AG03
QST de W1AW  
ARRL Bulletin 3  ARLB003
>From ARRL Headquarters  
Newington CT  January 12, 2017
To all radio amateurs 

SB QST ARL ARLB003
ARLB003 Illegal Drone Transmitters Could Interfere with Air Traffic
Control, ARRL Complaint Asserts

In what it calls an 'extremely urgent complaint' to the FCC, ARRL
has targeted the interference potential of a series of audio/video
transmitters used on unmanned aircraft and marketed as Amateur Radio
equipment. In a January 10 letter to the FCC Spectrum Enforcement
Division, ARRL General Counsel Chris Imlay, W3KD, said the
transmitters use frequencies intended for navigational aids, air
traffic control radar, air route surveillance radars, and global
positioning systems.

'This is, in ARRL's view, a potentially very serious interference
problem, and it is respectfully requested that the products
referenced...be investigated and removed from the marketplace
immediately and that the importers be subjected to normal
sanctions,' ARRL's letter said. Some of the transmitters operate on
frequencies between 1010 and 1280 MHz. 'These video transmitters are
being marketed ostensibly as Amateur Radio equipment,' the League
said, 'but of the listed frequencies on which the devices operate,
only one, 1280 MHz, would be within the Amateur Radio allocation at
1240-1300 MHz.' Even then, ARRL said, operation there would conflict
with a channel used for radio location.

ARRL said the use of 1040 and 1080 MHz, which would directly
conflict with air traffic control transponder frequencies,
represented the greatest threat to the safety of flight. The use of
1010 MHz, employed for aeronautical guidance, could also be
problematic.

ARRL cited the Lawmate transmitter and companion 6 W amplifier as
examples of problematic devices being marketed in the US. Each costs
less than $100 via the Internet. The device carries no FCC
identification number.

'[T]he target market for these devices is the drone hobbyist, not
licensed radio amateurs. The device, due to the channel
configuration, has no valid Amateur Radio application,' ARRL told
the FCC. 'While these transmitters are marked as appropriate for
amateur use, they cannot be used legally for Amateur Radio
communications.' In the hands of unlicensed individuals, the
transmitters could also cause interference to Amateur Radio
communication in the 1.2 GHz band, ARRL contended.

The League said it's obvious that the devices at issue lack proper
FCC equipment authorization under FCC Part 15 rules, which require
such low-power intentional radiators to be certified.

'Of most concern is the capability of the devices to cripple the
operation of the [air traffic control] secondary target/transponder
systems,' ARRL said. 'These illegal transmitters represent a
significant hazard to public safety in general and the safety of
flight specifically.'

The surge in sales of drones has been dramatic. The FAA has
predicted that combined commercial and hobby sales will increase
from 2.5 million in 2016 to 7 million by 2020.

In Exhibit A of the January 10 letter, 'Illegal Drones Threaten
Public Safety,' the League noted that some of the drones and
associated equipment it has come across 'are blatantly illegal at
multiple levels,' with some drone TV transmitters described as
'particularly alarming.'

'Rated at 6 times over the legal power limit, and on critical air
navigation transponder frequencies, these devices represent a real
and dangerous threat to the safety of flight, especially when
operated from a drone platform that can be hundreds of feet in the
air,' the exhibit narrative asserted.