Newsletter "Packets" - Wireless News and Regulatory Updates
Providing information and fielding questions for wireless
manufacturers are some of the many activities that we perform at
ACB. Packets provides an overview of just a small portion of the
communiqués that run in and out of our office.
NEWS! American Certification Body Earns EPA ENERGYSTAR® Recognition
American Certification Body has recently been recognized by the US
Environmental Protection Agency (EPA) under the newly-revamped
ENERGY STAR® program that requires that all new product submissions
from manufacturers participating in the ENERGY STAR® program be
reviewed by an EPA-recognized Certification Body (CB)
KDB449343 – Pre-calibrated field method will NOT be accepted
Measurements to detect unwanted transmitter emissions in the
spurious domain that may be radiated from an Equipment Under Test
(EUT) cabinet, control circuits, power leads, or intermediate
circuit elements under normal conditions of operation are required
per Section 2.1053 of the FCC rules, and must be performed on a
radiated basis. Additionally, radiated measurements are often
required to determine the maximum output power from a licensed
transmitter that features an integral transmit antenna but does not
provide an access port for performing conducted measurements.
FCC laboratory policy requires the use of a signal/antenna
substitution methodology, as described in Sections 2.2.12 and 2.2.17
of TIA-603-C, to perform these measurements.
The FCC has received several inquiries regarding the acceptance of
an adjunct methodology, whereby a signal generator is used to
radiate a signal that is swept over a pertinent frequency range and
then recorded at a single point in space at a distance corresponding
to the measurement distance required for compliance testing. A
table of data collected from this site "pre-calibration" is then to
be used to replace specific substitution procedures as described in
Sections 2.2.12 (j) through (l) and/or 2.2.17 (c) and (d) of the
Since the pre-calibrated field methodology has not been recognized
as part of an industry standard or formally submitted to the FCC for
consideration, data collected using this method cannot be deemed
acceptable for demonstrating compliance to FCC rules, and therefore
such data will not be accepted after January 1, 2011. It is our
understanding that the Accredited Standards Committee C63 -
Electromagnetic Compatibility is considering related measurement
procedures. If C63, or another recognized standards organization,
develops alternatives to the measurement methods described in
TIA-603-C, then the FCC is prepared to consider the acceptability of
those alternative measurement methods.
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KDB 447498 D02 said the (A) Horizontal-Up USB
orientation should be tested within the host computer. How about
the (C) Vertical-Front, or (D) Vertical-Back USB orientation? Does
it also need to be tested within the host computer? How do you
understand the "remaining" Vertical USB orientation in the KDB? Does
it cover C and D? Or just C OR D?
The USB dongle must be SAR tested directly connected to
a laptop USB port for the Horizontal-Up (A) position. The USB
dongle must be tested directly connected to a laptop USB port for
one of the vertical positions, either the Vertical-Front (C) or
Vertical-Back (D). For the remaining vertical position and the
Horizontal-Down (B) position, you may use a 12 inch long or less USB
extension cable to connect the USB dongle to the laptop USB port.
You get to choose which vertical position to connect directly to the
laptop; it probably depends upon what vertical USB port is available
on the host laptop.
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How to test external antenna(s) for the licensed
Licensed devices, such as a 3G router, that have integral
antenna(s) are tested with the antenna. Removable antenna(s) are
tested at the antenna port. Basically, what is done for an external
antenna is antenna conducted tests as follows:
1. Measure conducted antenna power at the antenna connector
(for the internal antenna, if it can be removed then remove it and
measure power at that antenna port. If it cannot be removed then
a. If the device is in the mobile category (i.e. is not a licensed
base station or cellular repeater etc) or a device which receives
its own license to operate, then you must measure ERP/eirp of both
the internal and external antenna port using the highest allowed
antenna gain. Remember parts 22 and 24 and 27 have ERP/eirp
maximums for non-base station, non-cellular repeater etc devices.
See sections 22.913, 24.232 and 27.50.
b. The manufacturer cannot relieve himself of the obligation to
insure that his device does not exceed the ERP/eirp limits by saying
he does supply the antenna. It would have to be made clear that a
maximum antenna gain restriction applies to his device is it is not
licensed at the time of installation.
c. This also deals with MPE. If the device is not licensed at the
time of installation, then the manufacturer MUST provide MPE
calculations (and possibly MPE measurements) at the time of grant.
In order to do this he would have to also limit the gain of any
external antenna used for his device. This maximum gain would be
listed ON THE GRANT. The ONLY way the manufacturer can get out of
MPE at the time of grant is to show how he NEVER sells his device to
anyone not getting a license to operate for the specific
transmitter. IF he sells to ANYONE not obtaining his own license to
operate, thus operating under the license of a base station (i.e.
CPE equipment), then MPE and thus a maximum stated antenna gain,
must be done at the time of granting of the device.
2. Measure antenna spurious power at the antenna connector. This
includes spurious and harmonics as well as band edges.
3. Measure radiated spurious emissions with the external port
terminated in its characteristic impedance.
a. Radiated emissions is not an alternate spurious emissions, but an
‘also ran’. BOTH conducted and radiated spurious emissions must be
done on a licensed rule part transmitter.
4. Test frequency drift (voltage and temperature) for frequency and
power stability at the antenna port.
5. Measure occupied bandwidth at the antenna port
6. Measure any other required test for licensed devices
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To do a DoC for the FCC, does the
applicant or manufacturer need to be within the United States?
The responsible party for the
applicant or manufacturer as defined in 2.909 must be in the U.S.
Note this is not necessarily the applicant or manufacturer. Note
In the case of equipment subject to authorization under the
Declaration of Conformity procedure:
(1) The manufacturer or, if the equipment is assembled from
individual component parts and the resulting system is subject to
authorization under a Declaration of Conformity, the assembler.
(2) If the equipment, by itself, is subject to a Declaration
of Conformity and that equipment is imported, the importer.
(3) Retailers or original equipment manufacturers may enter
into an agreement with the responsible party designated in paragraph
(c)(1) or (c)(2) of this section to assume the responsibilities to
ensure compliance of equipment and become the new responsible party.
(4) If the radio frequency equipment is modified by any party not
working under the authority of the responsible party, the party
performing the modifications, if located within the U.S., or the
importer, if the equipment is imported subsequent to the
modifications, becomes the new responsible party.
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Can a Part 15 transmitter such as an 802.11b/g, or a
UNII device, allow users or professional installers to set the
country code to ensure compliance; if the user’s manual contains the
following statement: " WARNING: Select only the country in which you
are using the device. Any other selection will make the operation
of this device illegal."?
No. As specified in Section 15.202 of
the rules, master devices marketed within the United States must be
limited to operation on permissible Part 15 frequencies, and such
devices cannot have the ability to be configured by end users or
professional installers to operate outside the authorized bands. Selecting country codes for different regulatory domains is not
permitted. If the device is certified for professional
installation, installers may be allowed access to configuration
parameters when on site (remote access is not permitted); and only
the configuration parameters identified in the equipment
authorization may be configured on site. Frequency selection using
country codes is not permitted.
Any device meeting the definition of a client as specified in
Section 15.202 may have the ability to operate on other regulatory
domain frequencies if it is under control of (automatically
associated with) a certified master device. In this case, the
"WARNING" statement mentioned above would not serve any purpose
since frequency selection, power or grant conditions would be
automatic, and regulatory domain selection would not be permitted.
Many devices referred to by the WiFi industry as "client devices"
may not meet the definition of a Section 15.202 client, and must be
limited to operating as master devices on US frequencies, and within
the grant conditions. To qualify as a Section 15.202 client, a
device cannot initiate, or be configured to initiate, any
transmission for any reason on non-US frequencies, or on frequencies
not authorized for use. This includes probes, beacons, and ad hoc
mode transmissions. Only if all features and functions that utilize
initiating transmissions are within the frequencies as granted, can
the device be authorized as a Section 15.202 client device. These
devices can then automatically associate and operate on non-US
frequencies when outside of the US, under the control of a foreign
master device authorized on other regulatory domain frequencies.
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Antennae or Antennas?
There are two main types of antenna. There are the
little things that stick out of the head of an insect (antenna) and
the things which connect to radio transmitters and EMC test sites
(antenna). If you have multiples, the spelling is different…
||If you are talking about insects and bugs, the plural of
antenna is antennae.
||If you are talking about transmitter radios and EMC
labs, the plural is antennas.
So, a bug has an antenna or perhaps two antennae.
A test lab has
an antenna or perhaps several antennas.
A radio with antennae
must have a bug inside it. Perhaps it is in the garden by the
A bug with antennas… is listening to the radio.
(Thanks for Michael Derby’s contribution.)
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941225 What are the current SAR test procedures for 3G
285076 What are the equipment authorization requirements for
hearing aid compatibility of mobile handsets?
552295 What are the guidelines for providing a Contention Based
Protocol (CBP) operational description, as required by Part 90Z?
643646 What are the Specific Absorption Rate (SAR) test
requirements for occupational push-to-talk (PTT) radios?
449343 Can a pre-calibrated field methodology be used in
conjunction with the procedures described in the TIA-603-C standard
to measure the radiated output power and/or the spurious emissions
generated by a transmitting device for demonstrating compliance to
971168 What are the procedures for compliance measurement for
the fundamental emission power for licensed wideband (> 1 MHz)
digital transmission systems?
412172 How do you determine ERP and EIRP Values for a RF
966099 Can a log average detector be used to make average
measurements on intentional radiators?
714737 What average detector should be used to measure radiated
emissions from an unintentional radiator?
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