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 XI

There is a real need in the TV/Video Games Industry for a better understanding of how it should relate to the FCC. There seems to be a growing feeling throughout the Industry that casts the FCC in the role of an antagonist. Within a particular company, that feeling intensifies whenever their effort to obtain the FCC's Type Approval of their product fails, and production is stalled. On the other hand, the FCC is operating under a set of Rules and Regulations which are, in some instances, rooted in antiquity or built on obsolete technical foundations. Neither side views this situation as desirable, but at least one side can move to improve it: The TV/Video Games Industry!

There are two sections in Part 15 of the FCC Rules and Regulations which pertain to TV games: Paragraph 15.7 covers those games which do not utilize the RF front-end of a television receiver, but rather feed the basic sync and video signals directly to deflection and video amplifiers. These types of games will be referred to in this paper as "video games." Paragraphs 15.401 through 15.423 (also referred to as "Subpart H") pertain to those games (which we will refer to as "TV games") that generate a modulated RF carrier on one of the VHF TV channels. This RF carrier is then fed into the front end of a standard TV receiver. The distinction between these two types of games is important from the FCC's standpoint for two reasons: First, the technical Regulations are somewhat different. Second, the FCC has no record of any actual interference problems occurring from the use of TV games, but they do have records of interference conditions, some of them potentially serious, which have been caused by video games. (This has been a factor in the generation, by the FCC, of a "Notice Of Proposed Rulemaking", NRPM, which changes the video game radiation and test procedures, and adds a requirement to test the levels of electromagnetic energy on the ac powerlines. See FCC Docket No. 20780.)

The question the TV Games Industry should be asking at this point is, "Are these two areas of Regulation reasonable?" Unfortunately, neither we nor the FCC really know. The Industry has a great deal at stake here. Are we being burdened by unnecessarily severe electromagnetic emission restrictions? On the other hand, if the requirements are not strict enough, the Industry stands a good chance of acquiring a bad name as the result of numerous electromagnetic interference (EMI) problems. We could even be the victim of congressional over-reaction if the problem became severe enough.

The Computer and Business Equipment Manufacturers Association (CBEMA) recognized this potential problem some time ago. They took positive steps to forestall the imposition of unrealistically stringent Part 15 requirements on such things as computers and business office equipment by the establishment of a subcommittee to study potential Stephen Beck, game consultant.