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February 7, 2005
Mr. Jim Humphrey
Farm Bureau Insurance Office
16844 Robbins Road
Grand Haven, MI 49417
RE: Radio Frequency Interference--Case #EB-2005-2708
Dear Mr. Humphrey:
The Federal Communications Commission has received a complaint that a Panasonic Electronic Key System, Model TDA-50 Hybrid IP-PBX, is causing harmful radio interference to an operator in the Amateur Radio Service.
The FCC has the responsibility to require that such problems be rectified within a reasonable time if the interference is caused by faulty consumer equipment. Under FCC rules, equipment such as the key system is classified as an "incidental radiator." This term is used to describe equipment that does not intentionally generate any radio-frequency energy, but that may create such energy as an incidental part of its intended operation. We understand that you may not have realized that such a device could cause radio interference problems, because very often such devices will work fine and cause no problems.
To help you better understand your responsibilities under FCC rules, here are the most important rules relating to radio and television interference from incidental radiators:
Title 47, CFR Section 15.5 General conditions of operation.
(b) Operation of an intentional, unintentional, or incidental radiator is subject to the conditions that no harmful interference is caused and that interference must be accepted that may be caused by the operation of an authorized radio station, by another intentional or unintentional radiator, by industrial, scientific and medical (ISM) equipment, or by an incidental radiator.
(c) The operator of the radio frequency device shall be required to cease operating the device upon notification by a Commission representative that the device is causing harmful interference. Operation shall not resume until the condition causing the harmful interference has been corrected.
Title 47, CFR Section 15.13 Incidental radiators.
Manufacturers of these devices shall employ good engineering practices to minimize the risk of harmful interference.
Title 47, CFR Section 15.15 General technical requirements.
(c) Parties responsible for equipment compliance should note that the limits specified in this part will not prevent harmful interference under all circumstances. Since the operators of Part 15 devices are required to cease operation should harmful interference occur to authorized users of the radio frequency spectrum, the parties responsible for equipment compliance are encouraged to employ the minimum field strength necessary for communications, to provide greater attenuation of unwanted emissions than required by these regulations, and to advise the user as to how to resolve harmful interference problems (for example, see Sec. 15.105(b)).
The complainant has attempted unsuccessfully to resolve this problem with you and as a result the matter has been referred to our office. The FCC prefers that those responsible for the proper operation of equipment assume their responsibilities fairly. This means that you should resolve the interference caused by the aquarium light and make necessary corrections within a reasonable time.
While the FCC has confidence that most people are able to resolve these issues voluntarily, the FCC wants to make you aware that this unresolved problem may be a violation of FCC rules and could result in a monetary forfeiture (fine) for each occurrence. At this stage, the FCC encourages the parties to resolve this problem without FCC intervention; but if necessary to facilitate resolution, the FCC may investigate possible rules violations and address appropriate remedies.
The American Radio Relay League, a national organization of Amateur Radio operators, may be able to offer help and guidance about radio interference that involves Amateur Radio operators.
American Radio Relay League
Radio Frequency Interference Desk
225 Main Street
Newington, CT 06111
860-594-0200
E-mail: rfi@arrl.org
Please advise us as to what steps you are taking to correct this reported interference problem. The FCC expects that most cases can be resolved within 30 days of the time they are first reported. If you are unable to resolve this within 30 days, please advise this office about the nature of the problem, the steps you are taking to resolve it and the estimated time in which those steps can be accomplished.
If you have any questions about this matter, please contact me at 717-338-2502. Thank you for your cooperation.
CC: FCC Northeastern Regional Director
