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Re: [RFI] Update: LG washer WT1501CW - EMI

To: Kim Elmore <cw_de_n5op@sbcglobal.net>, "rfi@contesting.com" <rfi@contesting.com>
Subject: Re: [RFI] Update: LG washer WT1501CW - EMI
From: "Hare, Ed W1RFI" <w1rfi@arrl.org>
Date: Tue, 20 Nov 2018 21:03:25 +0000
List-post: <mailto:rfi@contesting.com>
Now, I am looking at the rules for categorical exemptions, and not every device 
that is an "industrial plant" would be categorically exempt.

"A digital device used exclusively as an electronic control or power system 
utilized by a public utility or in an industrial plant."

Now, just what constitutes and "electronic control or power system" would be up 
to the FCC, and I suspect it would interpret it loosely. Does a pulse-wide 
motor controller constitute and "electronic control?"  Would it be considered 
to be a "power system," providing power to a motor? Probably.  To really get 
the interpretation would probably necessitate looking at the Report and Order 
and related releases that were issued by the FCC when the rule was implemented.

It could also be that the noise is being generated by an incidental emitter, 
also categorically exempt.

In most cases, hams are better off addressing interference on the basis of 
"harmful interference," because if we try too hard to pin it on emissions 
violations, we may end up in a situation where devices that meet the limits are 
presumed to not interfere, or, worse, we have to demonstrate that devices do 
not meet the limits, impractical in most cases.

Ed



-----Original Message-----
From: RFI <rfi-bounces@contesting.com> On Behalf Of Kim Elmore
Sent: Tuesday, November 20, 2018 3:42 PM
To: rfi@contesting.com
Subject: Re: [RFI] Update: LG washer WT1501CW - EMI

Yes. Consider an industrial plant near an airport that wipes out the ILS system 
or inhibits ATC or law enforcement comms. The section of Part 15 that says no 
harmful interference will most certainly come into play as the affected users 
are licensed operations. The exemption lies in the radiated field strength 
(they're neither Class B or Class A devices that have field strength limits) 
but they still may not cause interference to licensed operations.

Kim N5OP


On 11/20/2018 12:07 PM, Lee STRAHAN wrote:
>    So industrial plants are also exempt from the part 15 requirements but 
> does this also mean that they still cannot cause harmful interference?
>
> Lee   K7TJR   OR
>
> The FCC has not generally tried to interpret things as appliances that are 
> not. The devices are still subject to the requirement that the operator of 
> the device not cause harmful interference.
>
> Ed, W1RFI
>
>
> _______________________________________________
> RFI mailing list
> RFI@contesting.com
> http://lists.contesting.com/mailman/listinfo/rfi
>

-- 

Kim Elmore, Ph.D. (Adj. Assoc. Prof., OU School of Meteorology, CCM, PP 
SEL/MEL/Glider, N5OP, 2nd Class Radiotelegraph, GROL)

/"In theory there is no difference between theory and practice. But, in 
practice, there is." //– Attributed to many people; it’s so true that it 
doesn’t matter who said it./

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