Sorry I wasn't very clear.  I was speaking about the US FCC government 
requirements.  In the US, automotive requirements are private industry 
standard, exempted from FCC reg's, and the automotive industry can and does 
grant a "pass" on a device that they need or want - it's a non-government issue.
FDA regulates immunity for medical devices for a patient safety perspective.  
The US military has their own immunity standards, MIL-SPEC, and there are the 
usual safety standards to deal with.  
And few of the tests are the same.
So as the US Congress gets interested in Toyota and the safety issues that have 
arisen, then the US Congress just might authorize the FCC to regulate the US 
auto industry, especially for immunity.
What standards they might apply would be interesting, or would the FCC make up 
a new one?
Would the break points by at 80 MHz, 100 MHz, 230 MHz?  Would they be lower? 
and higher?
The US government regulations, FCC, have left Immunity up to market forces so 
far.  The product fails, no sales.  The consumer has to be aware of what he is 
buying, otherwise known as the "awareness tax".
Toyota seems to be aware of this effect is really trying to market themselves 
out of the reputation damage they have suffered.
 

 
- Bill
In the event of a national emergency, click on the following links to provide 
directions to your duly elected mis-representative.

http://www.usa.gov/Contact/Elected.shtml
or...
https://writerep.house.gov/writerep/welcome.shtml
http://www.senate.gov/general/contact_information/senators_cfm.cfm 


________________________________

From: Derek Walton <[email protected]>
To: Ken Javor <[email protected]>
Cc: "[email protected]" <[email protected]>
Sent: Wed, March 10, 2010 12:00:56 AM
Subject: Re: Radiated Immunity

I'd just like to enforce Kens comment. We have been running tests like the the 
NEMA showing arc tests for as long as I can remember being in the USA. That is 
one wicked test!

Derek Walton
L F Research

On 3/9/2010 10:41 PM, Ken Javor wrote: 

        The statement that, “But Immunity is still a non-USA concern, which 
might change with the toyota debacle since it involves significant safety 
concerns,” is not true.  The automotive industry has been performing 
susceptibility testing and qualification at levels commensurate with military, 
not commercial environments, for decades. 
          
        Ken Javor
        Phone: (256) 650-5261
        
        
        
________________________________

        From: Bill Owsley <[email protected]> <mailto:[email protected]> 
        Date: Tue, 9 Mar 2010 19:15:39 -0800 (PST)
        To: Ken Javor <[email protected]> 
<mailto:[email protected]> , "[email protected]" 
<mailto:[email protected]>  <[email protected]> <mailto:[email protected]> 
        Subject: Re: Radiated Immunity
        
        As I recall, Pate, German, and Smith came out with the NSA +/- 4 dB 
paper in 1982.  The FCC had been using tuned dipoles at 3 meters for Class B 
and 10 meters for Class A for quite awhile, but would accept "other" antennas 
if properly corrected for.  Any dispute would be settled with tuned dipoles at 
the above spec'd distances.  Why 30 MHz? tuned dipoles any bigger (lower freq) 
were too delicate and broke often, if you could find any sources.  They often 
had fixed section with a tunable end piece for a band.  And try to scan a 30 
MHz dipole in vertical...
        We had 3 meter pre-compliance chambers for frequency identification and 
measured at 3 and 10 m on the OATS for compliance data, until we got the first 
FCC recognized 3 meter chamber as an alternative test site done.  And then we 
used the distance correction factor for Class A.
        But the various EU standards in effect then only accepted 10 meter 
data, not corrected but measured, so we either measure at the OATS or sent it 
out, until we built the 10 meter chambers.  We did have a couple of 30 meter 
chambers at other locations, and I thought they were big until I stepped into a 
full size automotive SAC.  I've been in what has been said to be the worlds 
biggest, but I don't count military chambers in comparisons with civilian 
chambers.
        Another rational used by one of the FCC engineers ran along the line of 
3 meters is a SWAG for common house/apartment dimensions and 10 meters is 
common for office, commercial, etc.
         
        Why are the EU standards different than the FCC?  It has taken many 
years of negotiation and compromise to get as close as they are today.  But 
Immunity is still a non-USA concern, which might change with the toyota debacle 
since it involves significant safety concerns.  Why might the USA not be 
interested in immunity?  Could be the reciprocity mentioned in another email - 
'what can get out, can also get in', but the USA counts on market forces to 
handle quality issues instead of standards to test for a minimum level of 
"quality" or immunity.  Why the conducted to radiated break at 80 MHz?  Some 
standards run the conducted up to 230 MHz.  Some equipment will handle up to 1 
GHz conducted testing.
        The 80 MHz radiated start may well be due to the calculations (theory) 
of getting a 0,+6dB "plane" wave over 16 points in a chamber, with affordable 
power amps.  Not many of us can put a quarter million watts, or more, of RF 
power into a chamber to get the required field strength.
         
        
         
        - Bill
        In the event of a national emergency, click on the following links to 
provide directions to your duly elected mis-representative.
        
        http://www.usa.gov/Contact/Elected.shtml
        or...
        https://writerep.house.gov/writerep/welcome.shtml
        http://www.senate.gov/general/contact_information/senators_cfm.cfm 
        
        
        
________________________________

        From: Ken Javor <[email protected]> 
<mailto:[email protected]> 
        To: "[email protected]" <mailto:[email protected]>  <[email protected]> 
<mailto:[email protected]> 
        Sent: Tue, March 9, 2010 1:19:39 PM
        Subject: Re: Radiated Immunity
        
        The RE measurement starting at 30 MHz is based on the ability to use a 
tuned dipole at three meters and have reasonable repeatability (NSA +/- 4 dB).  
30 MHz is as low as you can go.
        
        Phone: (256) 650-5261
        
        
        
________________________________

        From: "Pettit, Ghery" <[email protected]> 
<mailto:[email protected]> 
        Date: Tue, 9 Mar 2010 10:13:32 -0800
        To: "[email protected]" <mailto:[email protected]>  
<[email protected]> <mailto:[email protected]> , "[email protected]" 
<mailto:[email protected]>  <[email protected]> <mailto:[email protected]> 
        Conversation: Radiated Immunity
        Subject: RE: Radiated Immunity
        
        Conducted immunity is done up to 80 MHz in place of radiated immunity.  
It is difficult to generate a uniform field at lower frequencies in the space 
available in a typical lab with reasonable power requirements for the 
amplifier.  As to why the break point for radiated emissions is 30 MHz?  To 
quote Tevye, “Tradition!” 
         
        
        Ghery S. Pettit
        
        
        From: [email protected] [mailto:[email protected]] On Behalf Of 
[email protected]
        Sent: Tuesday, March 09, 2010 7:13 AM
        To: [email protected]
        Subject: Radiated Immunity
        
        
        Can someone tell me why the Radiated Immunity testing is conducted from 
80 Mhz to 2 Ghz while Radiated Emissions is conducted from 30 Mhz to 1 Ghz (or 
5th harmonic), i.e. why the gap from 30 Mhz to 80 Mhz for Immunity?
        
        
        
        Robert Hanson
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