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Author Topic: Leviton Dimmer for 20-25W LEDs  (Read 1855 times)
AE5GT
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Posts: 398




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« Reply #15 on: September 08, 2018, 03:33:33 PM »

Except when you refuse to do anything about it. Its an unintentional radiator  until you know about it  ,then its intentional and falls under 15.209 ...paragraph 4   https://transition.fcc.gov/eb/FieldNotices/2003/DOC-275720A1.html 
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W9IQ
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Posts: 3414




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« Reply #16 on: September 08, 2018, 04:03:30 PM »

Except when you refuse to do anything about it. Its an unintentional radiator  until you know about it  ,then its intentional and falls under 15.209 ...paragraph 4   https://transition.fcc.gov/eb/FieldNotices/2003/DOC-275720A1.html  

That is not a correct interpretation. In the cited proceeding, the power company was operating an "incidental radiator" that was causing harmful interference. This does not change because they do or don't know about it. As an incidental radiator, their distribution system may not cause harmful interference. The FCC cites that they are causing harmful interference to a licensed radio service (W5KFT).  They then point them to the radiation limits for intended radiators to make it clear that they are exceeding even those limits. This is a subtle reference on the part of the FCC since even an intended radiator under part 15 may not cause harmful interference.

One of the other subtle points of such a citation is that it is the operation of the device that may not cause harmful interference. This often places the burden on the owner/operator of the device in question rather than the manufacturer. This was certainly the basis in the cited proceeding.

Because of regulations place the non-interference burden on the operation of the device, if an intentional, an unintentional, and an incidental radiator that falls under part 15 regulations meets the requirements for emissions, the FCC will cite the only the operator that is causing the interference. If they discover, for example, that a part 15 intentional radiator exceeds the allowed field strength limits, then the FCC will go after the manufacturer for violating the limits as well as the operator causing harmful interference.

The part 15 regulations have been pieced together over the years and so it holds many caveats and exceptions. They can be very confusing for the uninitiated.

- Glenn W9IQ
« Last Edit: September 08, 2018, 04:12:02 PM by W9IQ » Logged

- Glenn W9IQ

I never make a mistake. I thought I did once but I was wrong.
AE5GT
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Posts: 398




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« Reply #17 on: September 09, 2018, 10:51:15 AM »

If it doesnt make any difference whether they know about or not , then why did the FCC send out two previous letters  notifying  the power company ? why not just cite them right off the bat?

It makes a difference whether they are knowingly violating the rules and regs .  The initial letters make sure that they know. 



While its clear that the FCC is Citing them under "harmful interference" clause , the FCC does not appear to  define what constitutes harmful interference.
From the Citation
"
4. Section 15.209 sets the general radiated emission limits for
       intentional radiators. The limit for the band 30 to 88 MHz is 100
       micro-volts per meter measured at 3 meters. The attached list of
       strong electrical arcing points appears to exceed the value allowed
       even for intentional radiators.
"

This is not subtle reference . The FCC sent an engineer out to measure 44  points specifically in reference to 15.209.

The FCC is pretty clear , the "least" they expect is for 15.209 to be met . In effect they are using 15.209 as a minimal definition of what constitutes "harmful interference".



 The FCC is telling the power company if your " incidental radiator " radiates and you've known about it for more than 90 days , there going to treat it as intentional and cite accordingly.

 




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W9IQ
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« Reply #18 on: September 09, 2018, 04:20:33 PM »

The number of notices have nothing to do with the applicable regulations nor the terminology involved.

As I stated earlier, the FCC was coaching them to at least meet the requirement of an intentional radiator. To me this would indicate the FCC felt these levels would mitigate the harmful interference claim.

- Glenn W9IQ
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- Glenn W9IQ

I never make a mistake. I thought I did once but I was wrong.
W9IQ
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« Reply #19 on: September 09, 2018, 05:01:50 PM »

I should also point out that you are falling into the trap of applying and using terms in the way you want them to be defined. When dealing with the FCC regs, you need to stay with their definitions in order to reach a proper interpretation or application.

Read the regs for the definition of "intentional radiator", for example, and only use that meaning when reading the regs and related documents. Don't put your bias or slant into the definition.

And I neglected to answer your question as to why the FCC did not immediately pursue an enforcement action. It is common in the US legal system to practice selective enforcement. Obviously in this case they felt that warnings and remedial steps were more prudent for the situation.

- Glenn W9IQ
« Last Edit: September 09, 2018, 05:14:46 PM by W9IQ » Logged

- Glenn W9IQ

I never make a mistake. I thought I did once but I was wrong.
WB4SPT
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Posts: 777




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« Reply #20 on: September 10, 2018, 05:45:30 AM »

An intentional radiator (defined in Section 15.3 (o)) is a device that intentionally generates and emits radio frequency energy by radiation or induction that may be operated without an individual license.

A pole mounted insulator is no-how an intentional radiator.   (Its a defective insulator)...

Maybe there is some confusion with a spark-gap transmitter, that IS an intentional radiator.   Grin
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AE5GT
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Posts: 398




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« Reply #21 on: September 11, 2018, 03:10:17 PM »

I should also point out that you are falling into the trap of applying and using terms in the way you want them to be defined. When dealing with the FCC regs, you need to stay with their definitions in order to reach a proper interpretation or application.

Read the regs for the definition of "intentional radiator", for example, and only use that meaning when reading the regs and related documents. Don't put your bias or slant into the definition.

And I neglected to answer your question as to why the FCC did not immediately pursue an enforcement action. It is common in the US legal system to practice selective enforcement. Obviously in this case they felt that warnings and remedial steps were more prudent for the situation.

- Glenn W9IQ

BS .
Is this selective enforcement ?

http://www.arrl.org/fcc-enforcement-activities-and-the-electric-utility-industry

doesn't look to me like their being to selective here.



is it selective enforcement when the FCC has a form letter for it?

http://www.arrl.org/fcc-power-utility-letter
4
Its common pratice for the FCC  to send out warning letters  determine "intent"  for a potential violation they want to find out whether you really mean to do it or not ,and penalize accordingly. .Thats the case in virtually all FCC enforcement actions whether its individuals or power companies.
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AE5GT
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Posts: 398




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« Reply #22 on: September 11, 2018, 03:30:54 PM »

An intentional radiator (defined in Section 15.3 (o)) is a device that intentionally generates and emits radio frequency energy by radiation or induction that may be operated without an individual license.

A pole mounted insulator is no-how an intentional radiator.   (Its a defective insulator)...

Maybe there is some confusion with a spark-gap transmitter, that IS an intentional radiator.   Grin

Whether or not a device is "faulty" is irrelevant , its what you intend . If you deliberately leave it there to radiate , Then its an "intentional radiator" .  

"But your honor when i bought it was just a piece of 14-2 romex  wire rolled up, it didn't say "intentional radiator" on the outside of the package. "

It doesn't matter what it is , its what you do with it or allow it to do. And after 90 days they'll assume that its "intentional". You're making an assumption that original design intent determines whether its an "intentional radiator"  it doesn't,
« Last Edit: September 11, 2018, 03:33:25 PM by AE5GT » Logged
WB4SPT
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Posts: 777




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« Reply #23 on: September 11, 2018, 05:41:07 PM »



Whether or not a device is "faulty" is irrelevant , its what you intend . If you deliberately leave it there to radiate , Then its an "intentional radiator" .  



per your ARRL form letter:

Under FCC rules, most power-line and related equipment is classified as an "incidental radiator." This term is used to describe equipment that does not intentionally generate any radio-frequency energy, but that may create such energy as an incidental part of its intended operation.

The "intention" is to hold up a power line.   But, it has a "incidental" effect, that is not intentional. 
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W9IQ
Member

Posts: 3414




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« Reply #24 on: September 11, 2018, 09:18:52 PM »

Quote
BS .
Is this selective enforcement ?

http://www.arrl.org/fcc-enforcement-activities-and-the-electric-utility-industry

doesn't look to me like their being to selective here.

When you take the application of a very well established and accepted legal term and call it BS, it is clear to me you have no interest in learning but you are in it simply to argue.

I leave you with this last piece of legal advice - if you are cited by the FCC, do not represent yourself unless your intent is to lose.

- Glenn W9IQ
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- Glenn W9IQ

I never make a mistake. I thought I did once but I was wrong.
AE5GT
Member

Posts: 398




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« Reply #25 on: September 11, 2018, 10:27:21 PM »

 
Quote
BS .
Is this selective enforcement ?

http://www.arrl.org/fcc-enforcement-activities-and-the-electric-utility-industry

doesn't look to me like their being to selective here.

When you take the application of a very well established and accepted legal term and call it BS, it is clear to me you have no interest in learning but you are in it simply to argue.

I leave you with this last piece of legal advice - if you are cited by the FCC, do not represent yourself unless your intent is to lose.

- Glenn W9IQ


I ll take that as a no then.

The original poster was asking for some idea as to the amount of noise that might be expected . I gave the best answer i could with numbers not hand waving.

I HAVE HEARD NOTHING FROM YOU TO THAT END . Nothing but condescending attitude  (which i have ignored up to now) , arguments, and explanations with NO EVIDENCE to back it up.  I have at least provided documentation to show my reasoning is based on former enforcement actions .

All I have gotten out you is hand waving arguments  and dismissal.  Which leads me to believe your full of it. It looks to me like you got yourself in over your head  and couldn't BS your way out.

If you want someone to believe what your saying in a contentious debate you need to provide something to back it up not just blow smoke .  I am willing to listen to your evidence not your smoke .


Whether or not a device is "faulty" is irrelevant , its what you intend . If you deliberately leave it there to radiate , Then its an "intentional radiator" . 



per your ARRL form letter:

Under FCC rules, most power-line and related equipment is classified as an "incidental radiator." This term is used to describe equipment that does not intentionally generate any radio-frequency energy, but that may create such energy as an incidental part of its intended operation.

The "intention" is to hold up a power line.   But, it has a "incidental" effect, that is not intentional. 
[/quote]


If you take the time to read the letter you'll see its the first letter that goes out. And its the FCCs letter not the ARRLs . Laura Smith is the FCCs counsel .  It appears to me that they assume that its unintentional at the initial issuance, but after another 90 days they issue a citation  and  in at least 2 of the citations 15.209 is referenced and the FCC sends someone out to make observations in reference to 15.209 . Presumably , they are doing that with the intent to use it , should it go to court . 

Do you think if  someone is "inadvertently" dumping raw sewage into your drinking water , for 90 days after you notify them , that they might be doing it  intentionally ?






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WB4SPT
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Posts: 777




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« Reply #26 on: September 12, 2018, 11:53:01 AM »

So, in the POCO example;  its really the "intention" to ignore the warnings, as opposed to the intention of product design.  Is this the message? 
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K7NI
Member

Posts: 55




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« Reply #27 on: September 12, 2018, 07:38:29 PM »

Well this sure got a long way from the original question.

The power company in the example appears to be in violation of the basic requirement to not cause harmful interference. The FCC went out and took measurements. Since there are no established limits for incidental radiators, they simply used the 15.209 limits as an example. They didn't change the classification to intentional radiator.
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AE5GT
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Posts: 398




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« Reply #28 on: September 12, 2018, 08:47:12 PM »

And  was just a subtle reference anyway .  Grin
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K3SGB
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Posts: 31




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« Reply #29 on: September 13, 2018, 07:52:45 AM »

It looks like Leviton has no interest in answering my questions.  I have been told three times that I would receive a call back or maybe an email from the head of their technical dept, but so far.... nothing.  Also, I was told that they have not published any papers on the topic of RFI/EMI output from their dimmers.  So I have ordered a couple of the dimmers and I'll just have to hope for the best.  Thanks for all the help and advice here.  If I come to any conclusions once these devices are installed, I'll report back.

73 - K3SGB
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