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Author Topic: Do we need to petition the FCC regarding Part 15 compliance?  (Read 5519 times)
AA4HA
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« on: June 03, 2010, 06:01:19 AM »

So many of the interference problems we see are caused by devices that "should" be in compliance with Part 15 but either has not been tested or was tested under questionable circumstances.

A few years ago the FCC loosened the requirements for FCC compliance testing and allowed manufacturers to "self test" or to qualify a product as being in compliance because it was similar in design to something they had previously tested. Things were much better when the products earned a Part 15 compliance certificate after it was tested by an independent laboratory.

We have loosened (abandoned) our standards for FCC compliance in the interest of expediency for manufacturers to push products to market as quickly as possible. It has become a joke and all sorts of cheap (and expensive) trash is out there spewing out all sorts of RFI.

If the FCC is not going to enforce the rules then they should just delete the rules completely from Title 47.

I propose that someone start a petition or a request for rulemaking to the FCC for better FCC compliance standards (and enforcement).

Tisha Hayes, AA4HA
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Ms. Tisha Hayes, AA4HA
Lookout Mountain, Alabama
WX7G
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« Reply #1 on: June 03, 2010, 08:00:43 AM »

Devices that are compliant to FCC conducted and radiated emissions limits can still create quite a noise on the HF bands. If you want to be able to communicate near a device it needs to pass MIL emissions standards and those are over 30 dB below the FCC radiated emissions limits.

Additionally, testing at an EMI house (for self compliance) is not the same as installing a unit in a house. The well known DirecTV receiver RFI is an example of this. I have been told that during ENC testing the antenna cable was grounded to the EMC chamber floor so that it would pass radiated emissions. In a home installation it is not grounded this way.

The "must not cause harmful interference" label on consumer devices says that the device must be taken out of service if it harms radio communications.
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AA4PB
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« Reply #2 on: June 03, 2010, 09:01:38 AM »

The big question is, are the devices interferring because they don't meet standards or because the standards are not strict enough? The only way to tell that is to take a device that is interferring and then test it to see if it meets standards. That way you know what to change, the standards or their enforcement.
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KD6KWZ
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« Reply #3 on: June 03, 2010, 11:51:55 PM »

I read here somewhere that the ARRL has a Lab to check on part 15 suspect devices.

Some consumer electrical/electronic devices do have things like ferrites built into power cords from the factory, like my CPAP machine, so some companies are trying to do the right thing. But, some people expect RF miracles, like my non-ham Mother had a small TV placed above a microwave oven, and was disappointed that the microwave caused interference when running! And, check out the RF noise from a running calculator next to an AM radio, for example.

Quote
The big question is, are the devices interfering because they don't meet standards or because the standards are not strict enough?

Good question. I'm not happy to hear that bit about DirecTV. Do they insist on ground in the field installation instructions? If not, there's too much wiggle room in the rules for RFI.
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WX7G
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« Reply #4 on: June 04, 2010, 07:51:14 AM »

The big question is, are the devices interfering because they don't meet standards or because the standards are not strict enough?

Both. The standards are not intended to drive device RF emissions low enough to allow interference free amateur radio operation nearby. They are intended to allow most consumer RFcommunication (radio, TV reception) to be successful. As far as meeting the standards, they may pass at the EMC test house - this is what the standard calls out - but radiate much more in a consumer installation. I suspect that most of this is due to ignorance. Most design engineers are quessing when it comes to EMC. But in some cases they are aware that their device will pass at the EMC house but will fail at a consumer installation. They are adhering to the letter of the law but not the intent. This fails the 'due diligence' test.

I've worked in the EMC field for many years and have observed that the aim of many companies is simply to obtain a document saying they are compliant to such-and-such standards while ignoring the real world implications.

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N2EY
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« Reply #5 on: June 04, 2010, 09:30:23 AM »


Both. The standards are not intended to drive device RF emissions low enough to allow interference free amateur radio operation nearby. They are intended to allow most consumer RFcommunication (radio, TV reception) to be successful. As far as meeting the standards, they may pass at the EMC test house - this is what the standard calls out - but radiate much more in a consumer installation. I suspect that most of this is due to ignorance. Most design engineers are quessing when it comes to EMC. But in some cases they are aware that their device will pass at the EMC house but will fail at a consumer installation. They are adhering to the letter of the law but not the intent. This fails the 'due diligence' test.

I've worked in the EMC field for many years and have observed that the aim of many companies is simply to obtain a document saying they are compliant to such-and-such standards while ignoring the real world implications.


What we're seeing is the direct result of ~30 years of deregulation. Or what is sometimes referred to as "fox guarding the hen house".

Whether it's the oil spill in the Gulf, the financial meltdown, BPL, RFI or CC&R troubles, the driving force has been the push for "small government" and "free trade". The individual person on the receiving end has the burden of forcing the big company to meet the watered-down regulations.

It didn't used to be like that.

73 de Jim, N2EY
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WX7G
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« Reply #6 on: June 04, 2010, 12:37:53 PM »

I don't see the FCC EMC regulations as having been watered down. The FCC never did their own EMC testing, did they? The thing that has changed is that one can self-certify. A layer of paper work has been removed from the process. The testing is the same in that a manufacturer has an EMC test house test one unit. The goal of the EMC test house and the equipment manufacturer is to get the unit to pass; a certificate from the test house is the goal. This is a conflict of interest.

Perhaps someone needs to get the ARRL on the DirecTV receiver issue. They can test and decide if the FCC needs to be informed. This could lead to, for example, ferrites being sent to each of the millions of DirecTV subscribers. Would this serve as a warning to companies willing to cut EMC corners? In some cases yes but in most cases I think not.

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AA4HA
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« Reply #7 on: June 05, 2010, 10:16:12 AM »

But in some cases they are aware that their device will pass at the EMC house but will fail at a consumer installation. They are adhering to the letter of the law but not the intent. This fails the 'due diligence' test.

I've worked in the EMC field for many years and have observed that the aim of many companies is simply to obtain a document saying they are compliant to such-and-such standards while ignoring the real world implications.

I had only worked as a compliance engineer for three years back in the early 90's (before self certification) and I took my duties seriously. As I had "graduated" up into the position from a design engineering position I was also responsible for the redesign to get into compliance. Being in that position, at that point in time in a product development cycle, cost became less of an issue and I was permitted to "do the right thing".

Today I pick up a product off the shelf and am simply appalled by the complete lack of even basic EMC compliance measures but I flip over the device and see a Part 15 sticker. The Direct TV problems is a great example, so are BPL modems and plasma displays. It is pushing us more and more into the role of being an auxiliary arm of the FCC to find these devices but with no authority to go cut the cord off and beat the manufacturer about the head.

It takes an inordinate amount of RFI for it to affect most other consumer devices. As far as sensitivity to RFI is concerned we are only surpassed by radio astronomers. For the unwashed masses we are both geeks and nerds (hams and radio astronomers, not mutually exclusive) and the expediency of pushing new products out the door is the most important thing to them. Look at the squabble with the iPad and Israel from a few months ago when Israel would not allow the iPad into their country as it had not been tested to their standards (good for them). Inevitably they bowed to commercial pressures and relented, allowing folks to bring them into their country.

If a microwave oven didn't have an inherent risk of cooking your brains while in operation those things would not have shielding and doors if they were a new product today.

The standards are they are, suck, but they are supposedly the law of the land. Yes, I would like to see MIL standards for EMC but that is definitely a more difficult design proposition. All I ask for is that the current standards be enforced with penalties for companies that stick a Part 15 sticker on a product without any vestiges of a testing program (or knowing that it will not be in compliance).

One thing I run across all the time is where some company has installed a wireless device that has certain power restrictions ( 36 dB EIRP, etc...) and they install amplifiers to raise the power of the device well beyond any compliance limitations. I am fighting that problem right now for one customer where a local internet provider has put amplifiers on all of their gear, making the use of the band impossible for anyone else. The FCC has been called out there twice and gone through the same process that we did to identify the interference and calculate the power levels. They did an inspection and found the amplifiers and told the customer to remove them. A few days later, after the FCC has taken their white van and gone home the ISP has reinstalled their amplifier. So far there has been no legal action against this user and the FCC treats them like a wayward pre-schooler with no real punishment.

 Grin if the FCC would give us the power to do something I would create a small HARM missile that you could launch over a town. It would detect the offending device, zoom down and blow the thing to smithereens.

Tisha Hayes
« Last Edit: June 05, 2010, 10:20:37 AM by Tisha Hayes » Logged

Ms. Tisha Hayes, AA4HA
Lookout Mountain, Alabama
WX7G
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« Reply #8 on: June 05, 2010, 02:25:19 PM »

I doubt that plasma televisions violate FCC emissions class B test levels. The complaints I have seen at eham are about interference in the lower HF band. Radiated emissions levels are not tested below 30 MHz.

However, I think that FCC Part 15.33 Frequency Range of Radiated Measurements, (2) does apply to plasma televisions. This standards calls out testing down to 9 kHz because the TV outputs baseband video.

FCC Part 15.29 Inspection by the Commission, part (d) spells out how the FCC can test a unit.  

FCC Part 15.109 Radiated Emissions Limits, part (e) applies to plasma televisions and calls out the emission limits in 15.221 (a). I think that Part 15.223 Operation in the band 1.705 - 10 MHz can be invoked.

FCC Part 15.223 (a) specifies a radiated emissions limit of 100 uV/m at 30 meters for emissions exceeding 10% of the center frequency. But as plasma TV screen emissions are not this wide 15 uV/m at 30 meters appears to be the correct limit.

What received signal will 15 uV/m at 30 meters produce into an 80 meter vertical located 30 meters away? About 150 uV, which is S-9 plus 10 dB. In a real world installation emissions can exceed what is measured at an EMC test site. This is because the test site does not include AC power wiring that mimics long runs of exposed house wiring. This means that if the FCC were to test the unit as being compliant it could still (legally) exceed the limits in a real world installation.

From what I've read at eham plasma televisions may very well comply with FCC emissions standards. So it is not up to the manufacturer to remedy interference to amateur radio communications it is up to the plasma TV user (owner). This is invoked by the condition listed on the TV FCC certification sticker: This device may not cause harmful interference.

The next time you experience interference from a neighbor's TV or other device tell him that he is required by FCC regulations to stop using the device; and report his reaction to us.

 

« Last Edit: June 05, 2010, 04:17:43 PM by DAVE CUTHBERT » Logged
AA4HA
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« Reply #9 on: June 05, 2010, 07:30:24 PM »

The next time you experience interference from a neighbor's TV or other device tell him that he is required by FCC regulations to stop using the device; and report his reaction to us.

Exactly, they will laugh at you and slam the door in your face. The fix is not in us becoming the raving lunatics, members of the tinfoil hat society, in our communities. It is getting the federal government to enforce the laws that they have already set in place that regulate consumer products.
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Ms. Tisha Hayes, AA4HA
Lookout Mountain, Alabama
WX7G
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Posts: 6079




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« Reply #10 on: June 06, 2010, 12:14:35 PM »

But as I said, plasma TVs appear to be in compliance with FCC radiated emissions levels, from what I have read at eham. If this is the case the only legal avenue is to invoke the "may not cause harmful interferrence" rule.

If anyone has a complaint direct it to the ARRL or the FCC.

If someone in the Salt Lake City area has a plasma TV I can work on I can see about reducing the radiated emissions. Be aware that a 20 dB reduction would be an agressive goal. This is but 3 S-units.
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N2EY
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« Reply #11 on: June 07, 2010, 03:09:37 AM »

The fix is not in us becoming the raving lunatics, members of the tinfoil hat society, in our communities. It is getting the federal government to enforce the laws that they have already set in place that regulate consumer products.

The problem I see is the culture of deregulation and the triumph of MBAs over EEs.

Take BPL - I remember a time when no company with any sense at all would have even proposed such a thing, because they knew FCC would shoot it down. If a company persisted, the FCC would take them aside and say something like "the first time we get a complaint of harmful interference we'll make you shut it off". Who would pursue such a technology?

But that was the old days. Over time the manufacturers have learned that such shutdowns and product pulls are rare to nonexistent, and that by the time anything is done, they'll have made their money and moved on.

Here's an analogy:

Suppose that tomorrow every state and federal regulation regarding pollution controls on cars and trucks was removed. Or simply not enforced any more.

You wouldn't see a change in air quality right away. People wouldn't start ripping out catalytic converters and such, and you wouldn't find leaded gas at the pumps any time soon.

But over time the message would get across. You'd start to see cars with no pollution controls for sale, and their lower price would crowd out those with pollution controls. Pretty soon you'd be hard pressed to find a car that had pollution controls.

I use this analogy because RFI really is a form of pollution. And we hams are "downstream" from the polluters.

73 de Jim, N2EY
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K5END
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« Reply #12 on: June 07, 2010, 07:27:22 AM »


I propose that someone start a petition or a request for rulemaking to the FCC for better FCC compliance standards (and enforcement).

Tisha Hayes, AA4HA

Excellent idea.

I would emphasize enforcement in the petition. We have to start somewhere, and tighter regs without enforcment would be of little use. If the FCC needs more budget to do enforcement, they would welcome as many of these petitions as they can process. Writing to ones senator and representative would be a good measure as well, IMO.

It appears that you are sufficiently informed in both the technical and regulatory details to draft such a petition.

Do so and I will review and sign (if in agreement with the content.)
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AA4HA
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« Reply #13 on: June 07, 2010, 09:05:43 AM »

But that was the old days. Over time the manufacturers have learned that such shutdowns and product pulls are rare to nonexistent, and that by the time anything is done, they'll have made their money and moved on.

Yes, we are in the "too big to fail" mentality today. If a company (bank, manufacturer, etc...) pushes millions of "something" out there, knowing that it is a defective product or idea they are confident that the rules will be changed after the fact. At one time a deliberate decision to ignore the rules when manufacturing a product would result in bankruptcy for the company. Now it is a rush to push as much stuff as possible into the marketplace so the sheer mass of a bad product will overwhelm any attempts to regulate it after the fact. Overseas manufacturers can make garbage (some by the prompting of US companies) and they are hidden behind LLC's or a lack of international repercussions.

I am by no means an advocate of "big government" and I do believe that a free market society is the best solution so far. We do need some basic regulation on corporate behavior with strong repercussions for the folks who knowingly disregard the law. For an electronics manufacturer, ignorance is no excuse. Piss-poor products should not be shilled with the "risk of getting caught" being justified by MBA's as the cost of doing business.

Tisha Hayes
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Ms. Tisha Hayes, AA4HA
Lookout Mountain, Alabama
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