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.
Questions and Answers:
Q: Are there maximum numbers of days or times when short-term confidentiality can be extended by the Commission? We currently have an application that will be submitted in the near future but want to release items publicly in a few months. This would require 2 or 3 extensions depending on the exact date of grant and day in the month that we desire. Would this be a problem?
A: The Commission’s current policy is to allow a maximum of 4 extensions of 45 calendar days which is 180 days. Back to Top...
Q: We would like to know if it is possible to get a list of basic issues regarding FCC Part 15 that the Commission plans on addressing in new or proposed rule changes in the upcoming New Year. Can you comment briefly or provide a short list on the specific issues the Commission is currently addressing or will be addressing soon regarding Part 15 devices?
A: The Commission has not recently indicated what it would be working on in the upcoming New Year; we will inform all our clients as soon as this information is readily available. Back to Top...
Q: We have a receiver that operates at 49MHz and 433.92MHz that includes a motor. However, our understanding is that a regular motor is exempted from FCC Part 15 testing. Therefore, should disturbance from the motor in our receiver be considered under FCC Part 15.109?
A: We would recommend including the disturbance from any motors in FCC Part 15.109 measurements. However, if the final end user device is marketed and used commercially or residentially it would be subject to Class A or Class B emissions, respectively. Note that for all emissions the receiver must meet limits that are equivalent to Class B limits, thus, if the end user device is intended for industrial use only, all other digital emission not coming from the receiver section may meet Class A limits.
Additionally, if the motor is AC or pulse driven by frequencies of 9 kHz or higher (as defined by 15.3(k)) they must be measured under FCC 15.109 to Class A or B limit as appropriate. There are variable speed drives that can be considered digital devices under FCC Part 15 subpart B. If the motor is DC driven or AC driven strictly from a switched AC line power (50 or 60 Hz) source, then it may be possible to consider emissions from that portion of the device exempted. However, note that there are cases where the design of the device is not clear and whether motors can be considered exempt is difficult to determine. In such cases the manufacturer should be cautioned to consider them exempted only after obtaining a written confirmation from the Commission. If it is determined that motor emissions can be exempted, the test needs to be conducted with the motor installed in the device and in an idle mode of operation to make sure it doesn't amplify any digital device emissions or contribute to the overall digital device radiated emissions.
Since portions of the end user device i.e. digital circuits, receiver etc. are subjected to FCC Part 15 and the device labeled as such, the consumer will also assume the entire device to be compliant. If any part of the device is considered exempted from FCC Part 15, it is still subject to the exemption requirements of FCC Part 15.103. This section of the rules states that even if a device is exempted from the rules, if it causes or creates interference, the manufacturer will still be considered liable. Furthermore, the rules also states "although not mandatory, it is strongly recommended that the manufacturer of an exempted device endeavor to have the device meet the specific technical standards in this part." The manufacturer is ultimately responsible for any interference the device produces. Back to Top...
Designating Accrediting Authority Daily Updates; Federal Communications Commission (FCC), Industry Canada (IC), and Compliance Europe (CE)
Hearing Aid Compatibility Waiver (HAC) – FCC has granted a request for waiver of the HAC rules in section 20.19 for dual band GSM handsets. The waiver has specific conditions, as stated in the order (FCC 05-166) and expires 1 August 2006.
HAC Measurement Update – C63.19 has clarified “peak power” in response to public comment during the review process. Effective immediately, TCBs are allowed to review applications that use 20 kHz VBW in lieu of full VBW for probe modulation factor determination. Back to Top...
Industry Canada published the following documents on Sept. 10, 2005: RSS 210 (Issue 6) – will facilitate the operation of radio frequency identification (RFID) systems; also includes technical requirements for license-exempt wireless local area networks (LE-LAN) in the 5 GHz band to reflect new policy.
RSS 310 (Issue 1) – low power license-exempt radiocommunication equipment designated as Category II.
RSS Gen (Issue 1) – contains technical and administrative requirements common to all, or most, RSS standards. Back to Top...
The following Industry Canada Standards were published on September 10, 2005:
RSS 210 (Issue 6)
RSS 310 (Issue 1)
RSS-Gen (Issue 1)
RSS-133 - 2 (Issue 3)
The following ETSI Standards were recently published:
ETSI EN 302 291-2 V1.1.1 (2005-07) Close Range Inductive Data Communication equipment operating at 13,56 MHz; Part 2: Harmonized EN under article 3.2 of the R&TTE Directive
ETSI EN 301 893 V1.3.1 (2005-08) 5 GHz high performance RLAN; Harmonized EN covering essential requirements of article 3.2 of the R&TTE Directive
The following ETSI Standards are on Public Enquiry:
ETSI EN 301 428 V1.2.7 (2005-08) Harmonized EN for Very Small Aperture Terminal (VSAT); Transmit-only, transmit/receive or receive-only satellite earth stations operating in the 11/12/14 GHz frequency bands covering essential requirements under article 3.2 of the R&TTE directive. Back to Top...