Cortland

Given the legal and philosophical  "issues" in the USA, that sounds as if it 
MIGHT work - my latest take on this subject, as "discussed" today from both 
sides, is that suppliers and users of intentional emitters should not be 
immune(!) from legal action if they continue to cause interference to 
non-intentional emitters and their use by entirely "innocent" people going 
about their legal daily business and activities at work and at home. Again, 
what is good for the goose (intentional emitter suppliers/users) is good for 
the gander (the rest of the public).

Not a particularly "good" solution IMHO - but maybe the best you collectively 
can hope for at present, given the apparently "entrenched" position of many 
people in the US who oppose any concept of immunity/susceptibility testing for 
general public-use products :-(.

Unfortunately that approach still does not address the, probably widespread, 
issue of one non-intentional product interfering with another one - which, I 
would suggest, is probably the more widespread problem for many of the public 
but they don't know what the issues are or how to fix them. 

For example, in my own case, my first digital sat receiver (around 1998) 
suffered interference from other components in my AV system (and this was a 
quite widely reported problem as I recall), until, with some relevant 
background knowledge to help, I replaced all the old single screened RF 
connections with decent double screened sat-spec cable - most people would not 
know why/how to do that. However, since then, I (and presumably many other 
consumers!) have never suffered the same issues  as the newer receivers are far 
more resilient to external interference because the manufacturers have been 
compelled to comply with the EU immunity requirements!

John E Allen
W. London, UK





-----Original Message-----
From: Cortland Richmond [mailto:k...@earthlink.net] 
Sent: 30 September 2016 21:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

On 9/30/2016 2:16 PM, Ken Javor wrote:
> I still don't understand what the applicability is, but if that 
> statement about MIL-STD-461 applies to products to be sold 
> commercially, it has serious issues and drawbacks that make it utterly 
> impractical.

I suspect the choice of MIL-Standards was made to reduce emissions more than 
FCC rules require and thus increase the margin available to prevent 
interference in the marketplace.

The problem with lower numerical limits is, however, that either they become 
prohibitively expensive to manufacture, or they will be adopted pro forma and 
ignored in practice – which is often what manufacturers do already facing FCC 
limits.  It does not help to require compliance with standards never meant to 
apply to consumer devices.



A reasonable default limitation – Part 15 – can put a ceiling on the number of 
interference complaints, and a predictably expensive penalty for actually 
causing interference could ensure that manufacturers actually complied with 
those limits, thus my suggestion to require a manufacturer warranty covering 
the costs of remediation should interference occur.  I think that might be 
enough; if coupled with a warranty against susceptibility to nearby 
transmitters, it could substantially reduce the number of complaints from that 
side as well.

Cortland Richmond
KA5S

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