sure that wasn't always the case, especially as the
kit exception seems to have been bolted onto the licence clause, and
looks to me to be badly drafted.  I do seem to remember seeing it
mentioned in RadCom, in the past that transmitters weren't acceptable.
Unfortunately, my older licence copies only have the Full licence rules.

The reasons why a kit that was capable of transmitting would be
discouraged, if it could not be immediately used, would be that the
setup procedure might well assume going on air; the reason the operator
would not have been allowed to use kits is basically that they would not
be deemed to have the knowledge to set them up properly and might not be
competent in the use of dummy loads.  (I would also suspect that a lot
of people would apply the "thou shalt not get caught out rule" and
transmit anyway.)

As to IR 2028, I said "some form of type approval", rather than "CE"
approved, because I was having difficulty working out what restriction
IR 2028 actually imposes.  It seems to me that IR 2028 doesn't actually
impose any constraints on equipment at all, but simply specifies the
technical parameters (frequency, modulation, and power) in which radio
amateurs can use the spectrum.

However, on further consideration, I would say that the intent of the
licence was definitely to require CE (or CE! - "!" means capable of
transmitting out of band) approval.  I assume it originally (possibly
unpublished) only referred to pre-built equipment, in which case the
fact that it has to be available commercially means that it must be CE
approved, as equipment cannot be sold commercially otherwise (except,
maybe, for grand fathering).  Moreover, the only reason that the IR
series documents exist is to provide a definition of a particular
service in relation to the main CE marking legislation, that covers many
services; they are part of the CE marking documentation system.

I think what was originally intended was that the equipment be CE marked
in connection with use that fell under IR 2028, i.e. amateur radio, i.e.
that, when used within the frequency, mode and power limits in IR 2028,
it would meet the "essential requirements" for CE marking, namely that
it was safe and did not cause undue interference.

My guess is that they were convinced that it was in the public good
(self education) to permit kits, but wanted them to meet the CE
requirements as well, and copied the language from the pre-built
equipment sentence without realising that the primary CE marking
legislation exempts kits of parts intended for radio amateurs from CE
marking.

Certainly, as currently written, it doesn't seem to make sense, because
IR 2028 doesn't impose constraints on equipment.

As to the idea that someone buying the kit can decide whether or not the
supplier complies, I don't really believe that that would ever be
intended.  As it is, I believe it is relatively easy for a supplier to
self certify; they just have to document why they think that it complies
and not have someone challenge the claim. (Kits may be more difficult,
as you presumably have to show it will comply even when built sloppily.)

> Sorry guys, this is getting a little OT

The charter of this list is "The Elecraft list is a forum for the
discussion of topics related to Elecraft products and more general
topics related ham radio.".  It seems to me that the legality of
legitimate radio amateurs using Elecraft kits is very much on topic!

--
David Woolley
Emails are not formal business letters, whatever businesses may want.
RFC1855 says there should be an address here, but, in a world of spam,
that is no longer good advice, as archive address hiding may not work.
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[David Cutter]

I am not an expert, but, a kit cannot be evaluated for safety and emc
because as it appears in the market it is just a collection of parts which
cannot be tested.  The purpose of CE marking is to allow free marketing
across the EU using harmonised standards; it is not in itself an approval.
The Certificate Of Compliance must list all the certification required to
allow this free movement, ie to ensure a level playing field across the EU.

The UK Foundation licence allows a kit to be used as apposed to a tx that is
made from just diagrams, say in a magazine or book.  The "manufacturer" ie
designer/seller of the kit has made a diligent effort to ensure it will
comply with emc legislation when assembled, eg power, frequency coverage,
stability, spurii, etc.  The safety part is "largely" covered by operation
from low voltage isolated supply which is purchased separately and is CE
marked and certified.   The kit supplier needs to ensure that it cannot
catch fire or exude noxious fumes etc when properly assembled.  I would not
suggest that the K2 is suitable for a Foundation project, except by someone
with proper skills, which an average 10 year old is unlikely to possess.

Interestingly, a Foundation licence holder is not allowed to modify another
equipment, say PMR radio, onto the amateur bands (whatever his personal
skills) or even use such a radio modified by others unless it is actually
sold as amateur radio equipment and CE marked (certified) as such.

David
G3UNA


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