Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) 1998 Biennial Regulatory Review --) Conducted Emissions Limits Below 30 MHz) ET Docket No. 98-80 for Equipment Regulated under Parts 15) and 18 of the Commission's Rules ) NOTICE OF PROPOSED RULE MAKING Adopted: October 13, 1999 Released: October 18, 1999 By the Commission: Comment date: [insert date 75 days from publication in Federal Register] Reply comment date: [insert date 105 days from publication in Federal Register] INTRODUCTION 1. By this Notice of Proposed Rule Making ("Notice"), we propose to amend Parts 15 and 18 of our rules to revise the limits on the amount of radio frequency (RF) energy that is permitted to be conducted onto the AC power lines. The purpose of these limits is to protect against interference to radio services operating below 30 MHz. The conducted emission limits apply to a wide variety of products, including various consumer electronic devices and radio transmitters. We propose to harmonize our standards on conducted emission limits with the international standards developed by the International Electrotechnical Commission (IEC), International Special Committee on Radio Interference (CISPR). We believe that such harmonization will better protect radio services against interference and facilitate a global marketplace to the benefit of manufacturers and consumers. BACKGROUND 2. The regulations permit the operation of RF devices under Parts 15 and 18 without any requirement to obtain a license. Part 15 devices are permitted to operate on any frequency except for certain designed restricted bands. However, all Part 15 devices operate on a non-interference basis to authorized radio services. Further, Part 15 devices must accept any interference received from other radio operations. Specific frequencies are designated for the operation of Part 18 devices. On these frequencies, all other radio services are required to accept any interference that is received from the Part 18 devices. In addition, Part 18 devices are permitted to operate on a non- interference basis on any other frequency, except for certain designated restricted bands. 3. Many RF devices obtain their electrical energy from the AC power lines, e.g., the 110 volt household electrical lines. Such devices include personal computers, personal computer peripherals, TV and FM receivers, video cassette recorders, cordless telephone base stations, wireless security alarm systems, RF lighting devices, microwave ovens, induction cooking ranges, and ultrasonic equipment. The RF energy that these devices generate can be conducted back onto the AC power lines. The conducted RF energy can cause interference to radio communications via two possible paths. First, the RF energy may be carried along the electrical wiring to another device that is also connected to the electrical wiring. Second, at frequencies below 30 MHz where wavelengths are greater than 10 meters, the long stretches of electrical wiring can act as very efficient antennas permitting the RF energy to be radiated over the airwaves. The signals radiating onto the airwaves can cause interference to operations at considerable distances because propagation losses are low at these frequencies. 4. Under Parts 15 and 18 of the rules, the potential for interference below 30 MHz is controlled by limiting the levels of RF emissions that may be conducted onto the AC power lines. Part 15 specifies conducted emission limits for RF devices, including certain unintentional and intentional radiators. Part 18 specifies conducted emission limits for certain types of products that are designed to generate and use locally RF energy for industrial, scientific, medical, domestic or similar purposes but specifically excludes applications in the field of telecommunication. Compliance with the conducted emission limits is usually determined by connecting the device to a line impedance stabilization network (LISN) which allows the measurement of RF voltages under standard conditions. 5. The current standards are based largely on limits that were developed in the late 1970s for digital devices. It has been several years since these standards were last examined. Accordingly, on May 29, 1998, the Commission adopted a Notice of Inquiry ("NOI") in this proceeding to review the conducted emission limits applicable to equipment operating under Parts 15 and 18 of its rules. The purpose of the NOI was to examine whether the regulations on conducted emission limits continue to be necessary and, if so, whether any changes to the limits may be appropriate. Information was sought as to the costs of complying with these regulations as well as any impediments these regulations may place on the development of new technologies. In response to the NOI, 15 parties filed comments and 6 parties filed reply comments. The list of the commenting parties is shown in Appendix B. 6. In the NOI, we designated this proceeding as part of our 1998 biennial review of regulations pursuant to Section 11 of the Communications Act of 1934, as amended. Section 11 requires us to review all of our regulations applicable to providers of telecommunication services and determine whether any rule is no longer in the public interest as the result of meaningful economic competition between providers of telecommunications services. While a review of the regulations regarding conducted emission limits for products subject to Parts 15 and 18 of the rules is not specifically encompassed by Section 11 of the Communications Act of 1934, this review is consistent with the objectives and spirit of Section 11. As part of our biennial review, we stated that our goal in this proceeding, among other things, was to examine whether the regulations on conducted emission limits continue to be necessary. We also sought information on the costs of complying with these regulations and whether these regulations impede new technologies. DISCUSSION 7. Based on the comments filed in response to the NOI, we are proposing a number of changes to the rules to make them more effective in controlling interference to communications services and to reduce the burden of these regulations. Specifically, we are proposing to amend the conducted emission limits to make them generally consistent with international standards. Consistency with international standards will promote a global marketplace that will reduce costs for manufacturers and consumers. We are proposing to adopt conducted emission limits for Part 18 consumer products, such as microwave ovens, that are currently subject only to radiated emission limits. We also propose an alternative measurement procedure for intentional radiators operating below 30 MHz where the responsible party may demonstrate that the total radiated emissions from the device, including emissions at the fundamental frequency that are conducted onto, and radiated from, the AC power lines, do not exceed the radiated emissions limits; such intentional radiators would not be required to demonstrate compliance with the AC power line conducted limits at the fundamental emission. Our specific proposals are discussed below. 8. Conducted emission limits. In the NOI, we expressed our view that conducted emission limits remain necessary for controlling potential interference to radio services below 30 MHz. We added that Part 15 RF devices and Part 18 ISM equipment continue to be capable of conducting significant RF energy onto the electric power lines that, uncontrolled, could severely disrupt over-the- air radio services operating on frequencies below 30 MHz. We also observed that there does not appear to have been any changes in technology that would inherently control conducted emissions from such equipment nor does it appear that competition would lead to a reduction in conducted emissions because the user can not observe any difference in product performance. Comments were invited on these observations. 9. There are a variety of services operating in the frequency bands below 30 MHz, including AM broadcasting, international broadcasting, amateur radio, the Personal Radio Services (e.g., Citizens Band Radio Service), aeronautical, maritime, land mobile, etc. Much of the spectrum below 30 MHz is used by, or shared by, federal government operations. We requested comments on whether the existing conducted emission limits were effective in controlling interference to radio services operating below 30 MHz and if changes in the types of radio services or the technologies used by these services require an increase or a decrease in the conducted limits. Additional factors that could be used to justify changes to the conducted limits were also requested. These factors include advances in analytical models for interference, consistency with international standards, electrical safety considerations that impact filter designs, and special requirements that may be appropriate for specific classes of products such as those used in business and commercial environments. 10. In the NOI, we also stated that the techniques for achieving compliance with the conducted emission limits are well known. Compliance generally is accomplished through the use of RF filtering. The costs associated with the conducted emission limits includes the cost of these RF filters along with the need to design the product to comply with the limits and to test the product to determine whether it complies with the limits. Information was sought regarding what percentage of product costs is typically associated with the Commission's standards on conducted emissions and the changes in costs that would occur should we relax our standards. 11. In general, the comments agreed with the Commission that standards on the amount of RF energy conducted onto the AC power lines are required to control potential interference to users of the radio spectrum below 30 MHz. However, manufacturers argued that the existing limits should be relaxed to lower product costs. In contrast, several groups representing radio spectrum users contend that the existing limits do not adequately control interference and should be tightened. 12. GE Lighting (GE) and Information Technology Industry Council (ITI) generally favored some degree of relaxation to the existing conducted limits. GE makes a number of specific proposals to relax the existing Part 18 RF lighting conducted emission limits to allow lower equipment costs. GE points out that in common low wattage compact fluorescent lighting the direct and indirect costs represented by filtering to comply with the conducted limits can equal 10 percent of the production cost; a 10 dB relaxation to the limits would provide a nominal but still significant reduction in the filter cost; a reduction of 20 to 25 dB may allow the entire input circuit configuration to change in a way that may provide other benefits such as increased reliability, different physical configurations or smaller size. GE adds that conducted limits are most likely to impede products that are targeted at extremely low costs, such as RF lighting, and have less impact on products that sell for hundreds of dollars. 13. ITI states that the technologies and equipment using the 450 kHz to 30 MHz band are stable and that no drastic action needs to be taken. ITI states that the use of international standards would eliminate conflicting requirements and facilitate a global market. It adds that since the CISPR limits employed in the European Union, and the limits employed in the U.S. have resulted in an interference-free situation, the Commission should adopt the more liberal of the Commission and/or the CISPR 22 standards over the band 450 kHz to 30 MHz. ITI does not believe that the Commission should implement the CISPR 22 limits from 150 kHz to 450 kHz because this would have a major cost impact. ITI states that the cost to comply with the existing Part 15 limits, which begin at 450 kHz, is under 2 percent for sensitive consumer digital equipment and under 0.5 percent for non-consumer digital equipment. Silicon Graphics, Inc. (Silicon) agrees with and supports ITI's comments. 14. The following commenters expressed their concern that the existing standards needed to be tighter: American Radio Relay League (ARRL), Jacor Communications (Jacor), National Association of Broadcasters (NAB), Senior Technologies, Inc. (Senior), Sensormatic Electronics Corporation (Sensormatic), and U.S. Coast Guard (Coast Guard). 15. ARRL states that the current limits are not sufficient to protect amateur transmissions from interference. It notes that interference problems are experienced regularly by amateur operators in the bands below 30 MHz due to conducted emissions from Part 15 devices such as TV receivers, personal computers and numerous Part 18 devices such as microwave ovens. Further, ARRL asserts that the number of such devices has been steadily increasing. ARRL adds that there is no incentive on the part of the operator of the device or the manufacturer to control conducted emissions. Accordingly, ARRL requests that the Commission not relax its limits. 16. NAB submitted test data demonstrating that the conducted limits need to be reduced by 22 dB in order to prevent interference to AM reception from conducted emissions coming into the power cord of the AM receiver that are on the same frequency as that to which the AM receiver is tuned. In addition to adopting a stricter limit, NAB requests that the Commission eliminate its separate limits for consumer (Class B) and non-consumer (Class A) devices since, according to the Radio Advertising Bureau's Radio Marketing Guide & Fact Book, 21 percent of all radio listening occurs somewhere other than at home or inside a vehicle. Jacor concurs with the NAB study and also urges the Commission to tighten its conducted emission limits, pointing out that interference to AM listeners has increased. Jacor adds that considerable listening to AM broadcast stations occurs in offices and homes in the vicinity of computer equipment. It also states that the distinction between consumer and non-consumer equipment is ineffective in providing interference protection, noting that a considerable amount of equipment designed as non-consumer finds its way into the home. 17. The Consumer Electronics Manufacturers Association (CEMA) and GE object to the NAB study. GE states that the NAB study does not represent a real-world environment. GE points out that the interfering signal was conducted directly onto the AC power cord of the AM receivers whereas the separation distance of this signal from the receiver in an actual situation would greatly mitigate any potential interference. GE reiterates that commercial installations use metal conduit that shields re-radiation and that the impedances and stray capacitances provided by wiring practices will reduce the level of conducted emissions. GE also states that NAB fails to provide compelling evidence that existing systems cause interference to AM radio or histories of complaints from customers. CEMA states that NAB has provided no cost/benefit analysis or insight as to how new technologies would be impeded by tighter limits. NAB responds that it is uncommon for a listener to complain to a manufacturer when interference occurs since there are natural and other common phenomena that produce AM interference, e.g., lightning, electric power lines and electric motors. It adds that AM listeners have become accustomed to hearing periodic interference and, based on a 1988 study prepared by B. Angell & Associates, generally change stations, probably to an FM broadcast station, when such interference occurs. Thus, NAB concludes that the proliferation of equipment that can cause interference has had a very negative impact on the AM broadcasting service which has seen its percentage of listeners decrease by over 50 percent in the past 15 years. 18. The Coast Guard, Senior and Sensormatic assert that the Commission needs to establish limits for conducted emissions below 450 kHz. The Coast Guard states that it uses spectrum between 90 kHz and 30 MHz and, in particular, operates the Differential Global Positioning System (DGPS) between 285-325 kHz that is used to improve the precision of positioning information available from Global Positioning Satellites. The Coast Guard adds that the DGPS is employed for navigation purposes such as harbor approaches, aid to navigation positioning, and vessel traffic system control of harbor navigation. Further, Automatic Identification System transponders using DGPS will soon be installed on commercial vessels operating in inland and coastal waters of the U.S. In addition, the DGPS is being expanded to cover the entire continental U.S. to promote the safe navigation of land vehicles and transportation systems. Because of concern about potential interference to the DGPS, the Coast Guard requests the Commission to extend its conducted emission limits to cover this band. Senior is concerned about interference to a low power radio system that it manufactures to operate at 295 kHz or 506 kHz under Part 15 of the rules that is used to help monitor dementia patients. Senior states that its system receives conducted and radiated interference from washing machines, televisions, electric door openers and personal computers, requiring customers to install power line filters or rearrange equipment placement. Sensormatic indicates that some security systems operate in the 25-100 kHz frequency range, and that the Commission needs to regulate conducted emissions above 9 kHz from industrial and commercial products. It points out a particular type of AC-to-AC converter that is used to increase the efficiency of energy consumption for products such as air handlers and elevators produces emissions below 450 kHz that cause interference to security products. Similarly, Sensormatic points out that RF lighting devices with emissions below 450 kHz cause interference and degradation to security systems. 19. Microsoft, in ex parte comments filed on March 4, 1999, requests that the Commission relax its limit on conducted emissions at the fundamental frequency of 27 MHz for radio transmitters it is investigating for various uses with personal computers. Microsoft argues that coupling of emissions from the transmitter to cables within the computer and to the AC power lines can not be controlled and that the resulting conducted emissions are highly variable. It adds that requiring the use of shielded AC power cords and the installation of filters on every signal and power line within each computer using this transmitter is not practical. 20. We observe that radio frequency devices and industrial, scientific and medical equipment continue to be capable of emitting signals that are capable of causing interference to communications services. It does not appear that market mechanisms or other incentives would be effective in controlling such interference. Consumers have no way to tell at the time of purchase whether a product emits high levels of conducted emissions that are capable of causing interference to communications services. Accordingly, we conclude that mandatory conducted emission limits continue to be necessary to control interference to communications services. 21. We note that considerable work has been done to develop conducted emission standards within the CISPR. Notably, CISPR has developed standards for information technology equipment under CISPR Publication 22, and for industrial, scientific and medical equipment under CISPR Publication 11. For digital devices, we permit use of the CISPR 22 standard as an alternative to the FCC standards. We note that there appears to be growing support by both governments and industry for the harmonization of emission standards internationally to promote trade and competition. Harmonized standards can improve economies of scale and thereby reduce product costs, to the benefit of consumers. Harmonized standards also tend to reduce testing costs for products marketed internationally. 22. There are several factors that must be considered in comparing the FCC and CISPR standards. The FCC conducted emission limits are based on quasi-peak measurements, but the measurement procedure allows the instrument readings for broadband emissions to be reduced by 13 dB for comparison to the limits. In contrast, the CISPR Publication 22 standards specify separate limits for quasi-peak and average measurements. The CISPR quasi-peak limits are less severe than the FCC quasi-peak limits, but they already take into account adjustments for broadband emissions. Also, some products with a low peak-to-average ratio may comply under the current FCC standards based on a quasi-peak measurement but may not comply with the CISPR average limits. After taking these factors into account, the CISPR emission limits for consumer equipment are approximately 5 dB more stringent below 5 MHz and 1 dB more stringent above 5 MHz. 23. We are unpersuaded by NAB's arguments favoring a substantial reduction in the conducted emission limits in the AM broadcast band. We observe that NAB's study is based on worst case assumptions. For example, the interference source was coupled directly into the power cord of the AM broadcast receiver, whereas in practice there would normally be some length of electrical cable between the devices that would attenuate the interfering signal. Our interference standards are designed to control interference from a user's device to other users of the spectrum, e.g., from a user's personal computer to a neighbor's AM broadcast reception. The standards do not attempt to control interference between the user's own devices, e.g., from the user's personal computer to an AM broadcast receiver sitting on the same desk and connected to the same electrical outlet. This approach recognizes that the consumer can take steps to control interference between closely spaced devices in their possession. We also find that NAB has not submitted compelling evidence that devices complying with the FCC standards have caused interference from one user to another. We note that the international CISPR standards would generally reduce emissions in the AM broadcast band by about 5 dB. The international standards appear to strike a reasonable balance between the need to establish standards to control interference to broadcasting services in this region of the spectrum and the need to avoid unnecessary constraints for RF devices and ISM equipment. 24. In light of these considerations, we propose to adopt the international CISPR limits in place of the current FCC conducted emission standards. The standards being proposed are shown in Appendix C. A graph comparing the various standards is attached as Appendix D. We believe that these standards address some of the concerns expressed by ARRL, Jacor, NAB and others. Even though the CISPR standards may be marginally more stringent than those currently required under the rules, the benefits that would be gained through harmonization should compensate for any additional technical burden. As previously stated, harmonization can promote trade and competition and can improve economies of scale, reducing product and testing costs. Harmonization also can simplify the implementation of mutual recognition agreements with other countries on product conformity assessment. 25. As noted above, the FCC conducted emission standards typically cover the frequency range 450 kHz to 30 MHz. The CISPR publications specify conducted emission limits from as low as 9 kHz up to 30 MHz. It appears that limits below 450 kHz are warranted to protect new and existing uses for this region of the spectrum. While there are several types of radio systems operating below 450 kHz, we are particularly concerned about the potential that harmful interference could be caused to radio services that are employed for applications involving safety of life and property, such as the DGPS. We also note the interference problems referenced by Senior and Sensormatic. While these latter products operate under Part 15 of our rules and are not entitled to interference protection regardless of the source of interference, we are concerned that these interference reports indicate that the lack of conducted emission limits below 450 kHz may be resulting in harmful interference or excessive background RF noise that could impede the operation of other authorized radio operations. Accordingly we invite comment on expanding the frequency ranges over which conducted emissions are applied to correspond to the same ranges employed under the CISPR standards. In particular, we request comment on other radio operations below 450 kHz that may experience, or have experienced, problems due to excessive man-made RF noise levels. We note ITI's suggestion that implementing the CISPR limits below 450 kHz would significantly increase the costs of digital devices, yet we also note that these standards currently are employed in Europe and other countries. Thus, we also invite comment on the equipment costs associated with expanding the frequency range for conducted emission limits. 26. We agree with Microsoft that some relief could be provided for conducted emissions appearing at the fundamental frequency for intentional radiators operating below 30 MHz. We recognize that it can be difficult and costly to suppress conducted emissions appearing at the fundamental frequency of the transmitter due to coupling between the antenna and the power wiring. To alleviate this burden, we propose to permit the responsible party to ignore the level of the emissions conducted onto the AC power lines at the transmitter's fundamental emission provided the responsible party includes the energy radiated from the AC power lines as part of the total radiated emissions from the intentional radiator. The resulting transmission system would be tantamount to the combination of a carrier current system with a conventional transmitter/antenna system. We recognize that the levels of radiated emissions due to RF energy conducted onto the power lines tend to vary from location-to-location, based on changes in the layout of home and business AC wiring. Because of this, like a carrier current system, testing to determine the radiated emission levels would be required at a minimum of three installations that are representative of typical installation sites. We believe that this proposal will simplify transmitter equipment designs and will provide the design relief sought by Microsoft. We also believe that this proposal will not result in increased interference concerns since the emissions from the power lines would be at the same frequency as that being radiated by the transmitter and would be subject to the existing radiated limits contained in Part 15. However, we are concerned about the increased testing burden that this proposal would place on responsible parties. Comments are requested on this proposal as well as alternative test procedures that could be employed, especially test procedures that would enable the equipment to be subjected to a single test at a laboratory open field test site. 27. We invite comment on whether these standards will adequately protect communications services against interference. Parties arguing that the international standards are inadequate should provide a complete technical analysis supporting alternative standards. We also invite comment on how compliance with international standards may affect product costs. With regard to digital devices, we propose to discontinue the choice of complying with either the current FCC limits or the international limits. We believe that many manufacturers are already complying with the CISPR limits and use of a single set of limits would simplify the regulations and promote compliance. We note that the international standards include separate limits for digital devices and ISM equipment used in residential environments as well as limits for equipment used in business/industrial environments. We believe such an approach is appropriate because it takes into account the different characteristics affecting interference in each environment, such as the wider separation distances between equipment that occur in business and commercial environments. However, we are not proposing to establish separate consumer and non-consumer conducted emission limits for Part 15 devices other than for digital devices. This decision is based on several factors: most Part 15 devices are marketed to the general public without restrictions placed on who purchases these products, are inexpensive, and can be used for mobile applications or easily moved to different locations. Thus, most Part 15 devices other than digital devices can not readily be established as being non-consumer products. We solicit views as to any other factors that should be taken into account in considering our proposal to adopt the international conducted emission standards. 28. Devices Covered by the Limits. We propose to apply the CISPR limits to all Part 15 devices that are currently subject to line conducted emission limits. This includes all unintentional and intentional radiators subject to the emission limits in Sections 15.107 and 15.207 of the rules. We are not proposing to apply these standards to incidental radiators or equipment that is currently exempt from complying with specific emission limits. Incidental radiators are not currently subject to any emission limits. Examples of incidental radiators include products that use electric motors, such as washing machines, dishwashers, refrigerators, hair dryers and other appliances. These devices are subject only to the general provisions that they may not cause harmful interference and must accept any interference that may be received. We note NAB's suggestion that the Commission should regulate all products that place RF noise on the AC power lines. However, given the large numbers of incidental radiators that would be affected, and overall lack of interference complaints from such devices, we do not believe that mandatory emission limits are warranted. We also are proposing to maintain the existing exemptions from specific emission limits for the devices listed in Section 15.103 of the rules, including digital devices used exclusively in any transportation vehicle; digital devices used exclusively as an electronic control or power system used by a public utility or in an industrial plant; digital devices used exclusively as industrial, commercial, or medical test equipment; digital devices used in appliances; and specialized medical digital devices. 29. Part 18 currently specifies conducted emission limits only for RF lighting devices, induction cooking ranges, and ultrasonic equipment. Part 18 specifically exempts from complying with any emission standards all non-consumer ultrasonic and magnetic resonance equipment that are used for medical diagnostic and monitoring applications. The emission standards for RF lighting devices were reviewed in a separate proceeding, and we are not considering any changes here. We observe that the current rules are inconsistent with regard to the treatment of consumer ISM equipment. For example, ultrasonic devices such as denture and jewelry cleaners are subject to conducted emission limits, but devices such as microwave ovens are not subject to any conducted emission limits. We note that consumer microwave ovens can use 1000 watts or more of RF energy and are known to conduct significant levels of RF energy onto the power lines. We are also concerned that new consumer ISM devices may be developed that would not be subject to any conducted emission limits under the current rules. Accordingly, we are proposing to amend the rules to establish general conducted emission limits for consumer ISM equipment consistent with the CISPR Publication 11 limits. We propose to maintain the current exemptions for non-consumer ultrasonic and magnetic resonance equipment that are used for medical diagnostic and monitoring applications. Tests on such equipment are costly and these products are not known to have caused significant interference to radio communications. We also are not proposing to require mandatory compliance with the CISPR limits for any additional industrial or commercial ISM equipment. Comments are invited on these proposals. We specifically request that parties filing comments provide analysis of the costs and benefits of alternative proposals. 30. Miscellaneous issues. In the NOI, we also requested comments on whether to change the standards for carrier current systems, such as campus radio systems. In general, the comments from Adaptive and Interactive Technologies (Interactive) request that we relax the standards to provide greater transmission range; however, neither party provided an analysis to demonstrate that such a relaxation would not result in an increased interference potential to other spectrum users. UTC, The Telecommunications Association (UTC) states that it is vital that the Commission's rules not impede the development of high-speed data and other services employing carrier current technology but adds that it is premature to propose specific changes to the regulations. Intellon Corporation (Intellon) and Microsoft Corporation (Microsoft) state that the current rules strike an equitable balance between protecting other radio services and allowing innovation at a reasonable cost. NAB, as noted above, requests a reduction in the conducted emission limits for carrier current systems. None of the commenting parties submitted compelling evidence that the existing limits present a significant impediment to technology development or that these limits could be relaxed without increasing the potential for interference to other radio services. Accordingly, we find that the existing rules for carrier current systems are appropriate and are not proposing changes at this time. We will consider changes to these standards at some later date if additional information justifying a change to the regulations is forthcoming. 31. Microsoft requests that we set a limit on the power line conducted emissions which could be used by carrier current systems as an optional alternative method of demonstrating compliance with the radiated limits outside of the AM broadcast band. Microsoft adds that further study is needed before specific limits can be proposed. We believe that such relief from measuring the radiated emissions from carrier current systems is desirable. Such a standard would simplify the rules by permitting responsible parties to comply with voltage and current limits on RF signals placed on the AC power lines in lieu of measuring radiated emissions. We request comments in this area. If the comments can provide specific conducted emission limits that will ensure that carrier current systems comply with the existing radiated emission standards, we propose to permit the responsible parties to demonstrate compliance with those conducted emission limits as an alternative to measuring radiated emissions. 32. Inline Connection Corporation (Inline), a manufacturer of TV interface devices that use the telephone lines for signal distribution, requests that the Commission clarify when measurements of radiated emission limits below 30 MHz are required. While this request normally would be considered to be beyond the scope of a proceeding dealing with conducted emission limits, we understand that the current regulation may be confusing and are proposing a clarification. According to 47 C.F.R.  15.109(e), radiated emissions measurements below 30 MHz are required for any unintentional radiator that is designed to conduct RF energy below 30 MHz via connecting wires or cables. This type of measurement can be difficult and should not be necessary if the connecting cables are so short that they can not act as an effective antenna. To clarify this regulation, we propose to amend our rules to require that radiated emission measurements below 30 MHz be required only when the length of the connecting cable is at least one-fourth of the wavelength of the center of the transmitted signal or is of unknown length. Comments are requested on this proposal. Comments are also requested on whether there is a frequency below which radiated measurements need not be made, e.g., below 50 kHz. 33. Silicon notes that there are non-digital devices that cause interference to licensed radio services and points to interference from halogen lamps with electronic transformers that continue to function even with the lamp turned off. Silicon requests that such products be subject to standards that control potential interference over the range 450 kHz to 88 MHz. In response, the electronic transformers referenced by Silicon are already subject to the standards on conducted emissions and radiated emissions. Depending on how the products generate and use RF energy, these lamps would be classified either as Part 18 RF lighting devices or as unintentional radiators under Part 15. In either case, the applicable technical standards are identical. TRANSITION PROVISIONS 34. We propose to require that the regulations proposed in this Notice become effective one year from the date of publication of the Report and Order in the Federal Register for all Part 15 and 18 products subsequently authorized under a grant of certification, a Declaration of Conformity, or verification. Since the standards being proposed are the same as those used in most other countries, we do not believe that additional time would be necessary to achieve compliance with the new standards. We also propose that all products imported or manufactured on or after three years from the date of publication in the Federal Register comply with these standards. We believe that most affected products would be redesigned within this three year time frame and that compliance with this proposal would not cause an unreasonable burden on industry. Comments are requested on the proposed transition provisions. PROCEDURAL MATTERS 35. As required by Section 603 of the Regulatory Flexibility Act, 5 U.S.C.  603, the Commission has prepared an Initial Regulatory Flexibility Analysis (IRFA) of the expected impact on small entities of the proposals suggested in this document. The IRFA is set forth in Appendix A. Written public comments are requested on the IRFA. These comments must be filed in accordance with the same filing deadlines as comments on the rest of the Notice of Proposed Rule Making (Notice), but they must have a separate and distinct heading designating them as responses to the IRFA. The Secretary shall send a copy of this Notice, including the IRFA, to the Chief Counsel for Advocacy of the Small Business Administration in accordance with Section 603(a) of the Regulatory Flexibility Act, 5 U.S.C.  603(a). 36. This is a non-restricted notice and comment rule making proceeding. Ex parte presentations are permitted, except during the Sunshine Agenda period, provided they are disclosed as provided in the Commission's rules. See generally 47 C.F.R.  1.1202, 1.1203, and 1.2306(a). 37. Pursuant to Sections 1.415 and 1.419 of the Commission's Rules, 47 C.F.R.  1.415 and 1.419, interested parties may file comments on or before [insert date 75 dates from date of publication in the Federal Register] and reply comments on or before [insert date 105 days from date of publication in the Federal Register]. Comments may be filed using the Commission's Electronic Comment Filing System (ECFS) or by filing paper copies. See Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 23,121 (1998). 38. Comments filed through the ECFS can be sent as an electronic file via the Internet to . Generally, only one copy of an electronic submission must be filed. If multiple docket or rule making numbers appear in the cation of this proceeding, however, commenters must transmit one electronic copy of the comments to each docket or rule making number referenced in the caption. In completing the transmittal screen, commenters should include their full name, Postal Service mailing address, and the applicable docket or rule making number. Parties may also submit an electronic comment by Internet e-mail. To get filing instructions for e-mail comments, commenters should send an e-mail to ecfs@fcc.gov, and should including the following words in the body of the message, "get form