That makes sense as a reading. Thanks. I just know that as someone who has briefly looked into very small scale manufacturing of amplifiers I would basically have to do it without specifying power (or give a specification that is misleadingly low about how loud the amp was) given my discomfort with the legal threshold this rule creates.
That's contradictory. A manufacturer can't comply with a regulation demanding that it meet deliver "full power" across a frequency range without testing that shows it can do so. If they could comply by just claiming it does so, the regulation is meaningless. Nevermind the possibility that third-party testing might show that it does not in fact comply would mean opening themselves up to liability.
So how about this fact. FTC regulations mandates THD+N specification but never says how that is supposed to be measured. As you well know, the measurement bandwidth is critical to proper THD+N measurements. The more the bandwidth, the more noise and distortion is captured in THD+N. And it is not just you and I that insist on knowing the bandwidth, but here is Audio Precision itself: https://www.ap.com/blog/thd-and-thdn-similar-but-not-the-same
Cause probably the companies failed to meet the ONE instance you're allowed to unlock the vault and let engineers loose out there.
Or not understood. This is why standards are vetted by standards committees filled with technical experts, and one difference that I keep harping on between a standard and a regulation (which keep getting conflated despite being very different animals).
"Should" is a different animal than "is."
There was a period of time for comments, and many of us here as well as elsewhere made comments, but as @SIY said regulations are not necessarily vetted like a technical standard would be. There was a thread here on ASR with some folk commenting who knew the FTC person(s) involved, and they were pretty overwhelmed. My impression was one or two technical types, who may not have had a lot of experience in the amplifier design area, and then the bureaucrats wrote the final rule based on what they think the technical part means. It is pretty clear there was insufficient knowledge and/or attention paid to specifying the rule in a manner consistent with engineering practice and testability.
I've been in some technical standards groups and they are not the sort of environment where policy makers and lawyers hang out. It can be grinding work. If there is a dominant manufacturer they tend to dominate (and it can be tough gainsaying them if they are wrong). If there are several dominant manufacturers, it can be a bit of a carve up. Sometimes manufacturers develop pre-standard equipment and it's in their interest to get the standard to look as close as possible to their implementation (so changes don't require new silicon or boards). Despite all the hard work, it's often common for something that seemed obvious in the planning phase is completely misinterpreted in the field; simply due to poor wording.
I agree with most of that, but the Standards with which I have been involved were very connected to the real world, often had very rigorous math and such as well as (reasonably) well-defined practical test procedures, and included empirical data as part of setting the standard. But they may have been outliers; IEEE ADC and DAC Standards, OFC, PCIe, and SAS were the ones I have worked with the most and most recently. I do agree major manufacturers often drive industry standards, hard to avoid for a lot of reasons, good and bad. There were some that were pretty loose, though not as bad as this current FTC rule, but standards driven by industry in my experience (albeit limited compared to the world at large) were much better defined and clearer than the regulations applying to the same products. Some standards are loose, HDMI being a prime example of an interop mess, and some regs are very tight for things like laser emission and some electrical codes, but IME most standards are much better defined than most regulations.
I personally ignored it. The headline at the time was FTC abandoning the regulation. Since I knew they had no enforcement resources, I didn't care either way. I was surprised to see that it not only got revived but changed the original requirement into something impractical. I would have never thought that the government would make ad-hoc changes like this, simply through comments sent in by random folks/entities.
I find it interesting that blame is being raised about the industry and its associations now. You also had the opportunity to send in comments and share your perspective. Wouldn’t you also be considered part of that industry and its associations?
I'm not saying manufacturers shouldn't test, but they could technically avoid it if they chose to. As long as their engineering and simulations are reliable enough to determine an FTC-rated power output, they can still comply with the regulation without direct testing.
Industry and trade organization members have companies that pay their salaries. Such regulations determine their success in the marketplace. I qualify as neither. My future doesn't depend on what FTC does or doesn't do.
It is but in this case, I am bringing significant experience from when I was in the industry and drove many associations, standards, patent pools, licensing and regulations. We didn't drink water under my watch without managing this aspect of the business. It is on that basis that I say organizations such as CEA/CTA were sleep at the helm. As were major consumer electronics companies. This is partially excused because they like me, know that the FTC is a paper tiger when it comes to such regulations. But some blame must be accepted on their front.
If there are multiple ways, then the results cannot be compared to each other, defeating the very goal of the regulation.
Nothing about them ignoring FTC regulation makes them dishonest. They simply don't care about a regulation that is a) completely broken and b) won't be enforced anyway. That is what I would do if I were in their shoes. There are countless companies I suspect that don't even know about this ruling let alone want or not want to do anything about it!
No company with inside or outside attorney advising them would let them do what you say. Please don't make up nonsense like this. Simulations? Give me a break....
In the same comment, you're referencing authority while also stating that you're not part of the industry. If you believe you could have provided the FTC with valuable insights, perhaps you should have. "With great power comes great responsibility" -Uncle Ben
.No, that’s incorrect and a significant misrepresentation of my words.
Deliberately choosing not to follow regulations is deceptive.
I was simply addressing those, like you, who interpret the text as requiring testing at all frequencies between 20 Hz and 20 kHz.
