Certified Systems for "Newbies"

I'm not getting into the middle of any arguments, but I will try to clarify what is contained in our regulations.

As stated in Section 15.204(a) no one may market or use any external radio frequency power amplifier for use with any Part 15 transmitter with one exception - if the amplifier was authorized as part of a system including the transmitter, the amplifier and the antenna, then the amplifier may be sold as part of the complete system but may not be marketed separately. We do not separately certify Part 15 amplifiers; certification is issued only on the complete system.

Section 15.204(b) also states that when a transmission system is authorized as a system then it must always be marketed as a complete system in the configuration in which it was authorized. Add to this the requirement in 15.204(c) that a transmitter may be used only with the antenna with which it was certified. Further, Section 2.1043(b)(4) states that any changes to a certified product (or system) that are made by anyone other than the party that holds the grant of certification from us voids that certification. Based on these rules, it is very clear that you may not legally market or use any system configuration that differs from the exact configuration that we certified. The certified configuration can be based on a transmitter and an antenna or a transmitter, amplifier, and antenna. In fact, there are several system configurations that require the use of a specific type and minimum length of connecting cable between the transmitter and antenna. For those, the connecting cable has become part of the certified system configuration. Note that the marketing or use of a non-certified WISP transmission system, except as provided in Section 15.23, results in violations of Sections 2.803, 15.1, 15.201, etc. of our rules along with Sections 301 and 302a(b) of Title 47 of the U.S. Code.

It is correct that the Commission has proposed to modify some of its current requirements on the use of replacement antennas and external amplifiers for some WISP products. These proposals were made in ET Docket No. 03-201. However, none of these changes has yet been adopted and there is no guarantee that any of these changes will be made or that any changes that are made will apply to all 15.247 or 15.407 WISP operations. For example, we never proposed to permit an antenna to be replaced using a higher gain antenna than the ones with which the transmitter was certified. The actual changes won't be known until the Commission adopts the Report and Order in this proceeding.

While I do not handle enforcement issues, I am aware of some investigations of equipment suppliers and WISP providers. You need to talk to our Enforcement Bureau for any details in this area. However, I hope my discussion helps clear up any misunderstandings with our system configuration requirements.

John A. Reed
Senior Engineer
Technical Rules Branch