I am curious, Ed. Is it correct that BPL is classified by the FCC as an
unintentional emitter? I seem to recall reading somewhere in part 15
that PLC systems are considered unintentional emitters, but it was
never absolutely clear to me that HF BPL systems should receive the
73 de Mike, W4EF.....................................
----- Original Message -----
From: "Hare,Ed, W1RFI" <firstname.lastname@example.org>
To: "Michael Tope" <W4EF@dellroy.com>; "Richard Karlquist"
<email@example.com>; <firstname.lastname@example.org>; "RFI Reflector"
Sent: Monday, August 25, 2003 7:04 AM
Subject: RE: [RFI] BPL reply comments
> Streetlights can be incidental or unintentional emitters.
> Incidental emitters don't deliberately generate RF energy, but just happen
to do so as part of their operation. They have no specific radiated or
conducted emissions limits, subject only to a vague requirement to use good
engineering practice and a stipulation that if they cause harmful
interference, the operator of the device must take whatever steps are
necessary to correct the interference. Examples of incidental emitters are
electric motors or power-line arcs.
> Unintentional emitters do internally generate RF signals, but don't
intentionally radiate it. They have conducted emissions limits below 30 MHz
and radiated emissions limits above 30 MHz, also with the requirement that
they not cause harmful interference. Examples are computer or switch-mode
> Ed Hare, W1RFI
> ARRL Lab
> 225 Main St
> Newington, CT 06111
> Tel: 860-594-0318
> Internet: email@example.com
> Web: http://www.arrl.org/tis
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> > -----Original Message-----
> > From: Michael Tope [mailto:W4EF@dellroy.com]
> > Sent: Saturday, August 23, 2003 12:32 PM
> > To: Richard Karlquist; firstname.lastname@example.org; RFI Reflector
> > Subject: Re: [RFI] BPL reply comments
> > 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" <email@example.com>
> > To: "Michael Tope" <W4EF@dellroy.com>; <firstname.lastname@example.org>;
> > "RFI Reflector"
> > <email@example.com>
> > 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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