Bravo, Paul. We should all be writing our Directors asking for attention
and action on this issue. In the meantime, it would be very interesting to
know whether a good filter (common plus differential mode) on the line cord
is generally sufficient to manage this, and if specific manufacturers have
been more or less responsive in dealing with it. That's the sort of thing
that ARRL HQ staff could be working on while we wait for the new FCC
leadership to sort itself out.
73, Pete N4ZRE
At 03:11 AM 12/16/2008, Paul Christensen wrote:
>I posted this reply on QRP-L this morning. I thought it would be equally
>relevant here on this list.:
> > When I complained to the FCC about the RFI from my Kenmore High
> > Efficiency washer and dryer (see my post from a few months ago) they
> > responded by explaining that since I am the operator of the appliances
> > I am the source of the interference and could not (read that would
> > not) help me.
>It's a tough pill to swallow, but pursuant to current Part 15 Rules, the
>Commission was correct by their (in)action in your case. Section 15.103(d)
>states that such washing appliances are subject only to the general
>provisions of Section 15.5 and 15.29, and are further "exempt from the
>specific technical standards and other requirements contained in Part 15."
>The operator of an exempted device shall be required to stop operating the
>device upon a finding by the Commission or its representative that the
>device is causing harmful interference. Operation shall not resume until the
>condition causing the harmful interference has been corrected.
>You are the owner of the washer. You must stop operating the washer if it
>is causing harmful interference.
>The real issue here is that Part 15 has not kept pace with the realities of
>modern appliances. The new wave of washing systems with direct-drive motors
>generate enormous amounts of RFI.
>In our home, nearly every major appliance runs from some form of digital
>controlling device and/or switch-mode power supply. And yet, Part 15 is
>telling us that the manufacturers of common appliances are given special
>dispensation from having to comply with technical standards set forth in
>other sections of Part 15. Ironically, the switch-mode power supply that
>provides powering to the appliances may be non-exempt if sold and used on
>its own. But subject only to vague interpretation under Sec. 15.103(i), the
>device is protected through exemption under the shield of the "appliance."
>Then to add insult to injury, the preamble of 15.103 goes on state "Although
>not mandatory, it is strongly recommended that the manufacturer of an
>exempted device endeavor to have the device meet the specific technical
>standards in this part." Well forgive me, but if the issue is important
>enough for the Commission to make a "strong recommendation," then it seems
>to me the issue should rise to a level of importance in which the
>manufacturers should be compelled to conform to the technical standards of
>BPL is important, but in terms of priority as to what is adversely impacting
>the population of amateur operators today, it is clearly the growing
>bombardment of trash coming from Part 15-exempt and non-exempt devices.
>Our spectrum protection activism should be focused on an overhaul of Part 15
>rules, and should not be limited to BPL activities. But reform in this area
>does not occur when we call the FCC to file a complaint. Reform requires a
>grass-roots effort, led in part by a strong organization like the ARRL.
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