Brook L. wrote:
There’s four ways you can emit RF and remain within the scope of FCC
regulations. First, you can emit RF for the purpose of communication as
an FCC licensee, pursuant to the rules of the service in which your
license is issued. Second, you can emit RF for the purpose of
communication not as an FCC licensee, pursuant to the rules in Part 15
for intentional radiators. Third, you can emit RF not for the purpose
of communication pursuant to the rules in Part 15 for incidential
radiators or pursuant to the rules in part 18 for ISM equipment.
Fourth, you can emit RF for any purpose pursuant to the terms of an
FCC-issued Special Temporary Authorization. Any other emission of RF
(within the FCC’s jurisdiction of 9 kilohertz to 300 gigahertz) is
illegal.
In the first case, you must comply with all requirements of the
regulations pertaining to the service in which you have a license. The
thing is, for most services one of the rules is that you may only use
equipment which has been certificated by the FCC for use with that
service; using equipment which has not been certificated for use in that
service is a violation of the rules and is prohibited. Some services
permit uncertificated equipment to be used in certain situations, most
notably the amateur radio service. An amateur radio licensee may use
just about anything he or she wants to emit RF as long as his or her
emissions are consistent with the regulations in Part 97 and with “good
engineering and good amateur practice” (§97.1). Since the USRP is not
certificated for use in any service, it can only be used as an
intentional emitter in a licensed service if that service permits the
use of uncertificated equipment.
In the second and third cases, you must comply with the relevant
requirements of Parts 15 and/or 18 for the class of unlicensed operation
that applies to your situation. In many cases relevant to the USRP,
neither Part 15 nor Part 18 will require certification. Generally,
“kits” and one-off projects require neither certification nor a
“declaration of comformity”; those requirements typically only come into
play when a device that operates within the scope of these rules is to
be offered for sale or distribution in commerce. The frequency, power,
spurious emission, and bandwidth limitations applicable to Part 15 and
Part 18 devices are complicated, and it’s no mean feat to determine
whether a given usage is or is not permissible; do your due diligence
before you transmit at any measurable power.
In the final case, of course, you can do whatever you negotiate for from
the FCC. STAs are not that hard to obtain, especially if you already
have a relationship with the FCC.
If you’re trying to develop a commercial product, you should obtain an
STA to do any free space testing; you’ll need to deal with the FCC
anyway to get the eventual certification, and doing the STA will put the
OET on notice of your product development, which might possibly
facilitate the eventual certification of your device for commercial sale
(or not). If you’re just playing with radio out of personal interest,
get an amateur radio license and use the amateur allocations, or if your
particular investigation cannot be conducted on the amateur bands, use
your amateur radio license as an entry to get an amateur STA. (The FCC
may, in some circumstances, waive its usual fees for an application for
an STA from an amateur licensee.) If your investigation or experiment
is such that it can be conducted within the scope of a Part 15
intentional radiator not requiring certification, then just do it,
although in that case I still recommend that you get an amateur radio
license, because it will make your life slightly easier if you do find
yourself dealing with the Enforcement Bureau.
Regards,
Kelly (AB9RF)