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 EMI problems, measurement techniques, and reasonable limits. A report was then issued by the subcommittee, primarily for the purpose of presenting recommendations to the FCC as to what, in their view, constituted a reasonable set of requirements. It is most important to observe that their recommendations were backed up by extensive research and a resulting rationale which was extremely thorough. That the FCC really does listen to and consider such inputs is evident from the following quotation from their NPRM, Docket No. 20780. In the section dealing with proposed changes to Paragraph 15.7, which governs video games, the FCC states that:

"....there is reason to believe that the proposed technical requirements may still be too stringent for many commercially operated computers and Data Processing Equipment (DPE). This is based on several considerations. One is an interim report released by the Computer and Business Equipment Manufacturers Association (CBEMA) on 'Narrowband RF Emanations from Electronic Data Processing Equipment and Office Machines'.... For these reasons, the Commission is willing to entertain an alternative proposal.... if sufficient justification is provided. Information dealing with all aspects of the operation and interference potential of this equipment is solicited. In particular, information with respect to the following questions is sought:

(1) What levels of emissions from computers exist today?

(2) If the proposed limits are not acceptable .... what would be reasonable alternative limits?

(3) What equipment should be subject to these limits? ....

(4) How would the limit be applied to a system comprising a number of units interconnected by cables, etc.?

(5) How would measurements be made to determine compliance with the limits? ....

(6) What restriction should the Commission place on the manufacturer as a precondition for marketing to ensure compliance?"

The CBEMA Report recommends limits for electromagnetic radiation and powerline emissions which are somewhat more lenient than those the FCC is proposing. A final decision (i.e., issuance of a "Report And Order Amending The Rules") is yet to be made by the FCC. Because of our recent arrival on the scene, and since the rulemaking process is well along, it is unlikely that the TV Games Industry can affect the outcome to any great degree. We will probably have to live with whatever form Paragraph 15.7 takes for some time to come. However, the important Subpart H, which deals with TV games, is another matter. But before we get into that, let us look at the Industry's present situation from the standpoint of their efforts to design their product so as to gain Type Approval.