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Yes, obviously, it would be best if there's not an emission that doesn't include a call sign ID. Part 97 seems to say this should never, ever occur (the law is often written in that kind of black-and-white view).

The real world isn't quite that cooperative, in my experience.

Especially with radio gear under repair or gear operated by internal firmware, it's very possible to accidentally transmit either without knowing it has occurred, or without any way to subsequently transmit a call sign.

Say you're repairing a transceiver, and you power the station (connected to an antenna) to check receive functions -- and realize after a few seconds that it's transmitting. You don't have a microphone or key connected, so it's not practical to transmit an ID.

Do you need to pick up your cell phone and turn yourself in to the FCC? Or, realistically, what should you do in this kind of situation?

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Practically I think the answer is more or less as Brian says. Mistakes happen and I think it's generally reasonable to simply move on:

[…] if the unintended transmission was brief, within the ham bands and did not interfere with urgent operations.

In fact, I imagine an argument could be made that this is the most reasonable decision, in accordance with §97.101:

(d) No amateur operator shall willfully or maliciously interfere with or cause interference to any radio communication or signal.

As soon as you realize that you were unintentionally transmitting, the first and best thing to do would be to cease transmitting.

The identification requirement is a requirement. I'm not trying to downplay that. But let's say you're in a situation where you've just unintentionally transmitted and perhaps in an interfering matter. Now you have a choice. Which rule would you rather break next — flout the identification rule this time, or perpetuate against the willful interference rule?

Personally, I would rather go with "least said soonest mended". Shut down and be prepared to apologize profusely for the initial unintended (and unidentified) transmission should the occasion arise. If I would willfully keep interfering, solely in an attempt to identify myself, that doesn't seem to help either party.

However, to answer the original question more directly, I think there is nearly always a way to identify — if, only if, and/or when I am reasonably certain that I am able to transmit a clean and non-interfering signal. The "key" (pun intended) is that there is no lower limit to the speed of a CW emission. Quoting §97.119:

(b) The call sign must be transmitted with an emission authorized for the transmitting channel in one of the following ways:

(1) By a CW emission. When keyed by an automatic device used only for identification, the speed must not exceed 20 words per minute;

(2) […other potentially authorized options follow…]

I understand this to mean:

  • it is always acceptable to identify by a CW emission, since CW is an "emission authorized" everywhere within the ham bands.
  • there's a maximum speed limit when automatic keying, but…
  • there's no regulation on speed for manual keying. Neither maximum, or… minimum!

To get to the point, if you have enough control to both start and stop your transmissions at any given time, you are able to identify in Morse Code! Maybe back in ham's heydey they called this "Westinghouse keying" or something :-P

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  • $\begingroup$ +1, Nate. However if you're going to ID via CW in this case, I think one's callsign should be sent at a very high speed to minimize QRM. Program your callsign to at least 60 WPM. :-) $\endgroup$
    – Mike Waters
    Commented Apr 10, 2019 at 18:00
  • $\begingroup$ @MikeWaters Do you mean 60Hz? That's what I'm getting at… ;-) $\endgroup$
    – natevw - AF7TB
    Commented Apr 10, 2019 at 18:01
  • $\begingroup$ At 60Hz, your ID could not be heard. $\endgroup$
    – Mike Waters
    Commented Apr 10, 2019 at 18:07
  • $\begingroup$ Heh, I'm probably mixing too much humor and seriousness here… the OP was asking in the context of a transceiver on the bench, not really hooked up or prepared to transmit normally. But at worst case, they could plug/unplug the device from the wall (modulating the 60Hz VAC "Westinghouse input") to transmit a QRSS CW signal. Automatic keying would have to be limited to 20 WPM per §97.119 and wouldn't usually be an option in the sort of scenario the question implies. $\endgroup$
    – natevw - AF7TB
    Commented Apr 10, 2019 at 18:15
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    $\begingroup$ This had actually occurred to me -- I remember it as "CBCW" since you can do it even on a 70s vintage CB just by keying and releasing the PTT. It'd be slow and sloppy, and in my shack, uncomfortable (at present, the power is a strip under the workbench) -- but it'd be legal. Providing, of course, that I can actually receive with something on the tuned frequency to assure clear air. $\endgroup$
    – Zeiss Ikon
    Commented Apr 10, 2019 at 19:16
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Before connecting a radio to an antenna, you could test your repair procedure with a dummy load to prevent this from happening. It is good engineering practice to make off-the-air observations and measurements of the effects of any change to a regulated emitter to ensure compliance once the antenna is connected. Note that, since the impedance of an antenna can affect the behavior of a transmitter or amplifier, off-the-air testing ideally replicates the load presented to the transmitter by the antenna.

If you have not followed this procedure, however, there would seem to be no reason to, "pick up your cell phone and turn yourself in to the FCC," if the unintended transmission was brief, within the ham bands and did not interfere with urgent operations.

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  • $\begingroup$ A dummy load doesn't help much to test the receiver. In the situation I described, I've have had to know beforehand that the radio would transmit uncommanded to know I needed a dummy instead of an antenna. $\endgroup$
    – Zeiss Ikon
    Commented Apr 9, 2019 at 13:19
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    $\begingroup$ @ZeissIkon If you had run the same test with a dummy load, before you ran the test with an antenna, you would have learned that the radio would transmit and you would have set up your on-air test differently to avoid the unidentified transmission. This is why the off-air test is good engineering practice: you find out things you didn't know before committing a faux pas. $\endgroup$
    – Brian K1LI
    Commented Apr 9, 2019 at 15:03
  • $\begingroup$ So this is basically a "don't have this problem" answer. And I need to add a dummy load to the list of "you can't fix anything you can afford without this". At least it's cheaper than the o-scope and frequency analyzer I also need before I key any used transmitter... $\endgroup$
    – Zeiss Ikon
    Commented Apr 9, 2019 at 15:41
  • $\begingroup$ @ZeissIkon I understand the frustration. The typical advice to save some money by buying a "boat anchor" is flat wrong IMO. Vintage gear is priced like precious antique to start with, and factoring in the equipment needed to "align" them and whatnot would get you a new rig. The route I went was QRP kits (where a scope is handy but not strictly necessary, and dummy loads are cheap/DIY affairs) and already-working 80s/90s equipment. $\endgroup$
    – natevw - AF7TB
    Commented Apr 10, 2019 at 18:35
  • $\begingroup$ Come to think of it, buying "already-working [thirty years old] equipment" is probably exactly what people were doing when the "boat anchor" advice started. If your device has firmware, you're probably not talking about restoring some softly-glowing Heathkit anyway! $\endgroup$
    – natevw - AF7TB
    Commented Apr 10, 2019 at 18:42

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