5 GHz Wi-Fi Interference, FCC Issues Warning

The FCC Issued a public notice targeted at operators, manufacturers and marketers of wireless transmitters operating in the 5.25 GHz to 5.35 GHz and 5.47 GHz to 5.725 GHz band, commonly referred to as Unlicensed National Information Infrastructure (UNII) devices. The most common consumer/commercial wireless product operating in these bands being 5 GHz Wi-Fi devices.

This FCC enforcement advisory explains what rules apply, what the U-NII operator should do to comply, and what manufacturers and retailers must do to comply. Retailers include both on-line (e.g. Amazon) and brick-and-mortar locations.

The advisory warns of significant penalties, not limited to substantial monetary fines, for operators, manufacturers and retailers for failure to comply with the Title 47, Part 15 rules.

The FCC advisory casts a large net and it squarely places the responsibility for compliance on the shoulders of not only the user and the manufacturer but also, as we are seeing more and more from the FCC, including online retailers of such devices.

Interference from non-compliant devices to Doppler weather radar stations, used by aviation to detect wind shear and other weather-related dangers, is potentially life threatening.

REF: FCC Public Notice DA 19-807

Related:

FCC TAKES ACTION AGAINST COMPANIES THAT INTERFERED WITH FAA WEATHER RADAR IN PUERTO RICO

Electronic Device Retailers FCC Issues Warning

February 15, 2019, the Federal Communication Commission issued an enforcement advisory warning electronic device retailers, yes, those selling devices not just making them, of potential fines if devices are in violation of the applicable FCC authorization requirements. Fines could total more than $150,000 per violation.

This is of significant importance as many retailers and distributors assume that the device manufacturer shoulders the burden for regulatory compliance, and accepts that if a product manufacturer claims compliance then that is all that is required, often retailers and distributors are unaware of the authorization requirements but this advisory opens the door for retailers and distributors to face penalties if the products are not in compliance with the required FCC authorization methods found under part 15 of Title 47 Code of Federal Regulations.

Specifically, this advisory is addressing those products that fall under the "Suppliers Declaration of Conformity" or SDoC authorization rules. A non-exhaustive list of examples of the types of products covered can be found in C.F.R. 47 §15.101(a) and §18.203.

For a basic guide and to understand what the SDoC authorization encompasses, please visit https://celectronics.com/training/learning/authorization/FCC-SDoC-Guide.html

REF:
https://docs.fcc.gov/public/attachments/DA-19-91A1.pdf

FCC Steps up enforcement

FCC fines LED light suppliers for rule violations. Fines range from $15,000 to $61,000.

In an article posted on Digital Signage Today, it’s reported that the FCC is significantly stepping up enforcement of the radio equipment rules. The article quotes Commissioner Michael O'Reilly as stating that the FCC intends to pursue vigorous enforcement and suggests substantially increasing fines on violators.

While the FCC has been relaxing the requirements, oversight and complexities of the authorization methods for products, they still take violations of the rules very seriously. It is reported that the FCC has recently targeted LED light suppliers and found multiple violations of the rules. Violations that range from improper labeling to marketing and selling without first applying proper FCC equipment authorizations.

REF:

Digital Signage Today article
https://www.digitalsignagetoday.com/blogs/how-led-suppliers-can-avoid-trouble-with-the-fcc/

FCC SDoC Authorization guide
https://celectronics.com/training/learning/authorization/FCC-SDoC-Guide.html

FCC will no longer accept applications for equipment certification

The FCC introduced a Report and order just before the new year that among other things, effectively puts them out of the RF device certification business and permits this activity to be performed solely by private Telecommunication Certification Bodies, also known as TCBs,

The big take away is that the FCC will no longer be certifying products, however also included in this report is a new requirement that all testing be done at an “accredited” lab.

A quote from the report and order; 

41. Proposal. In the Notice, the Commission proposed to require that all laboratories that test
equipment subject to Certification or to DoC under any rule part be accredited to ISO/IEC 17025, ending
the “2.948-listing” program for unaccredited labs to test equipment to be certified under Parts 15 and 18
of the rules.

Prior to this order devices subject to certification; such as radio transmitters, could be tested at any listed lab. This listing program is less rigorous and less expensive than full certification. The listing program simply requires that the lab file information with the FCC. In contrast, the accreditation requirement ensures that the the testing laboratory is competent to perform the required work, but it also requires that the laboratory be in a country that is recognized by the FCC, such as one with an established Mutual Recognition Agreement (MRA) with the United States.

Currently, many companies rely on test data suppled by third party test labs that are not accredited or are in countries which do not have an established MRA with the United States. As an example, there are no laboratories in China that are qualified to perform testing for FCC certification or DoC, due to the fact that there is no MRA between China and the United States.

Along with this change the FCC lays out the process for a pre-grant approval procedure to be followed when a TCB is faced with certification of a device based on new technology.

The FCC also makes clear in the report the TCB’s responsibility in performing “post-market” surveillance of products it has certified.

Reference;

http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db1230/FCC-14-208A1.pdf

Crackdown on jammers continue with “NOJAM” and action against sellers on Craigslist

No one I know (Photo credit: Mickipedia)

The FCC has a new weapon in its continued efforts to aggressively enforce the law with respect to the sale and use of illegal radio jammers. The new weapon is a dedicated jammer tip hotline, 1-855-55-NOJAM. The hotline is intended to make it easier for the general public to report offenders.

The Press Release announcing the new hotline encourages the public to call the hotline if;

• you are aware of the ongoing use of a cell, GPS, or other signal jammer;
• your employer operates a jammer in your workplace;
• you observe a jammer in operation at your school or college;
• you observe an advertisement for a jammer at a local store; or
• you observe a jammer being operated on your local bus, train or other mass transit system.

In the Press Release, Michele Ellison, Chief of the Enforcement Bureau, said: “We need consumers to be our eyes and ears. Jammers do not just weed out noisy or annoying conversations and disable unwanted GPS tracking, they can prevent 9-1-1 and other emergency phone calls from getting through in a time of need.”

On the same day of the announcement, the Enforcement Bureau took action against another six individuals for advertising and selling signal jammers on the popular classified ad web site Craigslist.org. The actions come with a warning that the FCC intends to impose “Substantial Monetary Penalties” for similar violations going forward.

So how much will that $45 illegal jammer really cost? The Consumer Alert issued within an FCC Enforcement Advisory  explains penalties can exceed $100,000 per violation.

More about the activities related to jammer enforcement can be found on the Commission web site, http://www.fcc.gov/encyclopedia/jammer-enforcement.

REF:

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DOC-316795A1.pdf

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DOC-316796A1.pdf

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DA-12-1642A1.pdf

FCC cracking down on MVPD operators

Zenith (Photo credit: bcostin)

FCC issues a Public Notice informing non-cable, Multichannel Video Programming Distributors (MVPD), of the rules applicable to all MVPDs, cable provider or not, with regard to notification requirements and cable leakage limits and testing. On the same day, the FCC released several citations the bureau had issued, one to a hotel operator, one to a heath care center, and another to a rehabilitation hospital. All three citations were issued out of the Los Angeles Office, western region, of the FCC enforcement Bureau and all three cover violation of exceeding signal leakage limits in the aeronautical bands.

The notice explains that, like cable system operators, non-cable MVPDs must also notify the FCC prior to the use of any aeronautical frequency bands within their systems. Additionally, non-cable MVPDs must also comply with the same requirements cable operators follow with respect to preventing and testing for signal leakage. These rules can be found in Part 76 of Title 47 C.F.R.

An MVPD is any provider that distributes multichannel video programming, traditionally for a fee, for example the cable television systems. Non-cable MVPDs are exempt from the FCC’s legal definition of a cable system, but are subject to some of the same technical rules that traditional cable systems are. Examples of non-cable MVPDs are universities, hotels, apartment complexes and other multiple-unit communities, prisons, office buildings, and other facilities with in-house systems for making multiple channels of video programming available to subscribers or consumers.

The aeronautical frequency bands range from 108 – 137 MHz and 225 – 400 MHz, which correspond to cable channels 14-16, 25-53, and 98 & 99. Notification filing with the FCC is required once a year. All MVPDs must monitor for and repair signal leaks.

Fines for violators can range up to $37,500 per violation, per day of continued violation. It costs $60 to file a frequency usage notification form with the FCC, and no fees are assessed for filing the basic signal leakage performance report.

Ref;

DA 12-1340

Citation No.: C201232900002

Citation No.: C201232900003

Citation No.: C201232900004

C.F.R. Title 47, Part 76

$12,000 “Dollar” Forfeiture Order

SAN Control Tower (Photo credit: Peter Kaminski)

San Diego, California; FCC issues a forfeiture order in the amount of $12,000 to DTG Operations Inc., (d/b/a Dollar Rent-A-Car), after receiving complaints from the Federal Aviation Administration (FAA) regarding intermittent interference to three ground control frequencies used by air traffic controllers at San Diego’s International Airport.

During investigation by FCC Enforcement Bureau’s San Diego Office, agents discovered the source of the interference signal to be emanating from a transmitter on a Dollar airport shuttle bus. Upon discovery, the manager of the Dollar facility immediately took the radio transmitter out of service.

In Response to an earlier Notice of Apparent Liability for Forfeiture (NAL), Dollar requested that the fine be reduced because the violation was “an unintentional mistake,” which Dollar readily admitted, and because Dollar cooperated fully in the investigation. It was noted in the forfeiture order however that a reduction was not warranted.

For some information on the FCC enforcement process see “Enforcement Primer” on the FCC.gov web site. The legal firm Fish & Richardson has an article on their web site that gives a brief rundown on the process, as well as figures on Equipment manufacturer violations. Although the web page’s focus is on equipment violations associated with marketing rules and technical standards,  and not necessarily on the misuse of approved radio communication devices, the steps in enforcement are essentially the same.

Ref;

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db0404/DA-12-536A1.pdf

http://www.fcc.gov/

2011 market surveillance report EU –are tablet PCs a target for 2012?

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Bundesnetzagentur (Federal Network Agency) of Germany, for Electricity, Gas, Telecommunications, Post and Railway has the responsibility to carry out the market surveillance under the EMC and R&TTE Directives.

The agency published a summary of the 2011 market surveillance campaign on its web site. The campaign’s primary focus in 2011 was with the EMC directive and in particular, LED lighting equipment. The report also combines results from the 2010 and 2011 campaigns to give a summary overall and to achieve a low error probability due to the larger sample size.

For some background on emissions concerning LED product, see July 2011 post “Radio interference from LED lighting”.

The surveillance looked at administrative conformity, such as marking, documentation and declarations, as well as the technical aspects of the directive namely compliance with the emissions and immunity requirements. A total of 168 products were sampled in 2011.

On the administrative side, the surveillance found that 76.8% of the samples were compliant with the CE marking requirements, while only 39.9% were compliant with the Declaration of Conformity (DoC) requirements.

For the technical assessment, 61.5% of product complied with the radio emissions requirement, and 91.3% were found immune to specific interference phenomenon, out of 46 products tested overall.

In total, only 17.3% of LED lighting equipment was found to be fully compliant.

For the “reactive market surveillance”, the overall rate of non-compliance for electromagnetic compatibility (EMC) was 38.9%. For radio and telephone terminal equipment (R&TTE) a majority, 65.5%, was found non-compliant according to the report, but most concerning was that 75.6% of the R&TTE products checked were non-compliant with the safety and health measurement requirements.

The 2011 surveillance resulted in 90 EMC sales bans, 177 R&TTE sales bans, 353 “memoranda of understanding” between the two directives, and total revenues of €1,046,000

The report details some objectives for 2012 indicating supporting the revision of the EMC and R&TTE directives and transposition into national law, including harmonizing product assessment for market surveillance, and increasing cooperation with European market surveillance and customs authorities as well as adapting the national database for market surveillance results, to the European ICSMS database.

Two product group targets were mentioned for 2012, one a coordinated German/Dutch campaign targeting tablet PCs focused on the R&TTE directive, and another targeting “Ready-made connecting devices”, or laptop power supplies.

 

ref;

Market surveillance statistics 2011

Are on-board electric vehicle battery chargers exempt from FCC equipment authorization?

Image via Wikipedia

Under Title 47, Part 15 Subpart B § 15.103, the first item on the list of exempted devices is

“(a) A digital device utilized exclusively in any transportation vehicle including motor vehicles and aircraft.”

The clear answer is “Yes” to the question, “are electric vehicle battery chargers exempt”,… right? … What would you say?

As is the case with much of part 15 subpart B, in order to comply with the intent, you need a little common sense, good familiarity with electromagnetic energy propagation, the ability to think like an FCC engineer, and finally, a Knowledge Database publication (KDB) from the FCC with a clear “yes” or “no” answer to any question you may have, and you may have many.

See Publication Number: 892282

Question:
Is a battery charger and associated digital electronics on-board a vehicle that is used for charging the vehicles battery while parked and connected to AC power lines exempt from an equipment authorization under 15.103.
Answer:
No. Section 15.103, Exclusions, paragraph (a) does not apply to battery chargers for electric vehicles that can be used for charging while stationary and connected to an AC power line. The exemption is only intended for digital devices which operate primarily when the vehicle is operating in a mobile environment such as on a road or highway where the potential for interference is low. When stationary and connected to the AC power line, typically in a residential environment such as a home garage or driveway, the potential for interference by both AC lines conducted and radiated emissions is greater. The battery chargers and associated electronics on board an electric vehicle are therefore subject to an equipment authorization under the verification procedure as a Part 15  Class B or Class A (industrial vehicles) unintentional radiator (switching power supply and digital device).

The last word on Power Line telecom (PLT) in the EU, EN 55022:2006 applies in full, maybe….

Image by Sigfrid Lundberg via Flickr

Power Line communication devices continue to be a controversial subject, with respect to the Electromagnetic Compatibility of such devices. We have been following this subject for both the United States, and for Europe. The latest round comes from across the pond with the rejection (negative vote) of the European Norm targeted to cover the testing of these devices, prEN 50561-1:201X. For background on this topic, see my past article “An update on PLT, Power Line Telecommunications, in Europe”.

Due to the negative vote on prEN 50561-1:201X, and a lack of a specific standard covering the emissions testing for PLT devices, EN 55022:2006 applies in full for these devices as of October 1st. It should be noted that many newer high speed advanced PLT devices cannot pass the requirements of EN 55022:2006 at this time.

This conclusion will be confirmed by a note published in the Official Journal reference to harmonized standards under the EMC directive.

CENELEC may offer a second vote, indicating that the choice is between EN 50561-1 and EN 55022. If this vote fails, no further option exists.

What does this mean for product on the market? Are recalls required for non compliant devices? What about new product placed on the market? The Commission is expected to accept a reasonable Date of Withdrawal (DoW) as proposed by working group 11, and until that date, manufacturers should still be able to continue placing product on the market using the Declaration of Conformity and Notified Body TCF path. The EU market authorities are “encouraged” to accept this.

The group of European Notified Bodies are meeting to discuss, and will consider the Technical Guidance Note (TGN) on the matter, after the meeting. Is this the end of the debate? Time will only tell, and we’ll continue to post when we learn more.

FCC’s first wave crackdown against signal jammers

The Federal Communication Commission is making good on its warning to signal jammer vendors on Friday Sept. 30, issuing a sweeping citation to 20 of them.

Earlier this year, the FCC issued a warning to consumers and vendors of the illegal nature of jamming devices, and warned would-be violators of the consequences that may come if selling or using such devices.

The vendors listed in the citation order are all online vendors that offer a range of illegal jammers such as GPS blockers for vehicles, high-tech signal blockers with remote control capabilities, jammers disguised as paintings and cigarette packs, other small, easily-concealable cell phone jammers, as well as high powered industrial jammers that have the potential to disrupt radio signals in areas as large as a football field.

The citation requires that the online vendors report within 30 days on their specific actions taken to correct the violation. The citation also warns that continued violation may bring fines, equipment seizure or imprisonment.

By: J Klinger

Omission of Class B statement in users manual costs…

Image by wolfheadfilms via Flickr

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

$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

FCC reminds the public that radio jammers are illegal to operate in the United States, and warns would-be violators of the consequences of selling or using them

Image by G0SUB via Flickr

In a News Release titled “FCC ENFORCEMENT BUREAU STEPS UP EDUCATION AND ENFORCEMENT EFFORTS AGAINST CELLPHONE AND GPS JAMMING.”  The FCC warns and reminds consumers that it is a violation of federal law to use a cell jammer or similar device that would intentionally block, jam, or interfere with authorized radio communications.

In a kind of public outreach, the news release by the FCC Enforcement Bureau explains what can happen if you use a cell jammer, why jammers are prohibited, and information on how to file a complaint alerting the FCC to illegal jamming device usage. A copy can be downloaded at http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0209/DOC-304575A2.pdf.

Additionally, the FCC Enforcement Bureau released a public notice in the form  of an FCC Enforcement advisory. The public notice warns of the strict penalties for marketing or selling jamming devices. Among the penalties, a fine of up to $112,500 can be issued for a single violation. A complete list of jammer enforcement activity can be found at http://www.fcc.gov/eb/jammerenforcement/ A copy of the FCC Public Notice can be downloaded at http://www.fcc.gov/Daily_Releases/Daily_Business/2011/db0209/DA-11-249A1.pdf

Compatible Electronics, Inc. operates a fully certified telecommunication certification body for radio device approvals in accordance with FCC rules, please visit our site at http://www.celectronics.com/us.htm or contact us with your questions about the wireless device approvals process and regulations.

By: J Klinger

Company fined $10k for impacting weather radar near San Juan airport

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Terminal Doppler Weather Radar (TDWR) serving San Juan International Airport received interference adjacent to 5.61GHz, source tracked by FCC and FAA agents to radio transmitters providing wireless internet atop a nearby building.
The company responsible for the interference was issued a forfeiture order by the FCC enforcement bureau in the amount of $10,000. While the company used equipment that had been previously certified under the FCC rules for UNII operation, the equipment causing interference was operating on frequencies that it had not been approved for. Moreover, if the transmitters would be considered non-UNII devices and subject to section 15.407(2) of the FCC rules, then the power allowed would have been limited to ¼ Watt in that particular frequency band, however, the devices in question were designed to operating in excess of three times that level.
The full FCC forfeiture order can be found at http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-10-138A1.pdf.

FCC Enforcement Bureau issues statement on Enforcement Advisories

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On January 15, 2010, Michele Ellison, Chief of the FCC Enforcement Bureau made a statement on the launch of a new initiative with respect to “Enforcement Advisories”.

This would seem to indicate that the FCC will be more aggressive with respect to enforcement moving forward, as evident by this quote from the statement;

“While most companies and individuals take their regulatory obligations seriously, some appear unaware of what the Commission’s rules require or choose not to comply. The Enforcement Bureau will continue to work proactively to bring these entities into compliance. By the actions we take today, we affirm our commitment to strong, vigorous, and fair enforcement of the Commission’s rules.”

 

For a copy of this FCC release please see: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-295749A1.pdf

Below is a link to the new Enforcement Advisories page: http://www.fcc.gov/eb/Enforcement_Advisories/Welcome.html This and other helpful links can be found at EMCguy's Bookmarks on delicious.

Please visit the Compatible Electronics US certification page for other US related conformity assessment information.

 

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