equipment; industrial equipment; electrical insulating materials; and industrial electronics and communications equipment. Its member companies range in size from small single-line firms to diversified industrial giants. The National Electrical Manufacturers Association believes that there is no basic conflict with the Federal Communications Commission's intent and reasons to establish reasonable control of some types of radio interference devices. However, we do believe that a clarification of Senate bill S. 1015, in line with our understanding of the intent of the FCC, is desirable and necessary. The National Electrical Manufacturers Association, therefore, respectfully proposes the following modification (shown italicized) of section 302(a): "SEC. 302 (a) The Commission may, consistent with the public interest, convenience, and necessity, make reasonable regulations, formulated in consultation with the affected industry representatives, governing the interference potential of devices which in their operation are capable of emitting radio frequency energy by radiation, conduction, or other means in sufficient degree to cause harmful interference to commercial, aircraft, and public safety radio communications. Such regulations shall be applicable to the manufacture, import, sale, offer for sale, shipment, or use of such devices." The consideration by the Communications Subcommittee of the modification proposed herein would be greatly appreciated. Yours sincerely, L. D. PRICE, Secretary. ELECTRONIC INDUSTRIES ASSOCIATION, Re S. 1015 to amend the Communications Act. Chairman, Communications Subcommittee, Senate Office Building, Washington, D.C. DEAR SENATOR PASTORE: Members of the Electronic Industries Association are deeply concerned with the provisions of S. 1015 to amend the Communications Act and desire to submit the following comments for consideration by your subcommittee and publication in the record of your hearings. I apologize for the delay in filing our comments, but our position on the legislation was not determined finally until July 1 when our board of directors acted on recommendation of our legislative policy committee. EIA has a long history of cooperating with the Federal Communications Commission, particularly in the area of technical standardization, and is well aware of the serious problems confronting the FCC as a result of spurious or unauthorized radiation. We have worked closely with the FCC staff in controlling radiation emissions of television receivers for a number of years. Following the introduction of S. 1015 EIA staff members and representatives of member companies have carefully studied its provisions and, on EIA's initiative, we held a conference with the FCC staff. We also have received a letter of explanation of the bill from Chairman E. William Henry. However, these communications have raised as many questions as they have answered, and our members believe more time is needed to work out with the FCC the basic problems of applying radiation controls before blank authorization is granted to the Commission by Congress. Following consideration of the legislation and its implications to the elec tronics industry, the EIA board of directors on July 1 directed me to transmit the following conclusions and recommendations to your subcommittee: 1. EIA is acutely aware of the need for appropriate controls of spurious radiation in order to obtain maximum efficiency from the limited radio spectrum and is sympathetic with the Commission's efforts to limit interference with services licensed to operate within the spectrum. 2. Many members of EIA believe the FCC has sufficient regulatory power to control unwanted radiation through voluntary standardization practices by manufacturers, and they cite the experience of the radio-television industry as an example of effective action through government-industry cooperation. 3. The problems of interference caused by spurious radiation, while growing in number, have been known to the FCC and the industry for many years. Thus there is no emergency or recent development which requires immediate congressional approval by Congress of S. 1015. 4. On the other hand, hasty legislative action may result in the imposition of unreasonable regulations on manufacturing which will retard rather than encourage technical developments designed to limit interference from radiation. 5. EIA respectfully suggests that the Communications Subcommittee of the Senate Commerce Committee defer action on S. 1015 and instruct the Federal Communications Commission to confer with industry regarding the problems of spurious radiation and possible methods of controlling it after which a report and recommendations can be submitted to your subcommittee next year. We believe this delay will result in both a better understanding on the part of all industries concerned of the objectives of the FCC and in the eventual development of a program which will more effectively curb the causes of radiation interference with radio communications outlets and receivers. General agreement between the Commission and industry before legislation is enacted would best serve the public interest. EIA stands ready to suggest industry representatives to attend a Government. industry conference on radiation at the invitation of the FCC or to serve on a study committee if the Commission prefers this procedure. We believe this procedure will avoid the pitfalls of hasty legislation without unduly delaying the solution of the problem. Cordially, Re Senate bill 1015. Hon. JOHN O. PASTORE, Chairman, Subcommittee on Communications, Senate Office Building, Washington, D.C. JAMES D. SECREST, Executive Vice President. MULTI-ELMAC CO., Oak Park, Mich., July 8, 1965. MY DEAR MR. CHAIRMAN: At your subcommittee's hearing on June 23, 1965, time was graciously made available to members of the electronics industry engaged in the manufacture of radio controls for door operators. Representatives of this industry present at the hearing-including the undersigned as chief engineer of Multi-Elmac Co.-agreed that expansion of the authority of FCC by S. 1015 was not objectionable; that time set aside for our oral com. ments might well be relinquished; and that suitable written comments should be filed, where rendered appropriate by the presentations of others before your subcommittee. We respectfully ask that our following comment be received as a justifiable clarification of certain testimony given to your subcommittee. The demonstrative testimony of Mr. David D. Thomas, of the FAA, described several radio aids to navigation-"Navaids"-which are subject to radio interference. He discussed the VOR systems, but without mentioning that it operates within an assigned frequency range of 108 to 118 megacycles. He also discussed the ILS (instrument landing system), but did not mention that it operates within assigned frequencies of 330 to 335 megacycles, plus the VOR frequencies just mentioned. The Multi-Elmac Co. manufactures and sells a substantial number of radio controls each year; but none of these operate in the segments of the radio frequency spectrum set aside for VOR and ILS systems. Our currently produced equipment complies fully with existing FCC regulations as to radiation level; and to our knowledge, has not been cited by FCC for interference to other services. We have no reason to believe that equipment complying with FCC's present rules as to radiation level causes interference with air navigation devices. Contrary to the implications of Mr. Thomas' presentation, there is nothing inherently capable of interference with air navigation devices in the equipment we manufacture, since it does not operate on the frequencies of the Navaids to which Mr. Thomas' made reference. Our company is now working with FCC, as a member of an industry committee, to obtain adoption of appropriate new regulations meeting both the needs of the industry and the obvious necessity of eliminating interference to other services and pollution of the radio frequency spectrum. We are confident that equitable and effective regulations will be thus resolved. Pending their resolution, and in the deliberations of your subcommittee, we desire your recognition of the fact that the use of garage door openers is not inherently dangerous to air navigation. Appreciative of your consideration, we remain, Very truly yours, EMC TODAY ROBERT D. LELAND, Chief Engineer. In 1960 electronic industries was first to call attention to the growing problems in RFI (radio frequency interference). The 10 feature articles we published on RFI in that year formed the basis for a special military training course at the Armour Research Foundation. Since then the scope of this subject has broadened considerably. RFI has grown to EMC (electromagnetic compatibility). It has become a topic for special courses at the University of Pennsylvania as well as Massachusetts Institute of Technology. The National Symposium on Electromagnetic Compatibility, held in New York City last month, attests to the growing interest and concern in this area. We believe that you will find "New Developments in EMC," and "The Broad Aspects of EMC" both interesting and informative state-of-the-art reports. James Senn, James Hill, and Rexford Daniels are recognized industry spokesmen. In addition, we should like to make the following constructive sugges tions: 1. EMC technology has advanced sufficiently to warrant training engineers in the field of RFI-EMC. They should receive information about how to detect. measure, and design devices and equipment to suppress unwanted radiations. It would be a good subject to include in all college engineering courses. 2. Suppression devices and connections should be clearly marked as EMC devices and made in such a manner that they cannot be left out when equipment is repaired. We suggest that all devices and grounds be tagged with a phrase such as "Do not remove without prior approval of 3. There is a definite need for minimum specifications that would be applicable to all services-military, government, and civilian. Critical problems could be covered by more stringent specifications. 4. New EMC test equipment is coming on the market that has the desirable features of portability, automatic operation, and accuracy. This instrumentation is useful in the hands of trained specialists. However, there is still a need for equipment that can be used by technicians who do not have full knowledge of the field. This equipment should be rugged, portable, easy to operate, and less costly. 5. Engineers need comprehensive EMC design handbooks. Such texts would also help them solve existing problems. 6. Designers should more fully consider the electromagnetic environment in which equipment will operate. Some steps have been taken in this direction through ECAC (electromagnetic compatibility analysis center) for military equipment designers and users. A similar service, embracing the same methods, should be developed for civilian applications. Civilian and military equipment should be capable of living together. 7. Electrical-electronic devices such as heating pads, motors, razors, radios, tape recorders, and SCR's for control devices, etc., are creating unwanted radiation. Steps have been taken with some TV receivers under the "good neighbor" policy to reduce spurious radiation. All devices should be under some effective control. The purchaser of electrical devices knows that he should look for the Underwriters Laboratories approval label. Perhaps the engineering department of EIA and NEMA could develop radiation reduction standards. Then it would become possible to tag or label equipment that has met these specifications. Let's look at electromagnetic radiation as a natural resource that should be nurtured and conserved in every possible way. Senate bill, S. 1015, now before Congress would grant broad power to the FCC to regulate unwanted radiation. We believe this is a constructive step in the right direction. BERNARD F. OSBAHR. The field of electromagnetic compatibility (EMC) goes beyond the normal "interference" to communications. It now encompasses the effects of radiation on man, animals, plant life, and materials, to cite a few. New problems on the horizon may be grouped into legal, legislative, and labor. THE BROAD ASPECTS OF EMC (By Rexford Daniels, president, Interference Consultants, Inc., Boston, Mass.) Electronic industries state-of-the-art feature "Electromagnetic compatibility" (EMC) is a term which is acquiring a broader and broader meaning every day, as scientists and engineers push out the frontiers of the electromagnetic spectrum into other disciplines. They are discovering that everything in nature has a resonance which, when activated by magnetic or electromagnetic energy, can affect its molecular structure, its habits, its uses, and even its place in its own environment. What may, therefore, be compatible today in one environment may be found incompatible tomorrow if that environment is changed. EMC is still an art struggling to be a science with nature seeming to continually complicate matters. With the introduction of "spectrum signatures" by the military, all aspects of electromagnetic energy have become officially included, such as magnetic, inductive, Fresnel, and Fraunhofer regions, etc., as well as many terms in other disciplines which describe the reactions of this energy in those disciplines. EMC is also, therefore, no longer just an electronic term but is becoming an allembracing figure of speech which includes its "side effects" as they become known. Studies being made The electromagnetic (EM) spectrum has ceased to be an inexhaustible natural resource which can be indiscriminately used. It has to employ such things as time sharing and propagation characteristic considerations, in addition to frequency allocation, to achieve compatibility. A good book on this subject is Radio Spectrum Utilization, 1964,' by the Joint Technical Advisory Committee. The book discusses all aspects and gives the reasons why. At the IEEE convention, March 1965, a panel of experts detailed the problems as they affected military and civilian uses, and fully justified the title of their discussion "Radio Spectrum Utilization as a National Problem." This panel also disclosed to the public, for the first time, the nationwide survey of all aspects of electromagnetic energy which is being made for the executive branch of the Government, by the Joint Technical Advisory Committee, and which will probably have some bearing on what action Congress takes to amend the Communications Act of 1934, now before Congress and known as S. 1015. Another article in this issue will give the electronic progress which is being made in EMC, thereby, leaving for discussion the increasingly important "side effects" and, finally, the three L's-legal, legislative, and labor-which are beginning to appear on the horizons of those involved in the use of this energy. Research into other disciplines The EM spectrum is now being examined for a multitude of uses, many of which were not thought of 10 years ago. The Department of Agriculture, for example, is exploring different frequency ranges to learn if EM energy can be used for the control of insects and pests. Educational and technical institutions, foundations and industry are studying the biological effects of this energy on humans and animals. Other research groups are recording the operation of the brain and tapping in on muscle signals to control artificial limbs and guide fast-moving manned vehicles when the g.'s render the pilots immobile. Most of this research is unfortunately random in effort and not coordinated and, hence, the results often not available to those most interested. "Radio Spectrum Utilization." a report of the Joint Technical Advisory Committee. 1964, 345 East 47th St., New York, 10017, price $10. A bill to amend the Communications Act of 1934, S. 1015. "Electromagnetic Energy and Sound for Use in Control of Certain Pests," S. O. Nelson and J. L. Seubert, American Association for the Advancement of Science, Montreal, Canada, December 1964. RAD HAZ program, U.S. Navy. BuShips Joural, September 1959. "The Frequency Spectrum and the Principle of Resonance Absorption." L. J. Baranski, California Museum of Science and Industry Lecture, Los Angeles, January 1963. The military has taken the first step in recognizing the importance of the side effects of EM energy. They have established the triservice radiation hazards (RAD HAZ) program. This is divided into three subprograms: Bioeffects (hazards to personnel); HERO (hazards to ordnance) and SPARKS (hazards to flammable and volatile fluids). At present, there is no corresponding civilian groups-and there may never need to be, if technical information is made public and proper care is taken in its use. Principles in achieving EMC With the discovery that everything in nature has a basic resonance, it indicates that everything can become an active component in a sympathetic magnetic or electromagnetic environment. Architects are finding out that buildings are no longer inert masses of metal and mortar, but can be active antennas for radiating or conducting EM energy. Industry is finding out that a component or a product may appear to be compatible in a low test ambient, but can become suddenly active when placed in a system, assembly, or too near a "hot" element. Thus, length, width, and shape become important to the design engineer. and location to the packaging engineer. From a systems circuitry standpoint there is no theoretical or practical reason which dictates the use of a connection to the earth's surface as a necessary part of an RF systems circuit." In fact, there is no consideration dictating the use of any reference point as a so-called ground. However, the need for a single reference point, called a reference ground in RF systems circuitry, is well established. But the location of such a single point depends on its position in the circuitry of the system and impedance characteristics, and with no relationship to an NEC ground. EMC, thus, means the complete use of all EM energy within a system itself and leaving no residue to be attenuated or to be conducted to a ground outside of the circuitry. In other words, all energy. except that which is supposed to do outside work, should be controlled in basie design. A third basic principle is the simple one of using non-emitting components in place of those which have to be attenuated. For example, substituting incandescent lamps for fluorescent; induction motors for brush-type motors and nonsparking switches for sparking. Scanning the spectrum It is not possible to include all the known research, which is being done in disciplines other than electronics, because they could fill volumes. However, we can start at the bottom of the spectrum and work up. Man's last refuge for privacy, his brain, is now being invaded by laboratories all over the world. Russia is known to have eight groups working on all aspects of the brain, including thought transference. The number of those in the United States is unknown but more and more are continually coming to light. It seems that the speed of modern civilization is outrunning muscular reaction time and demanding quicker controls for all kinds of work. The brain's alpha rhythm, from about 7 to 13 cycles per second, can now be controlled and, when a person alters the pattern of his thinking, it is possible to use binary digits for communication. Or, in other words, thought transference.* As brain activity climbs the spectrum, up to 150 kilocycles, it can operate muscles by creating different frequencies. These signals can be intercepted on the surface of the skin and fed into electronic devices which will duplicate the muscle action. Artificial arms and legs have been made to act normally by such methods, and controls of fast planes can now be operated by just thinking about them. Some day it may be possible to sit in front of a TV set and direct explorations at the bottom of the ocean without even geting one's feet wet. The prospects seem limitless, once the basic principle is understood. Electrical anesthesia has been discovered at 700 cycles; from 550 kilocycles to 890 megacycles colloidal components of living cells have been found to resonate in the broadcast and TV bands; 5, 10, and 39 megacycles were found to increase germination of alfalfa seeds which contained hard seed: 21 megacycles increased the germination of gladiolus bulbs; 26 megacycles caused 2 "Study and Evaluation of Radio Frequency Grounding Systems," BuDocks U.S. Navy Contract NBy-17828. ITRL, Inc., Boston, Mass. 3 "Communication by Brain Waves," Microwave Physics Laboratory, AFCRL, Research Review. Office of Aerospace Research, November 1964. 4 "Muscle Voltage Moves Artificial Hand," G. W. Horn, Electronics, Oct. 11, 1963. 5 Same as above. |