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Re: [RFI] BPL reply comments

To: "Richard Karlquist" <richard@karlquist.com>, <kilo.mike@gte.net>, "RFI Reflector" <rfi@contesting.com>
Subject: Re: [RFI] BPL reply comments
From: "Michael Tope" <W4EF@dellroy.com>
Date: Sat, 23 Aug 2003 09:32:17 -0700
List-post: <mailto:rfi@contesting.com>
I am not an expert on part 15 regulations, Rick, but it is
clearly stated in the text of the regulations that meeting
the absolute emission limits is not sufficient for compliance
if the device still causes "harmful interference". This does
leave a little wiggle room for the commission, because
the term "harmful interference" is somewhat subjective.

This is what part 15 says:

47 C.F.R. §15.15(c) "Parties responsible for equipment
compliance should note that the limits specified in this
Part will not prevent harmful interference under all
circumstances. Since the operators of Part 15 devices
are required to cease operation should harmful interference
occur to authorized users of the radio frequency
spectrum, the parties responsible for equipment
compliance are encouraged to employ the minimum
field strength necessary for communications, to provide
greater attenuation of unwanted emissions than required by
these regulations, and to advise the user as to how
to resolve harmful interference problems."

And the definition of "harmful interference" found in
part 15:

"Harmful interference. Any emission, radiation or
induction that endangers the functioning of a radio
navigation service or of other safety services or
seriously degrades, obstructs or repeatedly
interrupts a radiocommunications service operating
in accordance with this Chapter."

In any case, you interpretation is correct. The utility
can't hide behind absolute emission limits. On the
other hand, the commission seems to have some
discretion as to what level of interference is
considered harmful. The best thing to do would
be to ask Ed Hare or Mike Gruber at ARRL
as the have lots of experience working with the
FCC on these sorts of problems.

73 de Mike, W4EF.........................

----- Original Message -----
From: "Richard Karlquist" <richard@karlquist.com>
To: "Michael Tope" <W4EF@dellroy.com>; <kilo.mike@gte.net>; "RFI Reflector"
Sent: Saturday, August 23, 2003 7:24 AM
Subject: RE: [RFI] BPL reply comments

> > Chris, et al, please check out my reply to Current Technologies
> > original comments (much of their reply comments reiterate the
> > b&llsh%t in their original comments). I did my best to counter
> > their brazen hubris.
> 73 de Mike, W4EF......................................................
> I just wanted to confirm something you said
> in your FCC comments about part 15 limits.
> This is in regard to some streetlight
> interference I have been having.  If I understand
> it correctly, the power company cannot use as a
> defense the fact that the streetlight is FCC type
> accepted for part 15, not the fact that the streetlight
> actually meets part 15 (although I doubt either is
> true).  Is that right?  Also, if the streetlight is
> "exempt" from part 15 type acceptance, that is also
> not an excuse for them to fix the interference.  Right?
> There is no level of interference I just have to
> live with, as you say.
> BTW, the interference is so bad on 1140 kHz that
> it puts a buzz on a 50 kW AM broadcast station
> only 6 miles away (and I am not in a pattern null).
> Rick N6RK

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