Info and News

Fiber Unbundling to Encourage Optical Network Development

The FCC voted to relax its “unbundling” restrictions on the regional Bell Operating companies (RBOCs) with respect to portions of their new fiber networks.  The concept of “bundling” and “unbundling” stems from the Telecommunications Act of 1996, which encouraged competition in the telecom sector by forcing the incumbent telephone companies to share their networks with potential rivals.   While this sharing fostered competition in service to end users, it reduced the return on investment to the RBOCs, and so had the side-effect of diminishing investment and development in new types of facilities.

In answer to petitions from the RBOCs, and part of its review of the unbundling rules, the FCC has been unbundling some of the elements of broadband networks.  This means the RBOCs can operate them without sharing them with potential competitors at a forced, regulated rate.  The current action will remove sharing obligations on fiber-to-the-home loops, fiber-to-the curb loops, packet switching, and the packetized functionality of hybrid copper-fiber loops.

The Public Notice announcement may be found at: 

 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-253492A1.pdf  

DoC vs. Verification:  FCC Clarifies Policy with Respect to PC Connected Musical Devices

In a recent Public Notice, the Federal Communications Commission highlighted the difference between the Verification and Declaration of Conformity (DoC)  authorization procedures.  In the FCC’s words, “DoC is a self-approval process similar to Verification except that it requires that the tests be performed by an accredited test laboratory.”  The two authorization procedures also carry different requirements for equipment labeling.

The FCC’s Notice was prompted by its observation that a number of types of musical equipment which included digital components (making them subject to the Part 15 requirements for digital device emissions) are being sold which connect to personal computers—for example by MIDI, USB, or IEEE 1394 ports.  If these were stand-alone devices, verification would be a suitable authorization procedure; however, once they connect to a personal computer, they become PC peripherals, and the Declaration of Conformity procedure must be followed.  The table below shows the differences in authorization required for different types of digital devices: 

Note that for some entries in the table, the DoC and Certification procedures are alternate routes to authorization.  Certification involves submission of a formal application to an FCC approved Telecommunications Certification Body (TCB).  Certification is the only route for many non-computing devices (certain receivers, most transmitters).  However, where the rules allow a choice of the Declaration of Conformity or Certification, nearly all manufacturers choose the quicker and less expensive DoC procedure.

For manufacturers of electronic music equipment that can connect to a personal computer, the message is to use the Declaration of Conformity procedure, rather than Verification.  This means that the emissions test must be performed at a facility which is registered with the FCC, and that the DoC-associated product labeling of FCC rules paragraph 15.19 should be applied. 

Enforcement:  FCC Issues Liability Notice to Computer Board Manufacturer

Recently, the FCC issued a “Notice of Apparent Liability for Forfeiture” to computer board manufacturer VIA Technologies in the amount of $14,000.  According to the record, the FCC investigated a complaint that VIA was importing two models of CPU motherboards with the spread spectrum clocking (SSC) disabled, leaving it to the user to enable the SSC function.  It was also alleged that the CPU boards did not meet the FCC’s Part 15 emissions with the SSC function disabled.  Further, the instruction manual provided with the boards discussed the spread spectrum function, and advised the end user to leave it disabled for optimal system stability and performance.  Spread spectrum clocking dithers the operating frequency of the CPU, and in particular, the system bus, spreading the energy in system clock harmonics so its interference potential at single frequencies is diminished.

In its response to the FCC’s inquiry, VIA stated that it had tested the boards for emissions compliance with the SSC function enabled, but had neglected to test with the SSC function disabled.  However, VIA said the disabling of the SSC function was not intentional.  It blamed the default configuration (no SSC) problem on erroneous production procedures. VIA also claimed that the manual’s tech writers were using a mistaken assumption on the effect of SSC on system stability.  Upon receiving the FCC’s inquiry, VIA pulled all non-compliant boards from US distribution, and took steps to update them so they would be shipped with an enabled SSC function, and to remove the option to disable it.  Further, all users would be urged to update their system BIOS, and the BIOS would force SSC operation.

In reviewing the situation, the FCC noted that VIA’s corrective actions were commendable, but did not mitigate the violations that had already occurred.  Accordingly, it decided to assess the base forfeiture rate of $7,000 per occurrence, treating each mother board as a single instance.  VIA has the right to appeal.

For manufacturers, this incident points out the FCC’s position that all relevant operating modes of a product need to be investigated.  It is also a reminder of why spread spectrum clocking was invented and came into common usage as a means of emission control.

TV Interference Triggers Aircraft Rescue Satellite Response

Does EMI matter?  Here’s a radio interference example highlighting why we have emissions control requirements.  

This October, Chris van Rossman of Corvallis Oregon turned on his do-everything combo TV and got a big surprise—the police, the Civil Air Patrol, and the County Search and Rescue Officers knocked on his door.  Apparently, Mr. van Rossman’s flat screen, VCR/CD/DVC combo TV had developed some sort of strong emission (a parasitic oscillation, more than likely) at 121.5 MHz, which is a rescue frequency used by aircraft and boat distress transponders and monitored by orbiting satellites.  This service uses an uncoded analog carrier detection system, and is therefore rather sensitive to unauthorized transmissions. 

When the distress signal was picked up from the satellite, the information was picked up by the Air Force Coordination Center at Langley Air Force Base in Virginia.  Langley in turn called the volunteer Civil Air Patrol in Oregon, which in turn contacted Benton Country Search and Rescue for help in locating the signal.  Using radio direction finding equipment, the officers were able to narrow the source down to a few possible units in Mr. Rossman’s apartment building.  When they knocked on his door and he turned off his set to answer, the signal disappeared.

David Mandrell, the CAP squad leader had heard of similar inadvertent interference from consumer equipment, but often it was weak enough to be ignored.  This particular instance of interference was unusual because it was abnormally strong.

Mr. Rossman was simply warned to keep his TV turned off or face fines of potentially up to $10,000 per day for emitting a false distress signal.  He has contacted the set’s manufacturer, whose technicians had never heard of a case like this, and has agreed to send him a free replacement.

Source:  Corvallis Gazette-Times, Oct. 17, 2004

Watching the Pats Win the Superbowl—Priceless.  Janet’s Wardrobe Malfunction:  $550K

Although the current NFL football season is in full swing, the furor over last year’s Super Bowl Halftime Show is still winding down.  Readers may recall that last year’s show featured a number involving Justin Timberlake and Janet Jackson, which concluded with what has been euphemistically referred to as  “the wardrobe malfunction.”  Since the Super Bowl is seen by over 100 million U. S. viewers, it isn’t surprising that the FCC was deluged with complaints about the event—at last count, over 542,000.  Reacting to the outcry, the FCC launched an investigation, and has concluded that the material shown was “patently offensive,” and has assessed Viacom a fine of $550,000.  This fine amounts to nearly $1 for every complaint—although a different metric was used in arriving at it.

The FCC is charged by Congress with regulating broadcast communications.  Included in its duties is the oversight of broadcast licensees and their programming.  Because of the Constitutional commitment to free speech, the Commission has little authority over program content in general, but  it is authorized to enforce statutory and regulatory provisions concerning indecency, especially during the period of 6 a.m. through 10 p.m.  Typically, at any time, the FCC is reviewing some complaint in this area, some of which we’ve reported here.  However, none has generated as many complaints as the Super Bowl XXXVIII Halftime Show. 

CBS’ executives have so far indicated they would appeal the fine, claiming that they had no advance knowledge of the incident.  However, the FCC rejected this argument, saying that while CBS may not have known in advance of a planned wardrobe “malfunction,“ they were well aware of the racy nature of the performance and responsible for it. 

The fine was assessed at a maximum level of $27,500 per occurrence, counted as one for each of 20 affiliate stations owned by the network.  Affiliates stations that were separately owned were spared the fine.

The comments of the FCC’s commissioners on this action were interesting and varied.   Some wanted a much higher fine, pointing out that, despite the magnitude of the fine, it amounted to less than 10 seconds of Super Bowl ad revenue.  Another Commissioner thought that even the affiliates with separate ownership should have been fined.  Interestingly, on February 1, 2004, the broadcast of the Super Bowl ran with a five-second audio and video delay.  One week later, for the Grammy Awards programs, CBS instituted a five-minute delay to prevent any repeat mishap. 

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