Cohen, Dippell and Everist letter

0003-EX-PL-2007 Text Documents

CATERPILLAR, INC.

2007-11-28ELS_86266

                                 Cohen, Dippell and Everist, P.C.


TO:            Hossein Hashemzadeh

               cc: Nathan Schenkel
                   Andrew Knitt
                   Tom Van Wazer

TOPIC:         Caterpillar Test Procedure - Peoria and Tucson

DATE:          November 28, 2007

FROM:       Donald G. Everist
_____________________________

        Per our discussion, please find a summary of the test procedure entitled, “Summary of

Proposed EMC Testing Procedure.” This overview depicts that the test signal is very narrow in

comparison to 6 MHz and emits in a very small timeframe. Therefore, the test procedure limits

the potential for interference to broadcast operations in the VHF and UHF bands.

        This test procedure is based on Caterpillar’s internal requirements and ISO specifications

for international compliance.

        Also provided are two frequency/channel charts. One is for the Peoria test site and the

second is for the Tucson test site. This gives an overview of these channels in the TV broadcast

band which encompass Channels 2-69 in the area which

        !      an STA has already been received

        !      consent has been received from the relevant station, and

        !      de minimis interference has been predicted based on the Digital Low-Power

               Television Longley-Rice Analysis (those channels marked OK) which would

               impact any broadcast station by less than 0.5%

        !      Call letters are provided by a station(s) receiving interference greater than 0.5%


Memo to: Hossein Hashemzadeh
November 28, 2007
Page 2



       The Digital Low-Power Television Longley-Rice Analysis will over predict the

computed interference due to the narrow band nature of the test signal, its abbreviated duty

cycle, and the transmit test antenna which is only 2 to 3 meters above ground level rather than

the 30 meters used in the low power digital analysis. Further, each test site (Peoria and Tucson)

has surrounding ground elevation higher in almost every direction than the transmit test antenna,

thereby providing inherent terrain shielding of the test signal to the general test site area.

       Please give me a call at your convenience.

Attachments


                                     Caterpillar, Inc.
                       Summary of Proposed EMC Testing Procedures

Caterpillar has requested special temporary authority to conduct electromagnetic compatibility
(EMC) immunity testing on the channel edge of specified channels in television band at its
Peoria Proving Grounds and Tucson Proving Grounds sites. Caterpillar typically conducts
outdoor EMC testing on its large equipment approximately 10 times per year.

The EMC testing is directed to critical electronic components on large earth moving equipment
that could potentially be affected if operated in a high electromagnetic field environment. The
EMC testing is conducted across a large number of frequencies to ensure both product safety and
compliance under different international regulatory schemes, including those of the European
Union, that


Testing Procedures
EMC immunity testing involves illuminating the equipment under test with an electromagnetic
field of specified, uniform electric field strength across the applicable frequency range. Because
of the wide range of frequencies that the equipment under test must be subjected to, various
antennas are used in the testing phase. These include horn style, log periodic yagi, and other
broadband antennas. The antennas are typically mounted two meters or less off the ground and
three to five meters from the equipment under test. The antenna radiation pattern will be
omnidirectional below 200 MHz (biconical antenna) and directional above 200 MHz (log
periodic antenna).

Industry and internal standards for Caterpillar earth moving equipment require testing of
electronic systems on machines at a field strength level of 100 V/m. The transmitter output
power required for testing at this field strength varies due to the efficiency of the antenna at a
given frequency. At lower frequencies where the transmitting antenna is an inefficient radiator,
the transmitter output power will be much greater than the ERP due to high-reflected power. At
high frequencies where the transmitting antenna has significant gain, the transmitter output
power will be much lower than the ERP. Caterpillar has requested 500 watts of effective
radiated power to conduct this testing, although the actual transmitter power output will be much
less in most cases.

The test signals will be centered at the edge of any television channel used and will have a
maximum bandwidth of 2 kHz at frequencies below 800 MHz. Above 800 MHz, the maximum
bandwidth is 20 kHz. The transmitted test signal is either an unmodulated carrier an 80 percent
AM modulated at 1 kHz, or pulse modulated (only above 800 MHz).

Starting at the lowest frequency of interest, the signal generator is stepped through the
frequencies of interest by computer control. The computer normally dwells on one particular
frequency for less than 10 seconds per frequency sweep. A normal test regimen consists of six
frequency sweeps (three antenna positions x two antenna polarizations) over the course of
several hours. Given these parameters, the transmitter duty cycle at any particular frequency is
approximately 60 seconds (or .4 percent) for a four-hour test.


Interference Mitigation
The likelihood of interference with broadcast signals is low and will be reduced in the following
ways:

   •   Antennas mounted close (2 meters or less) to the ground and close (3 to 5 meters) to the
       equipment under test which will greatly limit the range of the transmitted signal
   •   Use of directional antennas for all frequencies above 200 MHz
   •   Test signal centered at the edge of any television channel with a maximum bandwidth of
       2 kHz.
   •   Dwell time on any frequency is less than 10 seconds
   •   The outdoor testing occurs infrequently (once every several months)
   •   The outdoor test site is in a low-lying area relative to surrounding terrain, which will limit
       signal propagation

In addition, Caterpillar personnel will be present for all aspects of the investigation, testing will
be coordinated with various public safety agencies in the area, and standards of good engineering
practice will be followed, with applicable FCC rules available as a reference.




                                                 2


                                     FREQUENCY TABLE OF SPECIAL TEMPORARY AUTHORITY, CONSENT AND __________
                                                             PEORIA (11-27 @ 11:20 AM)
                    ²---------------------------------------------------------- VHF ------------------------------------------------------------÷
      MHz           54          60          66           72          76          82          88         174         180         186         192        198         204         210         216
                         STA         STA         STA                      STA         STA                     STA         STA         STA         ?          STA         STA         STA


      CH                  2           3            4            75.4       5           6                      7           8           9           10         11          12          13
                                                                                                                                             (WILL)

                   ²-------------------------------------------------------------------- UHF -----------------------------------------------------------------------------÷
     MHz           470         476         482         488          494         500          506        512         518         524         530        536         542         548         554        560        566        572
                          OK         OK           OK           OK          OK         WHOI         OK         OK          OK          OK          OK     WEEK            OK          C       WYZZ           OK         OK


     CH                  14          15          16           17          18          19          20      21          22              23      24         25          26              27          28         29         30

                   ²-------------------------------------------------------------------- UHF ------------------------------------------ ----------------------------------÷
      MHz          572         578         584         590          596         602          608        614         620         626         632        638         644         650         656        662        668        674
                         WMBD        OK      W50DD            WWTO        WWTO        WWTO      ASTRO     WQAD        WAOE            OK      WICS       WICS        WYZZ        WRSP            OK         OK     WTVP
                                                                                                                      WQAD                                           WICS


      CH                 31          32            33          34          35              36       37         38          39          40         41          42          43          44         45         46          47

                    ²------------------------------------------------------------------- UHF -----------------------------------------------------------------------------÷
      MHz          674         680         686         692          698         704          710        716         722         728         734        740         746         752         758        764        770        776
                          C       KLJB        KLJB             C           OK          OK          OK         C       KWQC            OK          OK     WAOE            OK          OK          OK         OK         OK
                                 W50DD       W50DD


      CH                  48         49          50           51          52          53           54     55              56      57          58             59          60      61          62         63             64

                   ²-------------------UHF --------------------÷
      MHz          776         782         788         794          800         806
                          OK         OK          W67CW         OK          OK


      CH                 65          66          67           68          69

STA = Special Temporary Authority                 C=      Consent


                                   FREQUENCY TABLE OF SPECIAL TEMPORARY AUTHORITY, CONSENT AND __________
                                                                  TUCSON
                    ²---------------------------------------------------------- VHF ------------------------------------------------------------÷
      MHz           54        60          66         72         76         82          88         174        180        186         192        198        204         210        216
                      K02BW         C           C                     C         KUAT                    OK         OK      KGUN           OK     KMSB        KOLD       KOLD


      CH                 2           3          4                     5          6                      7          8           9          10         11          12         13
                      (LICENSE
                    CANCELLED)


                   ²-------------------------------------------------------------------- UHF -----------------------------------------------------------------------------÷
     MHz           470        476        482        488        494         500         506        512        518         524        530        536         542        548        554        560        566        572
                         OK         OK         OK          C         OK          OK          C          OK         OK          OK         C          OK          OK     KUAS           OK     KPCE-LP        OK


     CH                  14        15          16         17         18         19          20      21         22              23     24         25          26             27         28         29         30

                   ²-------------------------------------------------------------------- UHF ------------------------------------------ ----------------------------------÷
      MHz          572        578        584        590        596        602         608         614        620        626         632        638        644         650        656        662        668        674
                         OK        KOLD        OK         OK         OK          OK      ASTRO          OK         OK      KHRR           OK     KHRR            OK         OK         OK         OK         OK


      CH                 31         32          33        34          35          36          37        38          39         40         41          42         43         44         45         46          47

                    ²------------------------------------------------------------------- UHF -----------------------------------------------------------------------------÷
      MHz          674        680        686        692        698        704         710         716        722         728        734        740        746         752        758        764        770        776
                         OK         OK         OK         OK         OK          OK          OK         OK         OK          OK         OK         C           OK         OK         OK         OK         OK


      CH                 48         49         50         51         52         53          54      55             56      57         58             59         60      61         62         63             64

                   ²-------------------UHF --------------------÷
      MHz          776        782        788        794        800        806
                         OK         OK         OK         OK         OK


      CH                 65         66         67         68         69

STA = Special Temporary Authority              C=     Consent



Document Created: 2007-11-28 14:52:58
Document Modified: 2007-11-28 14:52:58

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