[RFI] Formal RFI complaint to the FCC

Hare,Ed, W1RFI w1rfi at arrl.org
Tue Nov 4 22:03:57 EST 2003

The TV won't be in the database. As an unintentional emitter and not a computer or computer peripheral, it is subject only to the verification requirements in Part 15. This means only that the manufacturer is required to test it.

As a "harmful interference" complaint, the FCC probably won't have a lot of sympathy.  A ham that owns a Part 15 device that interferes with his or her own station is able to control the use of the Part 15 device.

In all likelihood, it meets Part 15.  It internally uses signals >9 kHz, so it must meet the conducted emissions limits below 30 MHz. There are no limits on its radiated emissions limits below 30 MHz; it must meet radiated limits above 30 MHz.  The conducted emissions limits are 250 uV, quasi-peak, measured in 9 kHz bandwidth.  This is a power level of -59 dBm.  Let's run a few assumptions:

"Transmit" power level: -59 dBm
Power-wiring antenna gain: -20 dBi 
Path loss on 7 MHz, for 10 meters distance:  9.4 dB
Amateur receive antenna gain: 6 dBi (dipole, over ground)
Recieved signal level = -59 -20 -9.4 + 6 = -82.4 dBm

S9 would be 50 uV across 50 ohms, so the signal to be expected under the above circumstances would be about S7-S8.

If the antenna were located farther away, a "legal" device may produce about an S6 level. If the power wiring were a better antenna, quite reasonable, then you may be able to add as much as 15 dB.  Translation:  legal Part 15 emitters could result in S6 to S9 noise under typical conditions. 

Ed Hare, W1RFI
225 Main St
Newington, CT 06111
Tel: 860-594-0318
Internet: w1rfi at arrl.org
Web: http://www.arrl.org/tis

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> -----Original Message-----
> From: Cortland Richmond [mailto:ka5s at earthlink.net]
> Sent: Monday, November 03, 2003 5:35 PM
> To: rfi at contesting.com; Van Fair
> Subject: RE: [RFI] Formal RFI complaint to the FCC
> Van,
> Its Part 15, actually. 
> What model is it? Copies of the data may be searchable on the 
> FCC's Web
> site at http://www.fcc.gov/oet/fccid/ under its FCC ID number.
> For Amateur Radio related complaints, see 
> http://www.fcc.gov/eb/AmaCmpl.html
> (excerpt)
> -----------------------------------------------------
> Amateur radio complaints should be as specific as possible, 
> citing dates,
> times, and frequencies on which alleged violations occurred. 
> Complaints
> should also include a name and telephone number where the 
> complainant can
> be reached for further details, if necessary. Complaints 
> should be sent via
> e-mail to fccham at fcc.gov  <mailto:fccham at fcc.gov>or by mail 
> to the address
> below. Parties are encouraged to send tape recordings in 
> support of their
> complaints. Recordings should be mailed to: Federal Communications
> Commission, Enforcement Bureau, Amateur Radio, 1270 Fairfield Road,
> Gettysburg, PA 17325. Parties desiring further information 
> may call: (717)
> 338-2502. 
> -----------------------------------------------------
> That will end up on the desk of Riley Hollingsworth, who has 
> a LOT on his
> desk, so be concise. You should be prepared to provide copies of your
> correspondence with uncooperative vendors and manufacturers. 
> Aside from that, you might contact a consumer advocate in 
> your state to
> determine if there is a legally enforceable recourse against 
> the seller
> under its implied warranty laws. I'm not a lawyer, so I am 
> not the one to
> say, but most states have laws holding the seller liable for 
> items which
> cannot be used for the purpose sold, and compliance with Part 
> 15 on YOUR
> part (or *anyone's* who has one) would seem to require 
> turning it off. Does
> it "get" WWV?  
> Riley _might_ want you to hang onto it until the FCC can check the
> interference generated. 
> Cortland
> > [Original Message]
> > From: Van Fair <vfair at innova.net>
> > I have a sony 40 " tv which transmits a strong signal on 14 
> to 15 MHZ. =
> > There is no way to filter it out. I can pick it up on a 
> battery operted =
> > rcvr. 200 plus feet away at S7 or more.  On my pro 11 it is 
> s9+ when the =
> > beam is pointed at my TV.=20
> > 
> > Sony refuses to do anything or give me a copy of the test 
> conducted on =
> > my model set. Can anyone tell me the procedure for filing a formal =
> > complaint with the FCC for violation of the Part 19 
> regulations.  Thanks =
> > Van
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