On Fri, 22 Feb 2019 14:39:46 +0000,
  Jim Hulbert <[email protected]> wrote:

> Yes, FCC requirements for this type of equipment are not very practical.    
> As a side note, such large equipment is industrial in nature, which may lead 
> one to believe they would fall under FCC Part 18 for ISM instead of Part 15.  
>  However, Part 18 only covers industrial equipment that generates and locally 
> uses RF energy for the production of physical, biological, or chemical 
> effects.  An industrial machine that does not utilize RF energy for these 
> purposes is not within scope of Part 18, and so Part 15 applies.

I guess large industrial machines which will not fall under Part 18
may often be exempted from Part 15 (except for general conditions of
operation), especially due to 47 CFR 15.103 (b) or (c).

If the machine can't be exempted, although in-situ radiated emission
measurement can be very difficult, I think we need to measure them
in-situ individually at least for first three installations.

Regards,
Tom

-- 
Tomonori Sato  <[email protected]>

> From: John Woodgate [mailto:[email protected]]
> Sent: Friday, February 22, 2019 3:05 AM
> To: Jim Hulbert <[email protected]>; [email protected]
> Subject: **External**Re: [PSES] FCC Part 15 Testing in Situ
> 
> 
> Such very large equipment tends to be custom-designed, so three identical 
> installations never exist. Even if there are three identical installations, 
> they are unlikely to be completed simultaneously, so how can the first two be 
> legally operated before the third is installed and tested?
> 
> I wonder if FCC needs to look again at this requirement.
> 
> Best wishes
> 
> John Woodgate OOO-Own Opinions Only
> 
> J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>
> 
> Rayleigh, Essex UK
> On 2019-02-21 20:48, Jim Hulbert wrote:
> Equipment that is covered under FCC Rules Part 15, but which is too large to 
> test on an open area test site, can alternatively been tested in situ.  
> However, the rules state that the test should be performed at 3 different 
> representative installations of the equipment.  Does anyone on this forum 
> have experience doing this?  I would expect conducted emissions to be 
> reasonably similar, but I can see how environmental influences could result 
> in 3 different sets of radiated emissions data.  How do you make sense of the 
> data?
> 
> Jim Hulbert
> 
> 
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