Dieter

The simple answer to your question “isn’t FCC indirectly stating that immunity 
has to be met as well?  FCC Part 15.5 (b), is no.  While the FCC says that the 
manufacturer should consider methods to avoid interference, the impetus on 
15.5b only deals with interference to licensed users of the spectrum and not 
with any immunity issues not directly related to the protection of the 
spectrum. 

 

​​​​​

Dennis Ward

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From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Friday, September 30, 2016 5:59 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

 

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately. 

 

Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.

 

And finally, isn’t FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)

§15.5   General conditions of operation.

(a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.

(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.

(c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.

(d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.

 

Sincerely, 

 

Dieter Paasche

 

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