Hello Gary
Overall I think that your interpretation is convenient rather than factual, sorry:
***You said: Simon Kohler indicated in his Model Rail interview that European EMC is not recognised in the United States as a legal requirement there. He also indicated that the NMRA appear not to recognise EMC either.
REJ: No, he said that the NMRA didn't seem to acknowledge CE - he was wrong, and if he had actually read the standard he would have known that he was.
***You said: The use of "and/or" is ambiguous and implies options. One or the other or both. American FCC standards are lower than European CE standards as they relate to EMC. It would be easier to meet the American FCC standard. Whilst there appear to be assurances made by the NMRA or their representative that manufacturers are aware of their obligations in this regard in order that they may claim that equipment is compliant with local regulations in whichever market they supply to, the NMRA do not police this or carry out any form of spot checks.
REJ: No, its not ambiguous at all.
I have been intitately involved with CE type issues for nearly 20 years, and directly with CE for about half that.
ALL countries and all industries and all regulations put the onus on the manufacturer or distributor to ensure that their products comply. It is proimarily a self regulation regime by design even at CE level. NMRA state the Standards clearly, state any requirements that are product category or class specific and add the over blanket of the need for local emissions compliance.
NMRA have no policing ability but its is NOT an option if the product is to be marketed in a country - its up to the Mfr to ensure the product will comply, and up to either the Mfr or the ;ocal distributor to gain local approval.
All this ignores the fact that the standards were actually created primarily by EU based mfrs before they were adopted by the NMRA and so were primarily written so that DCC product would also by default comply with FCC or CE if it met the standards. That is why a clean square wave is important, among other things.
***You said: "And what about American grey imports into Europe?
REJ: What about them: Just blowing smoke in this question I'm afraid... The issue is Hornby, and only Hornby as far as this thread is concerned. Whether other brands do or do not, it won't make hornby any different.
You Said: As an example it does seem very odd that one minute the Guagemaster Prodigy won't work with Hornby Digital and all of a sudden a new updated version is released in the UK which will
REJ: Wrong example: Gaugemaster = MRC Prodigy etc. They started upgrading units in USA long before the hornby existed - and it was primarily becasue of a wrong implementation of function operation code plus other operational problems that needed to be sorted. Like Hornby they had gone their own way and the market demanded they did it right. They statred with an upgrade programme for existing products long before the H issues surfaced.
***You Said: When it comes to the NMRA DCC standard for the signal wave there is only one acceptable waveform. This part of the standard has not been modified since 1994 it would seem. Yet the European CE regulations have been modified significantly since this date. This may have been the point Simon Kohler was making in his interview and if it was he could have made it clearer.
REJ: Nonense: The standard was written to meet all applicable regulations. The degree or basic levels aren't moving, the paperwork and test procedures do change, but the standards regime is not really different in scope or levels/degree. NOTHING will make the Select waveform correct - especially as by its very nature it will always do worse in CE tests than a pure square wave which is what it should have been!
***You said: The NMRA standard appears not to keep up with legislation outside the USA and to accomodate regulation as it changes if this is indeed the case.
REJ: There has been no need to change the NMRA spec: It clearly states that the units must pass standards in countries they are marketed in. Changes in CE paperwork don;'t change this which is a clear statement, not subject to convenient interpretation.
***You said: What I would say is that Stan Ames in his book "Digital Command Control" does make reference to circumstances where non standard signal waves may be required and does suggest that the NMRA can be accomodating. That is how I read what is said by Stan.
REJ: I'm pleased you quoted Stan. What he said in a public forum was "The hornby select is not fit to be sold and its waveform is so bad that it really should not be called DCC. His comment about the hornby decoder was also as damning. Search the archives of DCC-UK to find his posts and read them in full.
Off list, Stan also sent me a code readout of the hornby decoder vs the standards (the same check that NMRA uses). It failed on all key points, including easily satisfied and critical points like the correct implementation of the basic and compulsory CV 29.
***Yous aid: On the waveform question asked earlier, I - etc etc etc
REJ Gary, why do you act as it you are Hornbys spin doctor. Its not open to interpretaion, guess, crystal ball gazing or anything else. There is a standard and a need, it doesn't meet it. Period! You cannot futureproof a product by making is incompatible with the very market its sold in, then blaiming all other product for its problems
***You said: Hornby seem comfortable that the Elite will receive an NMRA certificate of compliance.
REJ: It may do eventually - not yet though, there are still some monir gliches they can easily fix though. I sincerely hope it DEOS end up conformant.
***You said: They also claim that the Select is compatible (works) with all European control equipment out there. There is little evidence to suggest otherwise.
Nonsense, there is reams of evidence to the contrary on my own test bench it destroyed 2 lenz gold minis, made significant programming errors and generally caused significant layout problems such as renumbering lots of loco's all back to 3 when there was a momentry short.
The Selct waveform is guaranteed to damage decoders. 60 plus volts peak to peak is not explainable, sorry.
You said: Select issues seem to arrise with American equipment.
REJ: That same american equipment is well respected, reliable and works extremely well with all other EU made and US made products. ONLY the select has problems with it. Surely that tells you something that doesn't need ANY further comment or explanation.
You said: Richard mentions that the views are based on 2 Hornby consoles that have been examined.
REJ: Actually much more than two, but only tweo placed on the oscilliscope to prove the first one wasn't just faulty: Many usits trialled in several countries, all exhibiting the same problems is the reality.
You asked: Has the Elite been examined yet
Its being looked at - its better than select, but not yet perfect. It has all the makings of an excellent unit with some good features. Its ha nothing unfixable and I'm certain hornby will get this one right soon. strangest problem is a semi incompatibility with Select
Gary: Lets not turn this into a nagging set of emails. Lets simply allow others read the two articles side by side and make up their own minds...
Regards
Richard
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