Omission of Class B statement in users manual costs…

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The Federal Communications Commission( FCC) issued a Notice of Apparent Liability for Forfeiture (NAL) to Marshall Amplification PLC, seeking $7500 for what the FCC claims is “willful and repeated” violation of section 302(b) of the Communications Act and sections 2.803(a)(2) and 15.105(b) of the
Commission’s rules.

The notice follows a complaint received by the FCC that Marshall had not included the proper consumer disclosure in the users manual of some Class B digital devices being sold by Marshall. It is noted in the NAL that the products were verified for compliance with the Class B limits and the technical requirements had been met, thus the base forfeiture amount was adjusted down as a result, however, the forfeiture amount was adjusted  back up based on Marshall’s ability to pay, stating “large or highly profitable entities, such as Marshall should expect forfeitures higher than those reflected in the base amounts”

In general most consumers are unfamiliar with the requirements and rules of the FCC, and it can be assumed that a large amount of complaints received by the FCC are filed by industry competitors, excluding those cases that deal with actual radio interference.

The consumer disclosure in question is intended to inform the user of the potential for interference and what to do should it occur, and is required for all class B digital devices.

“ This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to part 15 of the FCC Rules.  These limits are designed to provide reasonable protection against harmful interference in a residential installation.  This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications.  However, there is no guarantee that interference will not occur in a particular installation.  If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:

• Reorient or relocate the receiving antenna.
• Increase the separation between the equipment and receiver.
• Connect the equipment into an outlet on a circuit different from that to which the receiver is connected.
• Consult the dealer or an experienced radio/TV technician for help. “

A NAL is not a forfeiture order, it usually follows a Letter of Inquiry, and the recipient of one can still seek dismissal and/or reduction in the amount. The process ends in one of three ways, an actual forfeiture order, a consent decree, or criminal prosecution, with the latter being rare.

While, with regard to this particular incident, the cost of this omission may be $7500, and some may consider this as simply the cost of doing business, it should be noted that the fines can be much higher for willful and repeated violations, and could be cumulative based on each product sold and compounded for each day the violation occurs.

The complete NAL can be found at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0830/DA-11-1468A1.pdf

EMC Society’s John Howard Memorial University Grant

The call for proposals to the IEEE EMC Society’s University grant program has been announced.

The program is designed to assist in adding EMC fundamentals to the curriculum of a qualified University or College. The award is $5000, intended as seed money for the establishment of the program.

Details can be found at http://www.emcs.org/committees/education/univ_grant/index.html

The Call for Proposals can be found at http://www.emcs.org/committees/education/univ_grant/UGC_Call_2011.pdf

By: J Klinger

Draft FCC publication for SAR listing on grants

New guidelines have been published by the FCC for the uniform listing of Specific Absorption Rate (SAR) numbers on the grant of equipment authorization.

This is of primary interest to Telecommunication Certification Bodies (TCBs), those being responsible for the actual grant of equipment authorization.

Last date to post comment: 9/16/2011, post comment at https://apps.fcc.gov/eas/comments/PostComment.do?id=197&tn=359396

See “SAR Listings on Equipment Authorization Grants”

By: J Klinger

FCC publishes new draft testing guidelines for U-NII devices

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Public comment is now open, until September 23, 2011, on the FCC guidelines for testing Unlicensed National Information Infrastructure (U-NII) devices, in accordance with CFR 47 Part 15, Subpart E.

In addition to the measurement standards called out in section 15.31, and ANSI C63.10, these guidelines will form the general test procedures for testing all U-NII devices for compliance with the technical requirements of section 15.407.

The U-NII radio band is an unlicensed band divided into three spectrum segments in the 5GHz range, 5.15–5.35 GHz, 5.47–5.725 GHz and 5.725–5.825 GHz. U-NII devices use wideband digital modulation techniques, and provide a wide array of high data rate mobile and fixed communications for individuals, businesses, and institutions. Examples are 802.11a devices.

Dynamic Frequency Selection (DFS) functions, which are required between 5.25 – 5.35 GHz and between 5.47 – 5.725 GHz for the protection of government radar systems, are covered in a separate document. See FCC Order, ET Docket No.03-122 (FCC 06-96).

For devices that transmit on multiple outputs simultaneously such as MIMO and beam forming technologies, FCC KDB Publication Number 662911 also applies.

The new guidance replaces Public Notice DA 02-2138 of 8/30/02 and contains the following changes;

• The document interprets and clarifies the language of 15.407(a)(4) (maximum conducted output power)
• Revises the spectrum analyzer-based methodologies for measuring maximum conducted power and provides an option to use an RF power meter
• Revises the methodologies for measuring Peak Power Spectral Density (PPSD) to match those used to measure maximum conducted output power
• Specifies the use of max hold when measuring Emission Bandwidth (EBW)
• Defines compliance with 15.407(a)(6) (peak excursion) in terms of the ratio of maximum of the peak-hold spectrum to the maximum of the average spectrum—eliminating the need to compute the ratio at each frequency (a process that had resulted in unintended failures near band edges)
• Adds guidance for measuring unwanted emissions.  The guidance interprets the non-restricted band limit as a peak limit and restricted band limits as including both average and peak limits.  Both restricted and non-restricted band limits are based on continuous transmission with no subsequent reduction for operational duty cycle.  The guidelines permit both restricted and non-restricted band compliance be demonstrated by radiated measurements or by antenna-port conducted measurements combined with radiated cabinet emission measurements.

By: J Klinger

IEEE EMC Society 2011

The 2011 IEEE EMC society symposium is underway in Long Beach, California. Be sure to drop by Compatible Electronics' booth #531.


By: J Klinger

$22,000 for operating an unlicensed radio station

A Florida resident has been issued a monetary forfeiture order for $22,000 by the FCC, for operating an unlicensed radio station out of her home and refusing to allow it’s inspection by field officers.
Read the monetary forfeiture at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-11-1266A1.pdf

Spectrum Sharing agreements with Canada and Mexico, announced by the FCC

The FCC reached agreements with Canada and Mexico for sharing commercial wireless broadband spectrum in the 700MHz band along the respective boarders, additionally, an arrangement has been made with Canada for sharing spectrum in the 800MHz band.

The goal of these arrangements is to further the deployment of commercial wireless broadband services near the boarder, with an aim to providing consumers additional options for 4G high speed mobile broadband access in these areas.

The arrangements made with respect to the 800MHz band on the northern boarder are inline with the 800MHz rebanding efforts by U.S. public safety and ESMR (Enhanced Specialized Mobile Radio) i.e. Nextel. Specifically the allotment of channels between the US and Canada, technical operational parameters within 87 miles of the boarder, and setting the schedule for transitioning facilities from US channels to complete the rebanding along the U.S.-Canadian border.

Read the FCC Press release at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0801/DOC-308822A1.pdf

By: J Klinger

Microsoft is designated a TV bands database admin, follows Google

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Microsoft Corporation received conditional designation by the FCC as a TV bands database administrator. Microsoft joins Google and 8 others, Comsearch, Frequency Finder Inc., KB Enterprises LLC and LS Telcom, Key Bridge Global LLC, Neustar Inc., Spectrum Bridge Inc., Telcordia Technologies, and WSdb LLC. This brings the list of available administrators to 10 in total. 

The TV bands, or television “white spaces” are the unused portions of the broadcast television spectrum, freed by the transition to digital TV. Availability within the spectrum varies with geographical location; the TV bands database is used as a control and coordination measure for the bands. It is required that devices that would use this unlicensed spectrum would include a geo-location capability and access to the database, containing frequencies off limits for use in that area, enabling devices to communicate without interfering with incumbent users. 

Manufacturers of devices are free to choose which database to use in their devices. Database administrators may charge fees for access to the database. In lieu of geo-location and database access, devices can employ hardware that listens to the band, called spectrum sensing, this requires approval by the FCC first, each application must be placed on public notice, and the FCC will conduct tests to evaluate performance prior to approval, which could result in a far more costly product. 

Each approved database administrator must make their database available for a 5 year term. At this time all administrators are conditional and pending, the FCC will announce when and if any particular administrator is available for public use.

By: J Klinger