Hi Tania, Dan, and Group,

Your quote brought up a nagging little question I had last time I was
reading through part 15 in this section (I was looking for requirements
relating to test equipment manufacturers...there are none) regarding the
reference to section 15.5.  Where is it or where did it go?  My version of
the CFR doesn't contain a 15.5, as it stops at section 15.407 in section E.
Does anyone know if this is a typo or to what it refers?
Thanks,
Dave Spencer
Oresis Communications

-----Original Message-----
From: Grant, Tania (Tania) [mailto:tgr...@lucent.com]
Sent: Wednesday, November 01, 2000 1:56 PM
To: 'Dan Kinney (A)'; emc-p...@ieee.org
Subject: RE: FCC Part 15 exempted devices
Importance: High



Dan,

(For lack of a comma, they hung a guy.)   I actually checked to be sure that
there is no comma in paragraph (b), since you could have inadvertently
omitted it.   There is no comma.   Therefore......

... your paragraphs b) and c) apply; however, I don't agree with your use of
"only" at the end of your paragraph b).    

Thus, digital electronic control devices and power systems used exclusively
by a public utility, or the same devices and power systems used exclusively
in an industrial plant are exempt from Rules Part 15, except for the general
conditions of operation in 15.5 and 15.29.  (Thou shalt not emit; and if
thou emits, thou will provide units for FCC inspection, and thou will cease
operation.)


Thus, thou is exempt up to a point.

Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions


-----Original Message-----
From: Dan Kinney (A) [ mailto:dan.kin...@heapg.com
<mailto:dan.kin...@heapg.com> ]
Sent: Wednesday, November 01, 2000 12:41 PM
To: emc-p...@ieee.org
Subject: FCC Part 15 exempted devices



I need help with interpretation of one paragraph in FCC Part 15.  I have the
1 Oct 97 version.  Paragraph 15.103 (b) says a digital device is exempted
from Part 15 if it is "used exclusively as an electronic control or power
system utilized by a public utility or in an industrial plant."  One could
interpret this several ways to include:

A digital device is exempted if it is used exclusively as:
1) an electronic control
2) an electronic control utilized by a public utility only
3) an electronic control utilized in an industrial plant

The first interpretation is pretty broad and would exclude a lot of
equipment.  The third interpretation is broad but causes the manufacturer of
control equipment to somehow make certain his products do not end up in use
anywhere except in an industrial plant.  The second interpretation is narrow
and might be the real intent of this exemption.

I would appreciate any advice on how any of you would interpret this.
Thanks in advance.
Dan Kinney
Horner APG



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