At a former employer, I took the approach that this exemption is applicable
ONLY when equipment is kept *by a public utility* within its own facility. 
Some made the argument that the exemption is available for utility company
vaults and rooms inside customer buildings. I see where that interpretation
might be made, but I think the INTENT of Part 15 requires this be evaluated
case-by-case. In any event, relying on the exemption in all circumstances
could in the end cost more than any cost edge from ignoring EMI/RFI.

The logic of the exemption, so far as I have been able to tell, is that
equipment operated by a utility (which nowadays includes much more than Ma
Bell and the Electric Company) in its own site creates interference that is
not a problem for the public, and if tolerable by the user, is tolerable by
the Commission. This does allow economies to be achieved in design IF the
building, facility, vault, cabinet or room can provide shielding and
filtering lacking in equipment.

However, adding that shielding and filtering AFTER installation can cost in
the end more than quiet equipment.



Cortland Richmond

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