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RE: Our friend the FCC, straight skinny part 2

I will try the patience of Terry and the list once more. 
In addition to my last post regarding FCC Part 15, here
are the INs and OUTs of operating under FCC Part 18, 
ISM equipment, as suggested by many coilers, plus
a mish mash of replies to many new questions and 
comments from the FCC message thread.

But First : Do we (1) want to operate under the rules  - or - 
(2) want new rules  ?  Option (1) is MUCH less expensive.  
Been there, done that, got the T shirt.

In a practical sense, DR. RESONANCE has the right answer:
Dont ask, dont tell.  Be a good neighbor.  This IS actually law
(the good neighbor part) as codified in CFR 47 part 15.5 (b) 
and also in part 18.111.

CFR Title 47 is available online at:
http://www.fcc.gov/wtb/rules.hml
The frequency allocation chart may be viewed at
http://www.ntia.doc.gov/osmhome/allochrt.pdf
also available by ftp: or purchasing a wall chart.
ALLOCATED FREQUENCIES cover 9 kHz to 300 GHz.  
Store theft detection operates around 8.9 kHz to avoid 
this, but operation oustide these limits IS still regulated 
if interference occurs.  

ISM devices are regulated under CFR 47 Part 18, and must 
meet broad technical requirements.  ISM equipment may 
operate with unrestricted power in certain bands.  Outside 
these bands, allowed field strength (part 18.305) for a device 
using more than 500w is :
25 * sqrt ( p / 500 )     uV/m measured at 300 m
So a NST coil could produce, say 25 uV/m and a 50 kW
RF (not kVA input) would be allowed 250 uV/m.
Also operation is prohibited in certain bands >> such as 
490 to 510 kHz <<   (distress radio frequency)

Equipment is approved by one of the following methods
2.902 Verification
2.903 Type Approval
2.904 Notification
2.905 Type Acceptance
2.907 Certification

TIP : Verification is THE ONE YOU WANT to fall under !

Under verification, you must make the measurements 
to verify you are in compliance, but you are not required 
to notify the FCC of waht you are doing.  They CAN demand 
to inspect your equipment and see your measurements 
if a problem arises.  (p 18.113) And you are responsible 
for correcting any complaints of interfenernce. (p 18.114)

Non-consumer ISM equipment is subject only to 
"verification" to meet technical standards.  Using
"TUV or one of the EMI licensing organizations" to 
approve a TC will not help.  We set up these labs
to "verify" and/or "certify" that a given equipment 
meets a given standard.  Labs are not free to "approve"
equipment at their own discretion.  (I know, I am one of
the 'high-priced experts' Terry mentioned, although I 
think the lawyers make much more money than me.)

I have equipment and can verify somebody's coil to be in
compliance with the ISM rules, but only if it really is.  Am
willing to work pro bono on this, you pay travel if needed.
Any takers ?

Get an attorney ?  Good way to burn money!  We have 
several attorneys on staff and on retainer in Washington 
DC who specialize in this, and I can refer any one who 
wishes.  These guys would be good if you wanted to 
challenge the FCC or petition for a rule change or new rules.
Warning : this is an uphill battle.  Your mileage with these
guys in uphill battles will range from "outrageous" to
"UN - !#%*&!#% - BELIEVEABLE"

Operating under Part 15 was discussed in my last 
post.  According to CFR 47 Part 15 the radiated limits 
from 0.009 to 0.490 MHz are computed by:
2400 / f(kHz) in uV/m at 300m. 
At 200 kHz that would be 12 MICROVOLTS per meter. 
What coilers consider 'low power' is orders of magnitude 
above what the FCC considers low power, the idea that
a coil is "not enough power" to be a problem is wrong.

In addition to radiated power limits, there are also 
conducted line limits, for instance you cannot legally inject 
more than 1000 uV into the AC line from 450 to 1705 kHz.

There is no legal 'out' for owning the property.  But it would
help you be a good neighbor.

You have no "right" to operate equipment that uses the 
EM spectrum.  Authority to operate is issued to civillians
by the FCC, and always comes with terms and conditions.
A "non-interference clause" is imposed on any but the 
primary licensee, and would certainly be imposed on TCs.

Even the "for sure" freqs of DC to 9 kHz are subject to non-
interference rules, just not allocated to a specific use.  
And dont forget harmonics.

You cant license all the freqs you emit on, as suggested by 
Justin Hennigan, because the TC is not eligible for licenses 
there. (although a CW coil would come a lot closer ! )  
Damped wave emissions are prohibited in nearly all license
classes, and most require crystal controlled frequency.


> > 
> > Original Poster: Greg Leyh <lod-at-pacbell-dot-net> 
> > 
> > Hi All,
> > 
> > I occasionally bring this up on the list, in the hopes that
> > an FCC-savvy lawyer might have just recently joined.
> > 
> > How does one approach the FCC in order to get their blessing
> > to operate a Tesla coil?  Are there ever exceptions or
> > variances granted?  Can the coil be creatively classified in
> > some way to minimize the legal hurdles?
> > 
> > This is an academic exercise.  Please do not provide skewed
> > answers such as  "Just be a good neighbor and the FCC won't
> > have to be involved", etc.  I wish to discover if one can 
> > run a TC 'on the level', in the true bureaucratic sense!
> > -- 
> > 
> > 
> > -GL
> > www.lod-dot-org
> > 
> 
>