DSL on residential buildings.

2002-03-20 Thread georgea



Your comments remind me of how FCC limits began a few decades ago.
As many may recall, in the days before "real" PCs, Playstations and the like,
Coleman and others began marketing ping pong games one could play on
their TV set.

Since TVs had no direct inputs at the time, the small game box fed VHF signals
to the TV antenna inputs, which were demodulated within the TV.  The user was
directed to remove the TV antenna leads to do this.

However, it was not uncommon for a consumer to leave both the antenna and
game leads attached to the TV.  When the game was tured on and played,
faint images of ping pong balls and paddles were transmitted via the outside
antenna to neighbors' TV sets, prompting compliants.

Due to this and related phenomena the FCC created EMI limits for digitally
clocked systems employing a 10kHz clock or higher.  You know the rest of the
story.  Oddly, our many electrical appliances not involving digital controls are
not regulated, and create most of the EMI in a typical household.

George



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Re: DSL on residential buildings.

2002-03-20 Thread Cortland Richmond


We agree. The "gray area" arises from the fact that
"residential" is not strictly defined. When the
distinction was first made in subpart B, it hinged on
whether equipment was sold for use in the home, not
whether it was installed close to a home or farther
away.

I take the position that the need may be defined by
whether the field strength from a class A device would
be above the Class B limit at or inside a residential
property. 

Whether Class B is enough is debatable. It is certainly
not enough to protect non-broadcast communications,
where received signals may be less than 20 dBuV/m.

Cheers,

Cortland


On Wednesday, 20 Mar 2002, Hans Mellberg  wrote

>I may have gotten in on the tail end of the dicussion, but
>here is my take on residential DSL.

>The FCC rules are quite clear on equipment marketed to
>residential environments, Class B. The DSL equipment
>being sold to residences must comply with class B
>limits notwithstanding office use.

>small, non-rack mounted routers and switches are probably
>still being argued as class A devices although most major
>mfg make them already as class B. Eventually, when a lot
>of homes incorporate hubs and routers then those will
>also have to be class B.

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Re: DSL on residential buildings.

2002-03-20 Thread Hans Mellberg

I may have gotten in on the tail end of the dicussion, but here is my take on
residential DSL.

The FCC rules are quite clear on equipment marketed to residential environments,
Class B. The DSL equipment being sold to residences must comply with class B 
limits
notwithstanding office use.

small, non-rack mounted routers and switches are probably still being argued as
class A devices although most major mfg make them already as class B. 
Eventually,
when a lot of homes incorporate hubs and routers then those will also have to be
class B.

--- Cortland Richmond <72146@compuserve.com> wrote:
> 
> The reason for the Part 15 residential (Class B) limit is to protect
> reception, and the levels prescribed are (arguably) low enough to do so. If
> we allow higher levels, we are asking for service calls and perhaps
> official attention. But (unless I am mistaken) it is now the USER who
> responsible for interference generated by his Class A devices, and it's
> perfectly legal for us to sell them to him.
> 
> I recently spent some years working for a company that makes telecomm
> equipment. I there encountered for the first time the "telco" point of view
> (which is probably not uncommon). In the telephone world, the service
> provider is responsible for everything up to the network interface.
> Everything beyond that is the responsibility of the customer. Therefore,
> some people assume that equipment installed prior to the NIC can be, and
> should be Class A for Part 15. I have argued, with success, that this is an
> error with potentially expensive consequences.
> 
> Part 15 contains an exemption for equipment located within a facility -
> even just a locked room, cabinet or vault - controlled by the telco. There
> is an argument, which I make, that when we do this in a residential
> building, if we are NOT Class B compliant, we may wish we had been. (Even
> Class B is often not enough, and I have seen equipment meant for customer
> use whose specification was well below the FCC limit.) And though our
> employers' products may comply with Part 15 we are still liable for harmful
> interference.
> 
> However, emissions may be suppressed by other means than installing only
> Class B equipment and this is often the way to go. The utility exemption
> does make this easier.
> 
> I personally believe that one may make a case for the mechanical room being
> Class A. It often contains furnaces, motors, and many other unregulated
> devices which generate high levels of radio and television interference,
> and to impose a stricter standard on telecom equipment in the same place
> seems a bit of a reach.
> 
> But look at the environment! Will emissions reaching a customer location be
> above the Class B limit? If so, then I would say due diligence requires
> suppressing them further.  A vault in a steel reinforced building's
> basement is a different matter than a rooftop utility hut with TV antennas
> just 3 meters away. If deployment entails a wide range of installations,
> then it is probably best to suppress all of it to Class B, rather than
> install Class B retrofit kits on a case-by-case basis. This is a decision I
> believe has to be made when the product is proposed.
> 
> 
> Regards,
> 
> Cortland Richmond
> (unemployed, and looking)
> 
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=
Best Regards
Hans Mellberg
Regulatory Compliance & EMC Design Services Consultant
By the Pacific Coast next to Silicon Valley,
Santa Cruz, CA, USA
408-507-9694

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Re: DSL on residential buildings.

2002-03-15 Thread Cortland Richmond

The reason for the Part 15 residential (Class B) limit is to protect
reception, and the levels prescribed are (arguably) low enough to do so. If
we allow higher levels, we are asking for service calls and perhaps
official attention. But (unless I am mistaken) it is now the USER who
responsible for interference generated by his Class A devices, and it's
perfectly legal for us to sell them to him.

I recently spent some years working for a company that makes telecomm
equipment. I there encountered for the first time the "telco" point of view
(which is probably not uncommon). In the telephone world, the service
provider is responsible for everything up to the network interface.
Everything beyond that is the responsibility of the customer. Therefore,
some people assume that equipment installed prior to the NIC can be, and
should be Class A for Part 15. I have argued, with success, that this is an
error with potentially expensive consequences.

Part 15 contains an exemption for equipment located within a facility -
even just a locked room, cabinet or vault - controlled by the telco. There
is an argument, which I make, that when we do this in a residential
building, if we are NOT Class B compliant, we may wish we had been. (Even
Class B is often not enough, and I have seen equipment meant for customer
use whose specification was well below the FCC limit.) And though our
employers' products may comply with Part 15 we are still liable for harmful
interference.

However, emissions may be suppressed by other means than installing only
Class B equipment and this is often the way to go. The utility exemption
does make this easier.

I personally believe that one may make a case for the mechanical room being
Class A. It often contains furnaces, motors, and many other unregulated
devices which generate high levels of radio and television interference,
and to impose a stricter standard on telecom equipment in the same place
seems a bit of a reach.

But look at the environment! Will emissions reaching a customer location be
above the Class B limit? If so, then I would say due diligence requires
suppressing them further.  A vault in a steel reinforced building's
basement is a different matter than a rooftop utility hut with TV antennas
just 3 meters away. If deployment entails a wide range of installations,
then it is probably best to suppress all of it to Class B, rather than
install Class B retrofit kits on a case-by-case basis. This is a decision I
believe has to be made when the product is proposed.


Regards,

Cortland Richmond
(unemployed, and looking)

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DSL on residential buildings.

2002-03-15 Thread Gary McInturff

Just making a quick check here. I'm seeing some product brochures out 
indicating some of these home units are class A. Am I missing something here, 
shouldn't that be class B. The fact its phone stuff (also carries the FCC part 
68 stuff) can't override this classification correct? 
How about apartment buildings - is their mechanical room A or B?
Gary

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