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There have been 8 comment(s) made on this document:
  • William Graff commented on 2015-12-04 19:25:33.676:
    If the FCC goes ahead and combines the DofC with the Verification procedure, does it mean that DofC is the only avenue for authorization of LED lighting products? And it should follow that all LED lighting needs to tested at an accredited and recognized facility?
  • Alex Boesenberg commented on 2016-03-03 11:28:10.653:
    November 28, 2 March 3, 2016 Submitted online at: https://apps.fcc.gov/oetcf/kdb/reports/PublishedDocumentList.cfm Mr. Rashmi Doshi Federal Communications Commission Director, Office of Engineering and Technology Laboratory Division 445 12th Street SW Washington, DC 20554 Re: NEMA Comments to FCC Document 640677 D01, Draft Laboratory Division Publications Report Dear Mr. Doshi, The National Electrical Manufacturers Association (NEMA) appreciates the opportunity to provide the following comments on the FCC’s Draft Testing Guidance for Radiated Emissions Testing of Lighting Products. These comments are submitted on behalf of NEMA Lighting Systems Division member companies. NEMA is the association of electrical equipment and medical imaging manufacturers, founded in 1926 and headquartered in Arlington, Virginia. Its 400-plus member companies manufacture a diverse set of products including power transmission and distribution equipment, lighting systems, factory automation and control systems, and medical diagnostic imaging systems. The U.S. electroindustry accounts for more than 7,000 manufacturing facilities, nearly 400,000 workers, and over $100 billion in total U.S. shipments. We perceive intent of this guidance document is to clarify the testing and equipment authorization requirements for LED lighting devices. Our understanding from the document is that the FCC does not intend to look backwards at older legacy lighting technologies. NEMA agrees with this approach, given the substantial number of preexisting installations (i.e. interference is an enforcement issue) and their diminishing markets (i.e. little benefit compared to the resources needed to redesign and retest existing product). Additionally, the FCC’s proposed guidance appears to be modifying the testing and authorization requirements that are practiced today for LED products by reinterpreting their classification. If we are incorrect in these assessments, we request the FCC clarify so that we may comment more accurately to the issue. The most significant proposed change in practice for LED lighting devices is to include radiated measurements regardless of the operating frequency range or frequencies being generated in the device. The current published version of FCC 47 CFR Part 15 does not include a radiated emission limits for frequencies less than 30 MHz. The FCC has previously allowed an exemption for this radiated testing requirement if the highest frequency generated in the device is less than 1.705 MHz. The new proposed guidance would mean that all LED lighting devices would require radiated testing from 30 MHz up to 1 GHz regardless of their operating frequency and frequencies being generated in the device. Since many companies already chose to electively perform this testing, we believe that the proposal is reasonable. We urge the FCC to not undertake any additional requirements without a formal rulemaking process and greater scientific study. A concern that NEMA member companies expressed in our face-to-face meetings with FCC staff in April 2014 is that increasing stringency on lighting device interference requirements does not address whether manufacturers of those devices that may be interfered with are taking their own appropriate precautions in design and operation to increase their immunity to unintended interference. It is our understanding that the FCC has begun to address this by reexamining the definition of “harmful interference” in its technical advisory council. We request the FCC to pursue this discussion to completion as it complements the efforts of lighting device manufacturers to avoid unintended interference with spectrum license holder’s products and systems. NEMA reminds the FCC that, along with Electro-Federation Canada, we have expressed interest in working collaboratively with the FCC and Innovation Canada to examine the electromagnetic landscape of today’s grid with respect to lighting devices and how the evolution of spectrum use may have changed the needs of device testing and design with respect to reducing or avoiding harmful interference. We support scientific investigation of these phenomena and discussion on how they might be minimized in the future. We request the FCC support this collaborative approach to harmonized bi-national requirements. We look forward to working with you further on this important effort. If you have any questions on these comments, please contact Alex Boesenberg of NEMA at 703-841-3268 or alex.boesenberg@nema.org. Sincerely, Kyle Pitsor Vice President, Government Relations
  • Terry McGowan commented on 2016-01-08 18:08:36.81:
    A document with additional comments from the American Lighting Association is part of this comment. View attachment associated with this comment
  • Terry McGowan commented on 2016-01-08 17:44:35.523:
    Comments from the American Lighting Association included. View attachment associated with this comment
  • Ernesto Mendoza commented on 2016-01-08 15:51:31.31:
    See attached file View attachment associated with this comment
  • Ernesto Mendoza commented on 2016-01-08 15:49:46.273:
    See Attached file View attachment associated with this comment
  • James Lester commented on 2016-01-07 12:15:47.546:
    Attached in PDF forn are my comments. Regards, James Lester View attachment associated with this comment
  • Edward Yandek commented on 2016-01-06 21:50:41.79:
    See attached PDF Document. Comments from Edward Yandek LLC Dated and Submitted January 6, 1016 re LED Lighting Guidance Document for KDB Publication. Edward Yandek LLC View attachment associated with this comment

Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.