In article , chuck
wrote:

Hello Bruce,

Don't mean to be picking but I'd like to be very clear on
this. Are you saying that all of the owners of "open" Icom
"type accepted" radios who operate these radios on marine
frequencies are operating illegally because the radios are
"open"? Are you certain that the type acceptance does not
include an open version? Is the SGC 2000 being sold in
violation of the law then?

Appreciate the info, Bruce.

Regards,

Chuck


Bruce in Alaska wrote:
In article , chuck
wrote:


We probably need a more carefully worded statement of just
what type acceptance means in this regard (VFOs). Or are you
suggesting that "open" versions of the type-accepted marine
radios are no longer type-accepted?

Regards,

Chuck


Yes I am stating that as a "Fact", that "opened" versions of "Type
Accepted" Radios are not still Type Accepted. The owner, or operator,
is not allowed to change ANY Major Operational Charactoristic of
a "Type Accepted" radio and still have a "Valid Claim" of Type
Acceptance. This is so stated in the FCC's Rules that detail
what is allowed and what spec's are required to meet "Type Acceptance"
by the FCC Chief Engineer, and his Lab. Just doing the required testing
of a radio, takes a couple of months, for MF/HF SSB Radios, and that
doesn't include any Modifications required to get the radio into
compliance. Been there, Done that, and it AIN't EASY........


Bruce in alaska who has worked BOTH sides of this issue......

Lets make this very clear.

The SGC-2000 IS Type Accepted and therefor can be used legally in both
the Marine and Ham Radio Services, as long as it is UNMODIFIED from the
original factory configuration.

Any other Marine Radio that is Type Accepted can be used in Marine or
Ham Radio Service, as long as it is UNMODIFIED from it's original factory
configuration.

If a Marine Radio that is Type Accepted is then subsequently MODIFIED
by anyone other than the OEM, it is NOT considered Type Accepted any
longer, by the FCC, as it is now MODIFIED, and therefor must go thru
the Type Acceptance Procedure again to qualify for Type Acceptance.

Any MODIFICATION to the radio that changes it's basic configuration
or Operating Charactoristics would invalidate the Type Acceptance for
that radio.

"Opening" a radio is considered such a MODIFACTION, as it requires one
to actually take the covers off and change something mechanically inside
the radio, itself, thus altering the FACTORY OEM Configuration.

There are ways around this Type Acceptace modifacation issue. Mostly
it is thru Undocumented Control Features that are built in to the User
Interface that "open" the radio without any MODIFICATION to it. The SEA
Radios all have a "TEST Mode" that is entered into via a Special Key
Sequence from the front panel. This is allowable, as the Test Mode is
not a MODIFICATION of the radio, but an "Undocumented Feature" as the
radio is still in "FACTORY" OEM condition.

There, NOW that should be VERY Clear for anyone who can read, and
comprehend, the King's English.

Bruce in alaska
--
add a 2 before @

The SGC-2000 IS Type Accepted and therefor can be used legally in both
the Marine and Ham Radio Services, as long as it is UNMODIFIED from the
original factory configuration.

Any other Marine Radio that is Type Accepted can be used in Marine or
Ham Radio Service, as long as it is UNMODIFIED from it's original factory
configuration.

If a Marine Radio that is Type Accepted is then subsequently MODIFIED
by anyone other than the OEM, it is NOT considered Type Accepted any
longer, by the FCC, as it is now MODIFIED, and therefor must go thru
the Type Acceptance Procedure again to qualify for Type Acceptance.

Any MODIFICATION to the radio that changes it's basic configuration
or Operating Charactoristics would invalidate the Type Acceptance for
that radio.

"Opening" a radio is considered such a MODIFACTION, as it requires one
to actually take the covers off and change something mechanically inside
the radio, itself, thus altering the FACTORY OEM Configuration.

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then it is
not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then it is
not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acceptance Proceedure, and different than the software
that was in the two submitted Representative Radios, then it is
considered a MODIFICATION by the FCC and would incalidate the
Type Acceptance of that radio when subsequently loaded in the radio
by ANYONE, even the OEM. The Radio isn't the same, when the different
software is loaded, unless that software was included in the Original,
or Subsequent Type Acceptance Proceedure by the OEM.

You can't modify the radio, in ANY substatial way after Type Acceptance
has been granted, and still have that Type Acceptance be Valid.


Bruce in alaska
--
add a 2 before @

On 2005-02-10 05:31:55 +1100, Bruce in Alaska said:

In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then
it is not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acceptance Proceedure, and different than the software
that was in the two submitted Representative Radios, then it is
considered a MODIFICATION by the FCC and would incalidate the
Type Acceptance of that radio when subsequently loaded in the radio
by ANYONE, even the OEM. The Radio isn't the same, when the different
software is loaded, unless that software was included in the Original,
or Subsequent Type Acceptance Proceedure by the OEM.

You can't modify the radio, in ANY substatial way after Type Acceptance
has been granted, and still have that Type Acceptance be Valid.


Bruce in alaska
--

Bruce, don't be too hard on Doug. This is a perception thing.

Generally people don't see software as the same thing as hardware. It
is somehow different because it is "just a file of 1's and 0's". As
more and more equipment is mushware (hardware and software combined to
give a reconfigurable device) that perception will have to change.

Rather than call it software if we were to call it firmware (which it
may be) then most people would consider it as tied to the hardware and
see it in the same light. And yes, the firmware and hardware
combination is type approved as a whole entity. Theoretically a new
release of the firmware would need to be certified as well but I expect
the FCC as a matter of convenience does not require a retest on each
new release of the firmware.

--
Regards,
John Proctor VK3JP, VKV6789
S/V Chagall

Cut me some slack John. I've been an EE and SE for 30 years specializing
mostly in embedded systems. I know the difference between hardware,
software, formware and underware

Doug, k3qt
s/v Callista

"John Proctor" wrote in message
news:2005021007410416807%lost@nowhereorg...
On 2005-02-10 05:31:55 +1100, Bruce in Alaska said:

In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then
it is not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acceptance Proceedure, and different than the software
that was in the two submitted Representative Radios, then it is
considered a MODIFICATION by the FCC and would incalidate the
Type Acceptance of that radio when subsequently loaded in the radio
by ANYONE, even the OEM. The Radio isn't the same, when the different
software is loaded, unless that software was included in the Original,
or Subsequent Type Acceptance Proceedure by the OEM.

You can't modify the radio, in ANY substatial way after Type Acceptance
has been granted, and still have that Type Acceptance be Valid.


Bruce in alaska
--

Bruce, don't be too hard on Doug. This is a perception thing.

Generally people don't see software as the same thing as hardware. It is
somehow different because it is "just a file of 1's and 0's". As more and
more equipment is mushware (hardware and software combined to give a
reconfigurable device) that perception will have to change.

Rather than call it software if we were to call it firmware (which it may
be) then most people would consider it as tied to the hardware and see it
in the same light. And yes, the firmware and hardware combination is type
approved as a whole entity. Theoretically a new release of the firmware
would need to be certified as well but I expect the FCC as a matter of
convenience does not require a retest on each new release of the firmware.

--
Regards,
John Proctor VK3JP, VKV6789
S/V Chagall

On 2005-02-10 08:04:11 +1100, "Doug Dotson"
dougdotson@NOSPAMcablespeedNOSPAMcom said:

Cut me some slack John. I've been an EE and SE for 30 years specializing
mostly in embedded systems. I know the difference between hardware,
software, formware and underware

Doug, k3qt
s/v Callista

"John Proctor" wrote in message
news:2005021007410416807%lost@nowhereorg...
On 2005-02-10 05:31:55 +1100, Bruce in Alaska said:

In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then
it is not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acc

Doug,

Now we can start a ****ing contest. I've been an EE since 1969. Over 25
years in IT and worked in software development, communications as well
as sales and marketing!

You should know that based upon your experience the software that runs
a radio is embedded fiirmware. Very much tied to the radio hardware.
For example memory channels and translating stored frequency
information to the binary code to set frequency is one example where
the firmware and radio hardware are totally dependent upon each other.
Thus type approval must be for hardware and firmware at a specific
revision level. What would happen if the hardware were changed
significantly, you would need to redo certification or convince the
testing organisation that the hardware revision did not change the
radio specifications. The same should be true for the firmware that
controls the radio. That is just plain logical. Oops maybe I just
negated my thinking. After all when was a government agency ever
logical ;-)

--
Regards,
John Proctor VK3JP, VKV6789
S/V Chagall

"John Proctor" wrote in message
news:2005021020272816807%lost@nowhereorg...
On 2005-02-10 08:04:11 +1100, "Doug Dotson"
dougdotson@NOSPAMcablespeedNOSPAMcom said:

Cut me some slack John. I've been an EE and SE for 30 years specializing
mostly in embedded systems. I know the difference between hardware,
software, formware and underware

Doug, k3qt
s/v Callista

"John Proctor" wrote in message
news:2005021007410416807%lost@nowhereorg...
On 2005-02-10 05:31:55 +1100, Bruce in Alaska said:

In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then
it is not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acc

Doug,

Now we can start a ****ing contest. I've been an EE since 1969. Over 25
years in IT and worked in software development, communications as well as
sales and marketing!

You should know that based upon your experience the software that runs a
radio is embedded fiirmware. Very much tied to the radio hardware. For
example memory channels and translating stored frequency information to
the binary code to set frequency is one example where the firmware and
radio hardware are totally dependent upon each other. Thus type approval
must be for hardware and firmware at a specific revision level. What would
happen if the hardware were changed significantly, you would need to redo
certification or convince the testing organisation that the hardware
revision did not change the radio specifications. The same should be true
for the firmware that controls the radio. That is just plain logical. Oops
maybe I just negated my thinking. After all when was a government agency
ever logical ;-)

That's my point. You're are preaching to the choir.

Regards,
John Proctor VK3JP, VKV6789
S/V Chagall

In article 2005021007410416807%lost@nowhereorg,
John Proctor wrote:

And yes, the firmware and hardware
combination is type approved as a whole entity. Theoretically a new
release of the firmware would need to be certified as well but I expect
the FCC as a matter of convenience does not require a retest on each
new release of the firmware.

--
Regards,
John Proctor VK3JP, VKV6789
S/V Chagall

If the firmware upgrade, makes any Substantial Change in the Operational
Charactoristics of the Radio then the FCC does require a new
Type Acceptance Proceedure from the OEM. "Opening" a radio may
be considered a Substantial Change, and therefore could trigger
a resubmitted Type Acceptance Filing. This would determined by the
OEM in consultation with the Office of Cheif Engineer at the FCC
Lab.

Bruce in alaska
--
add a 2 before @

How about an answer for a change. IS THE ICOM-M710 WITH THE
ICOM SUPPLIED SOFTWARE UPDATE TO ENABLE HAM BANDS
TYPE ACCEPTED? IS THERE A DIFFERENCE BETWEEN AN
M710 PURCHASED WITH THE MOD DIFFERENT THAN A RIG
THAT HAD THE MOD DONE LATER? I haven't a clue what ICOM
submitted to the FCC. It doesn;t seem to appear in the manual. Can you
wrap your head around this question?

Doug, k3qt
s/v Callista



"Bruce in Alaska" wrote in message
...
In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:

Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then it
is
not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista

Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acceptance Proceedure, and different than the software
that was in the two submitted Representative Radios, then it is
considered a MODIFICATION by the FCC and would incalidate the
Type Acceptance of that radio when subsequently loaded in the radio
by ANYONE, even the OEM. The Radio isn't the same, when the different
software is loaded, unless that software was included in the Original,
or Subsequent Type Acceptance Proceedure by the OEM.

You can't modify the radio, in ANY substatial way after Type Acceptance
has been granted, and still have that Type Acceptance be Valid.


Bruce in alaska
--
add a 2 before @

All Icom M710 transceivers mfg. since July 2002 are a type accepted
marine transceiver that has the ham bands enabled by Icom. NO software
uploads required. No "opening" of the radio required. It is legal for
the Marine bands if you have a ships radio license and Restricted Radio
operators license, and legal for the ham bands if you have a general or
higher ham license.
krj

Bruce in Alaska wrote:
In article ,
"Doug Dotson" dougdotson@NOSPAMcablespeedNOSPAMcom wrote:


Not all that clear. The ICOM M-710 is "opened" by uploading software
mods. Are you saying that if these mods are uploaded by the factory
or a dealer then it is still Type Accepted, but if I do it myself then it is
not?

BTW, your shift key seems to be malfunctioning. Better have it checked
by a qualified technician

Doug, k3qt
s/v Callista


Geeez Doug, What does it take for you to understand, here?

The software that is running in the radio, IS part of the Operational
Interface, and if it is different than what was submitted to the FCC
during the Type Acceptance Proceedure, and different than the software
that was in the two submitted Representative Radios, then it is
considered a MODIFICATION by the FCC and would incalidate the
Type Acceptance of that radio when subsequently loaded in the radio
by ANYONE, even the OEM. The Radio isn't the same, when the different
software is loaded, unless that software was included in the Original,
or Subsequent Type Acceptance Proceedure by the OEM.

You can't modify the radio, in ANY substatial way after Type Acceptance
has been granted, and still have that Type Acceptance be Valid.


Bruce in alaska