Hi  Ghery,

You need to get your numbers right.... Those tree entities outnumber your "real 
world" by 7.
Economically by a factor 2...
 


Regards,

Ing. Gert Gremmen
Approvals manager
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From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: Friday 30 September 2016 00:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Immunity testing is required in the EU, South Korea and China.  Nowhere else in 
the world is it required for commercial products.  I’d say that the US is in 
the “real world”.

Ghery S. Pettit

From: Ken Javor [mailto:ken.ja...@emccompliance.com] 
Sent: Thursday, September 29, 2016 3:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Without getting into the specifics of this particular argument, the idea that 
the “rest of the world” has dome something doesn’t necessarily imply that North 
America is “behind.”  In the same sense that if a train has derailed and the 
locomotive is headed over a cliff, we don’t say the caboose is behind and needs 
to catch up.

Ken Javor
Phone: (256) 650-5261
________________________________________
From: john Allen <john_e_al...@blueyonder.co.uk>
Reply-To: john Allen <john_e_al...@blueyonder.co.uk>
Date: Thu, 29 Sep 2016 22:44:48 +0100
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dennis
 
I really  do wonder what World you live in – but then, TBH, based on your 
previous comments of a similar nature, I did not expect anything else!
 
OK, Government “interference” is unwelcome in many cases but Brian O’Connell’s 
post is a  poignant “real world”  comment on what suppliers are facing, and 
what the Government should face up to and address – for the greater good of 
everyone in YOUR country.
 
Without getting trying to “personal”,  “get real”! - a lot of the rest of the 
“real world” has already adopted appropriate requirements to try to prevent 
undue interference problems and so N. America is behind on this issue.
 
John E Allen.
W. London, UK
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 22:28
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

The federal government already interferes with US citizens far too much as it 
is – we do not need, nor do most of us want more federal intrusion.  The feds 
are there to keep the wolves at bay and keep out of our lives.  Besides, the 
open market in the US seems to take care of itself in the interference area.  
Does not take long for the consumer to know what is trash and what works.
The only regulations dealing with the spectrum that is needed is the regulation 
to help stop interference to licensed services. That was the intent of the FCC 
to start and there is no reason to change it.
 
 

​​​​​
Dennis Ward
This communication and its attachements contain information from PCTEST 
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From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 2:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Dennis
 
And why not – seriously?
 
As was said many years ago – and often repeated! - “what’s right for the goose 
is right for the gander”.
 
In this case (and many others) In simple terms, that means that implies that 
electronic devices need to be appropriately resilient to the generally 
“predictable” levels of external interference in the environments for which 
they are designed to operate – one of the basic essential requirements of the 
EMC Directive!
 
Otherwise you might need to specify that YOUR products need to have MIL-STD-461 
levels (highest!) of immunity to try to ensure they will work “anywhere” they 
are likely to be used!
 
John E Allen
W. London, UK
 
 

From: dward [mailto:dw...@pctestlab.com] 
Sent: 29 September 2016 21:53
To: 'john Allen'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

Not a chance
 

​​​​​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended for the exclusive use of the 
recipient(s) named above.  It may contain information that is confidential 
and/or legally privileged.  Any unauthorized use that may compromise that 
confidentiality via distribution or disclosure is prohibited.  Please notify 
the sender immediately if you receive this communication in error, and delete 
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related activities is strictly prohibited.  No warranty is made that the e-mail 
or attachments(s) are free from computer virus or other defect.  Thank you.
 

From: john Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Thursday, September 29, 2016 1:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Almost sounds like a call for N. America to encompass our equivalent immunity 
requirements  (often denigrated - even with Europe, but they generally do seem 
to work!) ☺ 
 
John E Allen
W. London, UK
 
-----Original Message-----
From: Ghery S. Pettit [mailto:n6...@comcast.net] 
Sent: 29 September 2016 21:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Preventing harmful interference in all cases is a mighty tough call.  How low 
do you need to limit emissions?  How high a signal must the product be immune 
to?  The limits in Part 15 provide a reasonable level of protection, assuming 
the potential victim is far enough away.  Co-located devices may need more 
suppression.
 
Ghery S. Pettit, NCE
 
-----Original Message-----
From: Cortland Richmond [mailto:k...@earthlink.net <mailto:k...@earthlink.net> ]
Sent: Thursday, September 29, 2016 12:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
On 9/29/2016 2:07 PM, Ken Javor wrote:
> I missed out on the prologue and am curious as why Part 15 limits 
> aren't low enough. Not low enough for what?
 
Actually preventing harmful interference.  Requiring a warranty in the purchase 
contract would put manufacturers on notice that they're actually expected to do 
that -- and eat the cost of fixing things if they don't.
 
§ 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical
(ISM) equipment, or by an incidental radiator.
 
§ 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)).
 
[and (maybe -- good luck)]
 
§ 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. ...
 
 
Cortland
 
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