Article 19KG2 FCC Query: How to Include New ANSI Standard in the Rules?

FCC Query: How to Include New ANSI Standard in the Rules?

by
Mitchell Lazarus
from CommLawBlog on (#19KG2)

Public notice seeks guidance on incorporating new ANSI measurement procedures.

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This is one of those items that will interest only a few readers, but will interest those readers a lot.

Along with technical requirements for many kinds of devices, the FCC prescribes measurement procedures for assessing compliance with those requirements. Some of these procedures are developed by the FCC itself; other FCC measurement procedures incorporate standards adopted by industry groups.

A recent FCC public notice acknowledges publication of a new outside standard: the "American National Standard for Compliance Testing of Transmitters Used in Licensed Radio Services," code-named ANSI C63.26-2015. The standard itself is available here at US$137 for a PDF or $171 for a paper version, discounted for IEEE members. "ANSI" is short for the American National Standards Institute, which creates and maintains guidelines affecting many kinds of products of U.S. industry "from acoustical devices to construction equipment, from dairy and livestock production to energy distribution, and many more," according to its website.

The FCC's public notice asks whether the FCC should replace certain measurement procedures in the rules with references to the recent ANSI document. Other parts of the FCC rules incorporate other ANSI standards. Sometimes the FCC has to update its rules to reflect revisions adopted by ANSI. This one is not an update. The ANSI standard here would replace FCC-written rules.

Which rules? The FCC is looking for input on that question. The FCC seeks comment on which specific Part 2 measurement procedures the new standard should replace, and which specific licensed service rules should be replaced with cross-references to Part 2 (and, by extension, to ANSI C63.26).

Attentive readers - both of you - will recall that in late December 2015 the FCC adopted ANSI standards C63.4-2014 and C63.10-2013. These address compliance measurement for unlicensed devices: unintentional and intentional emitters, respectively. The new standard concerns licensed equipment.

(As long as we're talking about ANSI, here's a largely-irrelevant-but-nonetheless-interesting aside: Fittingly, the surname of ANSI's former chairman, Oliver R. Smoot, is also a widely known but rarely used unit of measurement. What's a smoot? According to the Google units conversion feature, one smoot equals 5.58333 feet or 170.18 cm. Smoot (the unit, not the man) obtained this meaning decades ago when Smoot (the man, not the unit) was used by his fraternity brothers as a yardstick to mark off the length of a bridge near MIT. The marks remain in place today, almost sixty years later.)

Comments on how the FCC's rules should address the new ANSI standard will be due 15 days after the public notice appears in the Federal Register, probably in about two weeks. Reply comments will be due 10 days after that. As always, CommLawBlog will publish the due dates when they are known.

Submit your comments at this FCC website; enter Proceeding Number 15-170.

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