A Case For Revising the FCC Regulations Governing Radio Frequency Devices

Part 15 of the Federal Communications Commission Rules and Regulations sets forth the technical and operational requirements for radio frequency devices. Basically, these rules deal with two areas. First, Part 15 provides for operation of low power transmitters without a radio station license. Second, these rules set forth requirements designed to control interference to authorized radio communication services that can be caused by equipment that emits radio frequency energy or noise as a by-product of its operation. This paper (1) briefly summarizes the history behind these rules, (2) outlines what the present rules are, and (3) examines ways in which the rules might be revised in the future to remove unnecessary restrictions to new devices and technologies, while simultaneously providing continued assurance that authorized radio communications will be adequately protected against radio interference. I S i E S S l H S i i S Q Part 15 of the Federal Communications Commission Rules and Regulations sets forth technical and operational requirements dealing with devices which emit radio frequency energy, termed “radio frequency (RF) devices." ill Radio frequency energy is defined as electromagnetic energy at any frequency in the radio spectrum between 9 kHz and 3,000,000 MHz. The rules serve a twofold purpose. First, they provide for operation of low power transmitters without a radio station license, subject to the conditions that (1) such operation may not cause harmful interference to authorized radio services and (2) all interference received must be accepted. Second, Part 15 sets forth provisions for control of interference caused by equipment which generates noise in the course of its operation. The Part 15 rules as they stand today have evolved over the course of nearly 50 years. The regulations have served well in controlling interference and have permitted the development of low power transmitters for a wide variety of applications, from * _ TRe auTRors a r e m e iB e r s ~ o f EResEaTT o l t h e O f f i c e o f S c ie n c e and T e c h n o lo g y o f th e F e d e r a l Com m unicat ions Comm ission, W asw h in g ton , D .C . The o p i n io n s e x p r e s s e d in t h i s p a p e r a r e th o s e o f th e a u t h o r s and may n o t n e c e s s a r i l y r e f l e c t th o s e o f th e Commission o r o t h e r s t a f f members. hobbyist devices such as walkie-talkies and radio controlled toys, to devices which have become a part of our everyday lives such as garage door opener controls and cordless telephones. Over the years, the regulations have been reviewed, either in whole or In part, on many occasions. For a number of reasons, on which we will elaborate later in this paper, the time once again appears to be ripe to reexamine these rules, with the aim of removing unnecessary obstacles to new devices, and also, to reduce the burden of the rules where appropriate. These objectives must be accomplished without compromising the underlying principle of protection of radio communications against radio interference. We wish to emphasize at the outset that the views expressed In this paper are solely those of the authors and do not necessarily represent those of the Federal Communications Commission. We have a number of reasons for presenting this paper. First, we seek to call attention to some of the difficulties that have been encountered in applying the current rules and past policies to new and soon to be developed types of equipment. Second, we would like to share with the public, and, in particular, the EMC community, some of the ideas that we and other members of the Commission staff have been considering for a possible framework for a revised Part 15, that would delete unnecessary regulations, reduce the burden on the public, and remove unneeded obstacles to new products and innovative technologies. Last, but perhaps most importantly, we seek to stimulate discussion and thought as to how the above stated objectives might best be accomplished. It is with these intentions