[RFI] Part 15 isn't enough..

Cortland Richmond ka5s at earthlink.net
Wed Sep 28 22:32:16 EDT 2016


On 9/28/2016 3:40 PM, charlie at thegallos.com wrote:
>   Gives them an objective system of numbers to
> work with

There's no need to add irrelevant regulations. First, the FCC has 
already SAID part 15 isn't enough, addressing "Parties responsible for 
equipment compliance":

§ 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the 
limits specified in this part will not prevent harmful interference 
under all circumstances.  Since the operators of part 15 devices are 
required to cease operation should harmful interference occur to 
authorized users of the radio frequency spectrum, the parties 
responsible for equipment compliance are encouraged to employ the 
minimum field strength necessary for communications, to provide greater 
attenuation of unwanted emissions than required by these regulations, 
and to advise the user as to how to resolve
harmful interference problems (for example, see §15.105(b)).

§ 15.17 Susceptibility to interference.
(a) Parties responsible for equipment compliance are advised to consider 
the proximity and the high power of non-Government licensed radio 
stations, such as broadcast, amateur, land mobile, and non-geostationary 
mobile satellite feeder link earth stations, and of U.S.
Government radio stations, which could include high-powered radar 
systems, when choosing operating frequencies during the design of their 
equipment so as to reduce the susceptibility for receiving harmful 
interference.

Second, there's no reason not to include in the purchase contract that 
the MANUFACTURER (as the Party responsible) warrants his equipment 
against causing harmful interference to radio or radio-frequency 
interference in accordance with FCC Part 15, section 15.105 (c). above

That means they have to 1) comply with the limits and 2) remedy the 
overage if it does occur, and add that to their product warranty in the 
customer instructions.

If you want to be really strict, you can require he also warrant the 
product against being interfered with per 15.17.


Cortland Richmond
KA5S












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