Issue 6
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.
Q: Please provide regulatory guidance for an advanced PDA cell phone that was recently approved by our TCB as a composite device as follows:
a) The grant specifies FCC Part 22 and 24 licensed device b) The grant specifies FCC Pat 15.247 unlicensed Bluetooth device c) The grant specifies a PC Peripheral unlicensed Device
Minor changes were made that may require retesting of the PC peripheral device (i.e. changing the size of built in memory or a similar type of change). These changes do not alter or affect the RF circuitry of the device. Is it possible to perform a Declaration of Conformity (DoC) on the PC peripheral device of the cell phone and adjust our labeling to include the DoC label and the manual to include information in accordance with FCC Part 2.1077?
A: In order to have the PC peripheral device authorized under Declaration of Conformity one must file for a change of Identification per Section 2.933 of the Commission’s Rules and Regulations to cover a) the licensed cell phone device and b) the unlicensed Bluetooth device described in the above question. After authorization is issued, the Cell phone and the Bluetooth device must carry the new FCC ID label and the PC peripheral the DoC label. Back to Top
Q: We wish to use a 6 feet dish antenna with 37dBi of gain, approximately 10dB higher than the previously certified antenna. In order to use this antenna we will be reducing the output power from the device by a factor of 10dB from the radio. Due to the size of the antenna, it will be difficult (but not impossible) to verify that the radiated spurious emissions are still within the limits. Would it be possible to simply measure the antenna-conducted emissions with the reduced power from the radio, verify that all spurious emissions are at least 10B down from the previously measured levels (levels submitted to the FCC from the original application) and submit these results for the permissive change? A: The commissions primary concern is that different antennas have different cut-off characteristics, i.e., the amount of attenuation at various frequencies (not the fundamental), and varying pass-bands within different antennas. Even if the RF conducted emissions are all down by 10 dB, this does not necessarily mean that the associated radiated emissions (particularly spurs) will also be down 10 dB. As a result, the commission would prefer that the actual radiated emissions be measured if possible. Back to Top
Q: We have a GMRS/ FRS walkie-talkie that operates 462MHz to 467MHz; do we need SAR measurement for FCC certification?
A: Unfortunately there are different power levels for SAR when submitting to the Commission or a TCB. The Commission specifies one level for its submissions and another for submittals to TCBs. The Commission is currently working on making a single level for both submissions, but this is not yet a reality.
The Commissions procedure “Federal Communications Commission OET Laboratory Division March 18, 2004 Mobile and Portable Device RF Exposure Equipment Authorization Procedures” section 1, Portable push-to-talk (PTT) – Parts 80, 90, 95a states the following:
a) For equipment certifications submitted to the FCC, SAR data is requested for GMRS PTT radios with either conducted or radiated (EIRP) output power higher than 1.0 W.
b) For equipment certifications submitted to a TCB, SAR data is requested if output power is greater than the low thresholds in the July 02 TCB Exclusion List.
c) Basic RF exposure instructions, similar to Supplement C body-worn recommendations, are requested for devices that satisfy general population exposure requirements, as part of the §2.1033(c)(3) required operating instructions; RF exposure training instructions and labeling info are requested for devices that satisfy occupational exposure requirements.
Basically, the Commission requires SAR if > 1.0 Watt (conducted or EIRP) and the application is submitted to them. TCBs require SAR if power (conducted or EIRP) are above 0.256W [using 120/f] assuming face to mouth use and any body clips allows > 2.5 cm spacing if the device is capable of transmitting on the body. If < 2.5 cm, for body worn conditions this would be 0.128 W (using 60/f). Note that for comparison of power to these limits, one can assume that a 50% duty cycle can be applied if the radios are push to talk (most FRS and GPRS are). Additionally, FRS and combined GPRS radios must meet general population RF exposure limits. Though you may be able to submit to the FCC without SAR, the application processing time is longer than TCBs, even then, the Commission sometimes requested SAR data at lower values when there are concerns. TCBs can usually perform the review in a matter of days, but they will require SAR even at lower output levels. Back to Top
Q: We have a Tablet PC device that looks like an LCD panel. In the Tablet PC, there is an 802.11g transmitter card and GPRS/CDMA transmitter card. Both cards are plug-in cards, but the Tablet PC manufacturer has two vendors for the 802.11g cards. The following are my questions:
1) It is possible to use one FCC ID to cover the Tablet PC with two selections on the 802.11g card?
2) The Tablet PC Looks like an LCD panel, it can be carried on your hands but not in your pocket because of the size; simultaneously transmitting is also possible with both transmitters. In such instance, is SAR measurement testing required?
3) How can we perform inter-modulation testing?
A: 1) Unless the two cards you proposed are identical in components, layout, schematics, etc., then they are not considered electrically identical and must be under two separate FCC ID's (assuming the device is approved as a system). Depending on your requirements, it may be desirable to approve the cards as a module instead and cover the co-location aspect in the Tablet PC approval.
2) For SAR, please note the following from the Commission OET Laboratory Division March 18, 2004 Mobile and Portable Device RF Exposure Equipment Authorization Procedures (IDB RFx) as guidance for performing SAR on Tablet PCs. a. Tablet device screen sizes must range between 8-14” and weights range 2-8 lbs; b. In general consumer Tablet PCs are expected to have lap-held use position; c. Smaller devices may qualify for handheld-only operations, but filing must include strong justification for such, the Commission needs to be contacted for guidance, if needed.
In general consumer tablet PCs are expected to have lap-held use position per FCC RF procedure IDB RFx section 7) d) ii). Furthermore, section 7) a) of IDB RFx procedure states the following: undefined or unclear device usage positions, where existing or standardized test procedures are not applicable, SAR should be evaluated according to the normal operating configurations which are intended for the device. 3) With respect to inter-modulation testing, the lab is expected to investigate various configurations to obtain worse case inter-modulation results. The report needs to provide only the worse case inter-modulation results, but the exact rationale for selection of channels/combinations must be documented in the test report. Back to Top
Designating Accrediting Authority Daily Updates; Federal Communications Commission (FCC), Industry Canada (IC), and Compliance Europe (CE) FCC: AMENDMENT OF PART 90 OF THE COMMISSION'S RULES TO PROVIDE FOR FLEXIBLE USE OF THE 896-901 MHZ AND 935-940 MHZ BANDS ALLOTTED TO THE BUSINESS AND INDUSTRIAL LAND TRANSPORTATION POOL. – The comment period for this proposal has been extended to May 18, 2005. The deadline for filing reply comments has been extended to June 2, 2005. (Dkt No. 05-62).DA-05-1084A1.doc DA-05-1084A1.pdf DA-05-1084A1.txt OET Clarifies Use of Revised Wireless Phone Hearing Aid Compatibility Standard Measurement Procedures and Rating Nomenclature –Public Notice DA 05-1134 Applicants may utilize either the 2001 or 2005 version of ANSI C63.19 (currently in draft form), and must identify which version is being used for compatibility testing and for rating wireless phones. Pending further action by the Commission to modify the rules to reference the revised version of ANSI C63.19, OET will certify equipment that meets the requirements, and has been tested and rated using the procedures from either version of the standard. This move should assist manufacturers and carriers in meeting the September 16, 2005, deadline for providing handset models that comply with the radio frequency interference requirements of § 20.19(b). TCBs will be permitted to review and issue grants for these devices after the training session on May 10-13, 2005. Back to Top OET Clarifies Emission Mask Measurements for DTV Transmitters Public Notice DA 05-1321 assists in clarifying Section 73.622 (h) and Section 74.794 of 47 C.F.R. as it provides guidance to the out-of-channel emission masks for full service DTV transmitters, and for low power stations. It also provides further guidance for performing measurements of these emissions of DTV transmitters. TCBs Can Now Approve Certain Multiple Input Multiple Output (MIMO) Systems The FCC announced at the recent May TCB Council Workshop that TCBs will be able to approve the following: Phased array systems; Sectorized systems; and Spatial Multiplexing MIMO systems with or without cyclic delay diversity. Back to Top IC:The emerging Radio Standards Specification 133 (RSS-133) Issue 3 will reflect the new unwanted emission mask for the certification of Universal Mobile Telecommunication System (UTMS) base stations operating in the 1850 – 1910 MHz and 1930 – 1990 MHz bands. Back to Top EMC Directive 2004/108/EC:The list of EMC Directive harmonised standards have been updated. You may find a great deal of useful information at the public download area of the R&TTE CA website: http://www.rtteca.com/EMC_HS_0503.pdf. The list of Low Voltage Directive harmonised standards have been updated and are available at the public download area of the R&TTE CA website: http://www.rtteca.com/LVD_HS_0504.pdf Standard updates:ETSI Standards Published: ETSI EN 302 217-3 V1.1.3 "Characteristics and requirements for point-to-point equipment and antennas; Part 3: Harmonized EN covering essential requirements of Article 3.2 of R&TTE Directive for equipment operating in frequency bands where no frequency co-ordination is applied" ETSI Standards on Public Vote: ETSI EN 302 291-2 V1.1.1 (2005-05) Short Range Devices (SRD); Close Range Inductive Data Communication equipment operating at 13,56 MHz; Part 2: Harmonized EN under article 3.2 of the R&TTE Directive Back to Top
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