You mean Part 15?
Did I really say Part 95? And of all the CFR sections, it was 95? Sheesh
and I can't use lack of coffee as an excuse! Specifially, I meant Sec.
15.103(d) for starters...
You'd be right except...
Part 15 is ineffectual because its limits are too high to preclude harmful
interference below 30MHz (and some above), especially since interference
now is much different than 50 or 60 years ago.
Given the current legislative climate, however, asking for change would
probably result in revoking Part 15 and throwing every complaint into the
civil courts.
Except that the FCC and the federal courts still have exclusive jurisdiction
over all EM matters in the U.S. In addition to the League, organizations
like the NAB and SBE (to protect AMBC listenership) have been engaged in
these discussions. I've not kept up on any related FCC petitions, but I'm
not aware of any Petitions for Rulemaking (PRM) that affect 15.103. If
there is/are, I would like a cite. The FCC can invoke a PRM on their own
motion -- but it will never happen. That's why it will take you, me, and a
damn financially strong lobbying effort to get any traction. This is
probbaly a more important issue to us than spectrum protection -- or at
least equally so.
I could see existing devices being grandfathered in. There's just no way of
going back an enforcing a rule change on existing appliances. But there's
no reason why EMC compliance cannot be invoked on new product to some of the
same standards used in the EU. I'm not an expert in EU EMC compliance, but
I'm lead to believe there's no such 15.103(d) type of exemption there.
Paul, W9AC
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