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Re: [RFI] Appliance interference and approvals (was Sears batterycharger

To: RFI@contesting.com
Subject: Re: [RFI] Appliance interference and approvals (was Sears batterycharger model #200.71222)
From: "Cortland Richmond" <ka5s@earthlink.net>
Reply-to: ka5s@earthlink.net
Date: Sat, 10 Apr 2010 22:43:10 -0400
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
I don't think so. The manufacturers claim (rightly) that the FCC exempts
them from certification and verification and in fact this means there are
no FCC requirements they must meet before sale .  They can thereafter
disclaim responsibility because it is the *owners' and operators'* duty to
turn off the interfering equipment. THEY don't even have to act unless
informed >by the Commission< that it is interfering.

However... even if I mistook omission for permission, it would indeed take
a Rulemaking -- a contentious one -- to fix things.  (Or the Courts.) Only
the FCC regulates interference, and Congress has been relucant to see it
enforce existing Rules, let alone make them more stringent.   


> [Original Message]
> From: Paul Christensen <w9ac@arrl.net>
> To: <RFI@contesting.com>
> Date: 4/10/2010 9:56:50 PM
> Subject: Re: [RFI] Appliance interference and approvals (was Sears
batterycharger model #200.71222)
> > "There are no FCC *emission requirements* for equipment used in 
> > appliances."
> You're confusing emissions with the certification requirement.  Under
> 15.103(d), appliances are exempt from the certification requirement. 
> Appliances are not exempt from the generation of harmful emissions as an 
> unintentional radiator.  Generally, if an appliance is causing harmful 
> interference to the user of a licensed service, the fact that the 
> manufacturer was not compelled to certify the appliance in no way grants 
> special dispensation to the device's owner if that device produces
> interference.  When put on notice, the owner of the device must still 
> protect a licensed service and cease device operations until the 
> interference is cured.
> I have been advocating a change to this rule for the past several years. 
> Frankly, the time is ripe for a Petition for Rulemaking.  I'm just not
> if the ARRL wants to take that on at the moment and the petition really 
> needs a strong sponsor like the League for what it will definitely face. 
> There will be significant opposition from appliance manufacturers and 
> manufacturers of appliance sub-components like those that manufacture 
> direct-drive, variable-speed motors and switch-mode power supplies.  An 
> oddity of the current rules implies, for example, that a SMPS that may 
> require Part 15(B - residential) certification as a stand-alone device
> is protected from the certification requirement when it's embedded into
> appliance.
> What clearly does not make sense is the continuation down the current
> where the FCC's enforcement branch must become engaged in conflict 
> resolution between a licensee and the owner of the
> appliance.  With certification of appliances that contain any switch-mode 
> technology or microprocessors, the FCC's enforcement job potentially gets
> whole lot easier and that, among other key points, would become pivotal
in a 
> Petition for Rulemaking.
> Paul, W9AC 
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