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Re: [RFI] Comments on RFI from Ductless Air Conditioning Units?

To: rfi@contesting.com
Subject: Re: [RFI] Comments on RFI from Ductless Air Conditioning Units?
From: Jeff Stevens <jeff@mossycup.com>
Date: Mon, 13 May 2013 13:21:06 -0400
List-post: <rfi@contesting.com">mailto:rfi@contesting.com>
I've been looking into the apparent exemption of AC equipment from
certain parts of Part 15.  It seems very specific and doesn't apply to
AC equipment per se, but the digital circuitry contained within the AC
unit which is responsible for its basic function.  I'm not sure an
inverter / PWM circuitry would fall within this exemption, but IDK.

Part 15.103 reads in part "The following devices are subject only to
the general conditions of operation in §§ 15.5 and 15.29 and are
exempt from the specific technical standards and other requirements
contained in this part."

One of the exemptions in this part reads "(d) A digital device
utilized exclusively in an appliance, e.g., microwave oven,
dishwasher, clothes dryer, air conditioner (central or window), etc."

It is the DIGITAL DEVICE within the AC unit -- not the other parts of
the unit -- which are exempt from certain part 15 requirements.

This document provides further clarification on the exemption:
https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=33062&switch=P

In part, it reads: "To be exempt under Section 15.103, only the
digital circuitry directly responsible for operation of the basic
functions associated with the appliance is exempt, and must be
contained within the major appliance and not remotely connected via
wire, cable or other communication system. "

It seems to me the exemption is referring to digital control logic --
not an AC/DC inverter and PWM circuitry used to power a compressor,
but IDK.  Additionally, the exemption doesn't appear absolute.  Such
digital circuitry inside an AC unit is still subject to "the general
conditions of operation" in 15.5 and 15.29 -- just not the "specific
technical standards".  While I've read through Part 15, it's not clear
to me what the real world implication of this limited exemption is.

-Jeff
W7WWA
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