Responding to the FCC 19-226
Issue #3: How should the FCC regulate Wireless Power Transfer (WPT) technologies that can remotely charge devices while the user is in motion?
Synopsis of Paragraphs 141-143 - The agency asks how it should consider the implications of wireless power transfer at distances greater than 50cm, since charging at a distance can create an RF field in three dimensions, with a varying beam shape depending on product design. What parameters should be used in considering this issue?
Our Analysis: Manufacturers are designing and testing a new generation of charging sources that can remotely charge your phone or tablet from across the room at home, in an office or a car.
Currently, devices can be charged using stationary charging "pads" where there is almost direct contact between the charger and the device. New technologies will beam power through homes and workplaces, allowing multiple devices to be charged while the users are stationary or in motion. The antennas directing such beams of energy will be variable and directional, using beam-forming technology to detect both devices and any possible obstructions.
The idea of never having to plug in your phone again to charge it will certainly excite consumers. But what are the implications of charging a phone remotely (wirelessly) as you carry it around on your body? How might this impact infants or children who might be in the way of the power beam? How might the elderly, those with compromised immune systems or implanted medical devices be impacted as electrical currents are beamed through the air?
Is the FCC developing human exposure guidelines to accommodate the capabilities of manufacturers, or determining safe levels for humans which manufacturers must then meet? And are we ready to trust manufacturers to make their products safe and be able to somehow detect obstructions (like other humans) and power down on their own? Or will they instead design products that work, and not worry about any health effects, which has historically been their course of action.
Sample Comment: I recommend that before the agency considers even tentative approval of WPT devices operating at ranges in excess of 5o cm, it requires manufacturers to conduct pre-market testing to demonstrate the safety of such devices when used in all possible “worst case” scenarios, including mitigation techniques to avoid inadvertent or collateral damage to the public. Such an analysis must include consideration of biological impacts.
The issues here are very significant. How will this impact an older person with an implanted cardiac pacemaker who uses a remote charger to charge his cell phone while he is moving around with the phone in his shirt pocket? Or consider the couple trying to get pregnant if the man's phone is frequently being charged wirelessly in the front pocket of his pants, with the beam irradiating his testicles?
What kind of human is the FCC considering protecting? What size, shape, age, and with what kind of underlying medical problem or weakness? I urge the agency to consider updating its standard anatomical models to reflect the wide variety of possible users.
Insert any comment here about a personal situation regarding wireless power transfer. If you include links to scientific studies please state the following: “Links hereby incorporated by reference” to ensure that the study becomes a part of the record. To submit a PDF of the study itself, please use the standard comment form that allows attachments to be uploaded along with your comment, not the Express comment form.