I'm guessing most people wouldn't even know to complain these days if theirs or 
their neighbors dishwasher started interfering with their TV or radio.

And TV's with their cable/internet/satellite connections and FM/satellite 
radios are a lot more immune to that stuff as well than 40 years ago. 

So I wouldn't be surprised if the rules don't change either.  Bigger fish to 
fry as they say.

-Dave 

-----Original Message-----
From: Ted Eckert [mailto:[email protected]] 
Sent: Wednesday, August 27, 2014 9:14 AM
To: [email protected]
Subject: Re: [PSES] construction machinery in USA

The rules made sense when they were drafted. Forty years ago, a dishwasher 
wouldn't have digital electronics and it would be unlikely to cause 
interference in receivers located more than a few meters away. The same 
dishwasher would be very loud during operation and you wouldn't be able to 
listen to the radio or TV in the kitchen where that dishwasher was operating. 
This was the rationale for many home appliances. The rules just haven't kept up 
with the changes. We now have appliances full of digital electronics and they 
make very little acoustic noise when operating. However, unless there are a lot 
of complaints to the FCC, the rules likely won't change.

The United States has a history where people in denser residential 
environments, where you are more likely to be affected by a neighbor's 
appliance, are in larger cities where most commercial radio and television 
transmitters have stronger signals. In areas with fringe reception, people 
historically lived in single family housing that was spread out. The risk of 
being affected adversely by somebody else's appliance was lower.

If my understanding of history is correct, we may even have the existence of 
the 2.4 GHz ISM band due to radiated emissions from microwave ovens. They 
operate at 2.4 GHz, and the early versions were a bit leaky. I've heard that 
this frequency was so polluted with noise in residential environments that it 
wasn't adopted by anybody for a specific purpose leaving it open to ISM 
applications.

Ted Eckert
Compliance Engineer
Microsoft Corporation
[email protected]

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

-----Original Message-----
From: Jim Hulbert [mailto:[email protected]]
Sent: Wednesday, August 27, 2014 4:59 AM
To: [email protected]
Subject: Re: [PSES] construction machinery in USA

A sidebar here.  FCC Rules also exempt "A digital device utilized exclusively 
in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air 
conditioner (central or window), etc.".  These devices not only can be operated 
but are expected to be operated in residential areas.

Rules don't always  make sense.

Jim Hulbert

-----Original Message-----
From: T.Sato [mailto:[email protected]]
Sent: Wednesday, August 27, 2014 6:20 AM
To: [email protected]
Subject: Re: [PSES] construction machinery in USA

On Wed, 27 Aug 2014 00:26:23 +0000,
  Ted Eckert <[email protected]> wrote:

> The FCC is generally not concerned with unintentional emissions from 
> construction machinery. The general assumption is that a susceptible 
> receiver would not be operating in close proximity to the construction 
> equipment. It may no longer be a correct assumption, but that is the 
> basis. It will likely be true in some cases. I can't imagine a 
> Caterpillar 797 operating in a residential area. However, smaller 
> pieces of machinery might be used closer to susceptible receivers. The 
> rules have not kept up with technology and they are based on a time 
> when the most significant ignition source in a vehicle was the 
> distributor and when digital electronics did not exist in construction 
> equipment.

Actually I guess so, but couldn't find the fact and the rationale.
I also sent an inquiry about this to FCC, but had no response at this time.

> The general assumption is that a susceptible receiver would not be 
> operating in close proximity to the construction equipment. It may no 
> longer be a corre ct assumption, but that is the basis. It will likely 
> be true in some cases. I can't imagine a Caterpillar 797 operating in 
> a residential area. However, smal ler pieces of machinery might be 
> used closer to susceptible receivers. The rul es have not kept up with 
> technology and they are based on a time when the most significant 
> ignition source in a vehicle was the distributor and when digital 
> electronics did not exist in construction equipment.

Well, in the good old days, heavy machines were driven by diesel engines with 
no ECU, those arms were driven by oil pressure through manual valves and they 
usually don't have any electronic circuit, so I risk of EMC problems should 
negligible.

However, these days, heavy machines may be equipped with electric/ electronic 
circuit including microprocessors, control circuits, inverter driven electric 
motors, sensors, etc., which can cause electromagnetic emission/immunity 
problems.
Also, such heavy machines (smaller ones, if not Caterpillar 797!) may be used 
also in/near residential areas.

General vehicles are still explicitly exempted by 47 CFR 15.103(a) and 
industrial machines are usually exempted by 47 CFR 15.103(b), but I couldn't 
find any exemption applicable to heavy machines in general.

This raise me the question.

> That being said, I'm not an expert in automotive EMC and I encourage 
> anybody with better information to amend or correct what I have 
> stated. (I would also like to know how you would run testing on a 
> Caterpillar 797. I don't think it would fit in many chambers.)

If international standards are accepted, I think we can measure those emissions 
with CISPR 12 test method.

Regards,
Tom

--
Tomonori Sato  <[email protected]>
URL: http://homepage3.nifty.com/tsato/

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Website:  http://www.ieee-pses.org/
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