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

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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).

OET requesting comment on TV bands database system test

The FCC's Office of Engineering and Technology (OET) is requesting comment on the 45-day public trial of Telcordia Technologies Inc.’s (Telcordia’s) TV bands database system that was completed on January 20, 2012.


Link to OET request;
OET Request - ET Docket No. 04-186

Digital Transmission Systems and Broadband over Power line among newly published FCC knowledge database (KDB) articles

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The Office of Engineering and technology maintains a knowledge database at https://apps.fcc.gov/kdb . The primary function of this service is to provide the public a means to research answers to equipment authorization questions. For questions that are particularly complex, frequently asked, or often misinterpreted, the FCC provides guidance documents on the subject.

Among the latest of these guidance documents , are guidance for performing measurements on Digital Transmission Systems (DTS), and an answer to the question “What are the measurement guidelines for equipment authorization for BPL systems?”

For Digital Transmission Systems (DTS), the primary changes are;

• A revision and expansion of spectrum analyzer-based measurement methodologies.
• A revision to the procedure for measuring power spectral density.
• An expansion of guidance for measuring unwanted (out-of-band) emissions.
• A new provision to permit antenna port conducted measurement of unwanted emissions in
  restricted bands.

For BPL, or, Broadband over Power line Systems, the FCC points to Second Report and Order FCC 11-160, namely Appendix D of the order, for measurement guidelines on these devices, this includes both in-house BPL and Access BPL. The rules that govern FCC compliance of BPL systems were revised In October of 2011. See my October 2011 article for background and history on this topic.

Ready-Made Connecting devices (cables) under EMC directive?

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During the revision of the EMC directive 89/336/EEC, back in 2003, one of the most controversial proposals was the inclusion of “Ready-made connecting devices” within the scope of the EMC directive.

Ready-made connecting devices would encompass passive product, typically 3rd party in nature, designed to interconnect and be connected to apparatus covered within the scope of the directive, in effect classifying such connecting devices as apparatus themselves within the scope of the directive.

Products such as network cables, Audio / Video cables, and other interconnecting cables and adaptors would come under such classification and be subject to the protection requirements of the EMC directive (to paraphrase; must not interfere with others and must operate in the presence of interference without significant loss of performance) , thus requiring testing and marking as any other apparatus would.

It was argued that the term, “Ready-made connecting devices”, itself was ambiguous and unclear. Eventually it was decided that the devices represented no major interference potential, and because of the costs manufactures would incur for testing and marking, it was removed from the scope of the directive.

With the current revision and alignment of the EMC Directive with New Legislative Framework (NLF), the EMC directive 204/108/EC once again is subject to modification, and potential scope expansion. One such change being circulated for inclusion is that ready-made connecting devices be considered again and brought under the regime of the EMC directive.

In a proposal from the German Administration (BNetza), it is argued that in light of experience gained since 2003, the non interference claims argument cannot be maintained. The proposal claims there is no longer any serious doubt that insufficiently shielded connecting devices greatly increase the interference potential of TV and Cable networks in particular. The proposal cites several reports with data supporting this conclusion. One such report shows a  peak 30dB difference in screening effectiveness between two types tested, from most to least shielding, and notes that cable connectors can contribute around 10 dB of difference. See   ”The Concise Report of the CENELEC/ETSI Joint Working Group on the digital dividend" of 12 August 2010 (section 7.3)

The proposal suggests  that the following requirement be added to the new EMC directive;

Ready-made connecting devices, although incapable of generating electromagnetic disturbance in isolation, may generate or transmit electromagnetic disturbance when connected to an apparatus and should therefore be considered to be apparatus for the purposes of this Directive.

With ready-made connecting devices being defined as;

ready-made connecting devices' intended for connection to an apparatus by an end user for the transmission of signals, which are placed on the market separately from such apparatus, and which are liable to generate or transmit electromagnetic disturbance when connected to it.

This addition would then subject cables and connectors to the same technical requirements as any other product under the EMC directive, regardless of the component’s active or passive nature.

EN 55013 modified and draft going for vote

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EN 55013 is the EMC emissions standard for broadcast receivers and associated equipment. The standard is aligned with the European Union’s EMC directive as published in the official journal. The EMC directive is a CE marking directive, and compliance with this directive is compulsory for most electrical / electronic products prior to placing on the European market.

Previously reported in a post back in the summer of 2009, EN 55013, QP vs RMS, it was noted that the EU commission was holding off publishing reference to the newest edition of EN 55013, 2009, in the Official Journal.

The CENELEC technical committee, CLC/TC 210, had decided that the standard should not be published, without the link to the EMC Directive, and accordingly has set up a task force to seek a resolution.

It was agreed that the new draft common modifications should be circulated under UAP. The current project name is EN 55013:201X

The CLC/TC 210 Secretary proposed that the following explanation appear in the forward to the draft common modifications, furthermore this is not to be included in the final publish standard, should the draft be accepted:

“The text of CISPR/I/296/FDIS, the future CISPR 13 ed 5.0, received a positive vote in CENELEC, but was not ratified due to technical objections raised by the EMC Consultant. These would have prevented the listing of the standard in the Official Journal of the European Union as a harmonised standard providing a presumption of conformity with the protection requirements of the EMC Directive 2004/108/EC. The following draft includes common modifications to address these objections, and they have been agreed by the EMC Consultant and the responsible committee, TC210. It is submitted to UAP.”

It is expected that in light of the upcoming CISPR 32, perhaps appearing within a couple years, that EN 55013 will then be deleted. At that time, the use of the QP detector will have become obsolete and replaced by the RMS/Average detector.

It should be noted that the UK is not in favor of issuing the document under UAP, nor is Italy. The UK proposes to wait and see what happens with CISPR 32. The draft will be submitted under UAP none the less.

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

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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 holds workshop on Switched Telephone Network in transition

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For those of us in the technology field and most tech savvy consumers, as well as 40% age 18-30, an analogue phone connected to a pair of wires, heading off to a central switch, may seem antique and obsolete. The facts are that many still depend on this for communication. However those numbers are dwindling fast, and the time to consider the way forward, according to the FCC, is now.

According to a Mercury news report in 2009, the recession gave a “push” and for the first time during the last half of 2008, American homes with cell phones but no landlines outnumbered those with landlines but no wireless devices, due to consumers being forced to make an economic choice of one over the other. According to an April 2011 CBS news report a new federal study says that more than a quarter of homes in the United States now have only a wireless phone.

FCC regulations govern many aspects of the PSTN (Public Switched Telephone Network) such as equipment interoperability and protection of the network, access for persons with disabilities, hearing aid compatibility and others. The FCC will need to evaluate these issues more intently as the move to alternative forms of  main communication hastens.

The FCC will be holding two workshops to examine the transition from the traditional PSTN to new technologies.

The first workshop will focus on obstacles and opportunities the transition may create regarding public safety, availability and accessibility. This workshop will also evaluate “Non-carrier” stranded assets, such as alarm monitoring systems that would be left behind. This workshop will be held the morning of December 6, 2011.

The second workshop will examine economic, technological and policy issues that need to be addressed as consumers choose new technologies and services. This workshop will be held December 14.

Both workshops will be held in Washington DC as well as streamed live at http://www.fcc.gov/live

The Public notice is available here; http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db1110/DA-11-1882A1.pdf