FCC Rules Seminar Taipei Taiwan April 2004 www

FCC Rules Seminar Taipei, Taiwan April 2004 www. atcb. com

American. TCB Taiwan • American. TCB, Inc. 3 F, 201, Ti Ding Avenue, Sec. 2, • Neihu 114 Taipei, Taiwan • Major Chen Sales Manager • Phone: 886 -2 -2658 -5152 ext 311 • Tim Johnson: +886 092039926 www. atcb. com

WELCOME and Thank You to our Sponsors • Trivet Industrial Corporation • Richtec Instruments Co. , Ltd • Training Research Corporation (TRC) • EMI&EMC (Item Publications) atcb. com

Seminar Schedule and Overview • Introduction & Overview of FCC Rules – Bill Graff: 1: 00 -1: 45 • Latest NPRMs and Rules Changes – Tim Johnson: 1: 45 -2: 30 • New requirements for Specific Absorption Rate (SAR) Testing – Bill Graff, ATCB: 2: 30 -3: 15 • • Break: 3: 15 -3: 30 Feature Presentation by Sponsors – Jones Yen, Trivet Industrial Corporation – Frank Tsai, TRC: 3: 30 -4: 00 – P. H. Yuan, Richtech: 3: 30 -4: 30 • European Update – Mike Violette, ATCB: 4: 30 -5: 00 • Q&A – 5: 00 -5: 30 • Reception – 5: 30 -7: 30 atcb. com

Fundamental Rules Seminar William H. Graff, American. TCB atcb. com

USA Compliance • US: Federal Communications Commission – Title 47 Code of Federal Regulations – Product approvals can be performed by FCC or Telecommunications Certification Bodies – TCBs are able to perform “routine” evaluations only using FCC recognized industry standard methods – New technologies or technologies where there is no industry consensus are excluded. atcb. com

FCC 47 CFR Regulations • • Part 2 General Requirements Part 5 Experimental Radio Service Part 15 Subpart C, D, and E Unlicensed Low Power Transmitters (802. 11 a/b/g, Bluetooth, etc. ) Part 20 Common Carrier Part 21 Domestic Public Service Part 22 Public Mobile Service Part 24 Licensed PCS atcb. com

FCC 47 CFR Regulations • • Part 25 Satellite Communication Services Part 26 General Wireless Services Part 27 Miscellaneous Wireless Services Part 68 Telecom Services Part 73 Education Services Part 74 Television Broadcast Part 80 Maritime Service atcb. com

FCC 47 CFR Regulations • • • Part 87 Aviation Part 90 Private Land Mobile Part 95 Personal Radio Service Part 97 Amateur Radio Part 101 Fixed Microwave atcb. com

FCC 47 CFR Regulations • FCC does not regulate • • • safety (except RF Exposure) susceptibility product performance atcb. com

Certification – Used for most “Equipment Authorizations” Formerly called “Type Acceptance”. – Is more than just a “test report” – actually a legal document – Requires a detailed list of “Exhibits” • See 2. 1033 for complete detail – Test Report should be designed to show transmitter is “well-behaved” atcb. com

Licensed Radio Services Test Parameters • • • 2. 1046 - Power Output 2. 1047 - Modulation Characteristics 2. 1049 - Occupied Bandwidth 2. 1051 - Antenna Terminal Spurious Emissions 2. 1053 - Radiated Spurious Emissions 2. 1055 - Frequency Stability for Temperature and Voltage Variations atcb. com

Licensed Radio Services Test Parameters • In most cases - the actual Radio Service rules have special or unique requirements and additional testing parameters. atcb. com

Licensed Radio Services Test Parameters • In addition to the Part 2 rules addressing test parameters the FCC also recognizes the test methods contained in ANSI/TIA/EIA-603 -1992 document • ***Reference test procedures in report atcb. com

Licensed Radio Services Test Parameters • Remember that the purpose of performing the measurements required and submitting interpretations is to establish compliance with the technical requirement contained in the Radio Service Rules. atcb. com

Licensed Radio Services Test Parameters • Power Output: 2. 1046 • For any special case as sighted in the specific rules compliance to 2. 1046 test method is accepted provided the specific Rule is addressed as part of the information. atcb. com

Licensed Radio Services Test Parameters • Where sections of the recommended standard EIA-603 differ from Part 2 requirements - the Part 2 test method must be used for testing purposes. atcb. com

Licensed Radio Services Test Parameters • Modulation Characteristics 2. 1047 • Test requirements of this section differ from EIA-603 requirements. • Compliance to Part 2 requirements is mandatory. atcb. com

Licensed Radio Services Test Parameters • Example: EIA 603 differs from Part 2. 1047 regarding the range which the audio frequency response is to be measured. – Part 2. 1047 requirement of 100 - 5000 Hz should be used for this test. • General Test Setup Transmitter Under Test Power Attenuator Power Measuring Receiver/Spectrum Analyzer Modulating Signal Generator atcb. com

Licensed Radio Services Test Parameters • Occupied Bandwidth 2. 1049 • While this test is identified as “Occupied Bandwidth” which is defined as that portion where 99% of the emitted energy (with the remaining 0. 5% above & 0. 5% below the occupied band), the results are mainly used to compare modulated spectrum with emissions masks • OBW @ 10 Log (0. 01) = -20 d. Bc • Other rule sections may call out -23 or -26 d. Bc atcb. com

Licensed Radio Services Test Parameters • In addition to meeting the emission mask, the occupied bandwidth may not exceed the authorized bandwidth as listed in the Radio Service Rules. • This test should be performed for each kind of emission to be listed on the FCC Grant. • Note: the emission mask is normally applied with 0 d. B equal to the level of the unmodulated carrier. atcb. com

Emissions Mask Example Analog Modulation Mask atcb. com

Emissions Mask Example Digital Modulation Mask atcb. com

Licensed Radio Services Test Parameters • 2. 1049 does not cover Occupied Bandwidth tests for amplifiers or similar units since these devices are intended to reproduce the modulated signal. • Amplifiers designed to handle multiple channels should be tested with multiple channels for each emission to show intermodulation products. • Tests for power amplifiers still should include “gozinto” and “gozouta” plots for each modulation desired. atcb. com

Licensed Radio Services Test Parameters • Intermodulation is considered a spurious emission by the FCC and are covered by the general emission limitations (masks) in each radio service. • This specifically refers to the IM products produced by transmitters / amplifiers carrying two or more signals. atcb. com

Licensed Radio Services Test Parameters • Antenna Terminal Spurious Emissions 2. 1051 • (Otherwise know as Conducted Emissions) • View levels of harmonic emissions. • An extension of the occupied bandwidth test showing the emission up to the highest frequency as specified in Section 2. 1057 [usually 10 th harmonic]. atcb. com 0

Licensed Radio Services Test Parameters • If the unit does not have a detachable antenna or an antenna output terminal then the test data is collected at the base of the antenna. atcb. com

Licensed Radio Services Test Parameters • Field Strength of Spurious Emissions 2. 1053 – ERP/EIRP Spurious Measurement • This test includes those emissions radiated from the cabinet, chassis, and associated wiring. The specification is the same emission mask under the Radio Service rules extended to the highest frequency specified in 2. 1057. • Substitution method described in TIA/EIA 603 required test procedure. Be sure to account for SWR when using broadband antennas ! atcb. com

Licensed Radio Services Test Parameters • Frequency Stability 2. 1055 • Done over temperature [-30 C to +50 C] and operating voltage [+/- 15%] specifications. • Battery operated devices should also include B. E. P [Battery End Point] • Usually defined in ppm but other units such as Hz, % are accepted as defined in specific rule section. • Differs some from methodology described in • TIA/EIA 603 atcb. com

Licensed Radio Services Test Parameters • Reference Standards: • TIA/EIA 603 Land Mobile FM or PM Communications Equipment Measurement and Performance Standards • TIA/EIA Telecommunications System Bulletin TSB 102 (Digital C 4 FM/CQPSK Transceivers Measurement Method atcb. com

Licensed Radio Services Test Parameters • Emission Designator: Determined from the Occupied bandwidth and the modulation scheme used • Classic equations described in Part 2 • Required as part of submittal atcb. com

Common Part 22 H Cellular Emission Designators • • • 40 K 0 F 8 W – AMPS Cellular voice & signaling tone 40 K 0 F 1 D – AMPS Cellular wideband data 1 M 25 F 9 W – CDMA (IS 95/98) 30 K 0 DXW - North American digital cellular - TDMA 300 KGXW – GSM 300 KG 7 W - EDGE atcb. com

Emission Designator Calculation • Emission Designator – 40 K 0 F 8 W - Voice & SAT signal • Voice (M=2. 5 k, D=12 k), SAT (M=6 k, D=2 k) • Pick highest frequency and add deviations and apply Carson’s Rule 2 M+2 D • 2(6 k) + 2(12 k+2 k) = 12+28 = 40 k. Hz – 40 K 0 F 8 W - Signaling Tone (ST) & SAT • ST (M=10 k, D=8 k), SAT (M=6 k, D=2 k) • 2(10 k) + 2(8 k+2 k) = 20+20 = 40 k. Hz – 40 K 0 F 1 D - Wideband Data • Data (M=10 k, D=8 k), SAT (M=6 k, D=2 k) • 2(10 k) + 2(8+2) = 20+20 = 40 k. Hz atcb. com

Example Part 22 H Grant atcb. com

Certification Checklist for Licensed Services • • • Applicant Name Correct Test Firm FCC ID: number Equipment Functional Description Equipment Class atcb. com

Certification Checklist for Licensed Services • Confidentiality Request Letter – Letter with details to be included with confidentiality. – Commonly Block Diagram, Schematics, Parts List and Tune-up are eligible for confidential treatment – Manuals, photos, test reports, SAR reports never allowed confidentiality – Date of letter atcb. com

Certification Checklist for Licensed Services • • Technical Information Rule Part(s) Frequency Range Power Output atcb. com

Certification Checklist for Licensed Services • Antenna Port – (Real Connection or Integral antenna? ) • Frequency Tolerance • Emissions • Necessary Bandwidth Values Justified • Emission Type Justified atcb. com

Certification Checklist for Licensed Services • RF Exposure Information • Description: Purpose, Use and Users • Instruction Manual • DC Voltages and Currents Listed • Tune Up Procedure • Circuit Diagram Block Diagrams atcb. com

Certification Checklist for Licensed Services • Photos (Internal & External) Technical Report • Power Output – (ERP/EIRP or Conducted? Peak or Average? ) • Audio Frequency Response • Modulation Limiting atcb. com

Certification Checklist for Licensed Services • Frequency Stability vs Voltage + 15% and Battery end point • Frequency Stability vs Temperature -30 C to +50 C atcb. com

Required Exhibits for Licensed Services • • Agent Authorization Letter Confidentiality Request Schematics Block Diagram RF Exposure Evaluation Operational Description Tune Up Procedure atcb. com

Required Exhibits for Licensed Services • • External Photographs Internal Photographs Sample Label with FCC ID: Label Location Test Setup Photographs Users Manual Test Report atcb. com

Recent FCC Clarifications, Latest NPRM’s and Rules Changes Timothy R. Johnson, American TCB atcb. com

Presentation Overview • Part 15 Recent Interpretation Issues, Reminders, and Application Concerns • Part 15 Rulemaking updates – NPRM’s, Report and Orders, etc. atcb. com

Multiple Modulation Capabilities in One Device • One familiar example, 802. 11(g) incorporates the following modulation capabilities. • BPSK modulation at 1 and 2 Mb/s • CCK modulation at 5. 5 and 11 Mb/s • OFDM modulation at 54 Mb/s • The FCC expects each of these modes and • modulations to be evaluated (i. e. pretest, etc. ) atcb. com

Multiple Modulation Capabilities in One Device – Cont. • Justification for worse case results reported or modes reported should be included in the test report • As a minimum, it is suggested that an 802. 11 g test report should include: – Data for BPSK/CCK. Due to similar waveforms, only worse case data needs to be shown for these 2 modulations – Data for OFDM atcb. com

AC Line Conducted Emissions for Part 15 Modules • Section 15. 207(a) requires test data unless the device is battery powered with no provision for receiving power directly or indirectly from an AC source. • Any application granted for battery power only will be listed as a condition on the grant of authorization. atcb. com

AC Line Conducted Emissions for Part 15 Modules – Cont. • Battery powered examples: – The transmitter is powered by an on-board battery. Ø Transmitter has a battery connector/compartment – The transmitter is only intended for battery powered applications and installed by OEM. Ø Device is conditioned only for battery powered applications and a limited module approval is issued Ø Any new non-battery application requires a new authorization (new FCC ID) – The transmitter is installed only in the equipment that will be battery manufacturers powered Ø Grant is conditioned accordingly and a LMA is issued atcb. com

CISPR AC Line Conducted Limits for All Transmitters • Since December 3, 2002, all Part 15 and 18 devices required to be tested for AC Line conducted emmissions must have either Note Code ’ 05’ or ‘CE’ listed on the grant of equipment authorization. atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • "05" NOTE- The manufacture and importation of this device must cease on July 10, 2005 pursuant to 15. 37(j) or 18. 123 transition provisions adopted under FCC 02 -157 (ET Docket 98 -80). • "CE" NOTE - This device has shown compliance with the conducted emissions limits in 15. 107, 15. 207, or 18. 307 adopted under FCC 02 -157 (ET Docket 98 -80) and may be marketed after July 11, 2005 and is not affected by the 15. 37(j) or 18. 123 transition provisions. atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • Currently the ’ 05’ note has been used on all devices that meet the older FCC line conducted regulations and not the new CISPR limits. This will only be allowed up until July 11, 2004. After this time TCBs and the Commission will no longer use the ’ 05’ note code. atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • The ‘CE’ note is used on all devices that are tested and comply with the new CISPR requirements and are granted before July 12, 2004. On July 12, 2004, all new approvals must meet the new CISPR limits. TCBs and the Commission will not use the “CE” note after July 11, 2004. • All devices (both new and previously approved) marketed after July 11, 2005 must meet the new CISPR AC Line Conducted Limits. atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • To update a Part 15 grant that was approved using the previous Part 15 limits, a Class II permissive change filing should be submitted showing compliance with the CISPR AC line conducted limits. atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • Special Note: • The policies for filing Class II permissive changes are different for some Part 18 devices because certain types of Part 18 devices had no AC line conducted emissions limits before the FCC adopted the CISPR limits. – Example Microwave ovens - for a detailed description see link: http: //hraunfoss. fcc. gov/eas_public/Silver. Stream/Pages/pg_html_fts_res. html? letter=1344 atcb. com

CISPR AC Line Conducted Limits for All Transmitters – Cont. • Special Note 2: • Part 18 RF lighting devices were excluded from the new CISPR AC line conducted limits by the last sentence in Paragraph 22 of the Report and Order (ET Docket No. 98 -80; FCC 02 -157). Therefore, RF lighting devices will not have a Note Code 05 or CE on a grant of Certification. atcb. com

Vehicular Battery Chargers (VBC) for Cellular Phones • There have been recent questions regarding whether a battery charger intended for use only in a vehicle requires FCC Certification. atcb. com

Vehicular Battery Chargers (VBC) for Cellular Phones – Cont. • Exempted per Section 15. 103(a) – The VBC is not promoted for applications other than use within a vehicle, Section 15. 103(a) exempts digital devices used exclusively in transportation vehicles – Classified as a digital device under Part 15 of the FCC rules – Subject only to non-interference provisions (Sections 15. 5 and 15. 29) – Certification not required atcb. com

Part 15 Water Meter Transceivers In Ground Testing Guidance • FCC has recently issued a special guidance regarding this issue. See link: • http: //hraunfoss. fcc. gov/eas_public/Silver. Stream/Pages/Fpg_html_fts_res. html? letter=1366 – This guidance allows testing in ground as opposed to an open area test site (OATS) – This gives the manufacturer more flexability to measure “system” vs. stand-alone configurations. Allows manufacture to tune power to meet their installation requirements – Professional installation is required – Instructions must provide appropriate details for the installation of the transmitter in the pits and must specify the types of pits – Grant will contain conditions accordingly Ø Professional installation and specific types of pits atcb. com

Part 15 Water Meter Transceivers In Ground Testing Guidance – Cont. • Special Guidance: – Use mast. Do not use a tripod with fixed height – Section 8. 1 in ANSI C 63. 4 should be consulted. Frequency scans of the EUT field strength with both polarities of the measuring – antenna shall be made at a minimum of 16 azimuth angles (nominally 22. 5 degrees) around the EUT atcb. com

15. 407(d) Integral Antenna Requirement for 5. 2 GHz UNII Devices • The integral antenna rule requires that the antenna is permanent or not removable. atcb. com

15. 407(d) Integral Antenna Requirement for 5. 2 GHz UNII Devices – Cont. • Acceptable methods: – Antenna and/or antenna connectors are soldered together – Permanent Loctite or industrial strength epoxy can be used – A locking connector that cannot be removed, even with a special tool ØMust be locked prior to shipment atcb. com

15. 407(d) Integral Antenna Requirement for 5. 2 GHz UNII Devices – Cont. – An antenna and/or connectors inside of a nonaccessible (there is no need for the user to ever open the case) Note that it is assumed that users will open desktop computers. atcb. com

15. 407(d) Integral Antenna Requirement for 5. 2 GHz UNII Devices – Cont. • Exceptions: • For a 5. 15 -5. 25 GHz UNII mini-PCI card installed in a notebook computer with built-in antennas – Bios locking feature satisfies the rule • Antenna with embedded code. – Code ensures that the proper antenna is used • Reminder: 5. 15 – 5. 25 GHz is for indoor use only. No outdoor antennas. atcb. com

15. 407(d) Integral Antenna Requirement for 5. 2 GHz UNII Devices – Cont. • Unacceptable Methods: – A unique connector is not sufficient – Bios lock with external antenna – A locking connector that can be removed with a special tool does not satisfy the requirement – Heatshrink – User Warnings atcb. com

User Selectable Frequencies • End user selectable frequencies for non USA frequencies are not allowed. – User selectable options must be disabled – This must be clear in all exhibits within the filing. For example user manual or descriptions for these options • Section 15. 15(b) prohibits adjustments of any control by the user that will cause operation of a device in violation of the regulations. atcb. com

Configuration of Antennas for Testing • The FCC has recently developed 2 concerns regarding test configurations for the antennas of a modular approval. atcb. com

Configuration of Antennas for Testing – Cont. • 1) Antenna positioning in test setup should represent typical final product configuration • 2) DO NOT LAY ANTENNAS ON WOOD TABLETOP atcb. com

Configuration of Antennas for Testing – Cont. atcb. com

Configuration of Antennas for Testing – Cont. • In this example the monopole antennas should be supported in vertical position, e. g. , using foamed-polystyrene blocks atcb. com

Configuration of Antennas for Testing – Cont. • Note that this also applies to antennas such as PIFA. The antennas shown on the following page should not be placed in contact with the table top during test. Additionally, the positioning should be justified in the report. atcb. com

Configuration of Antennas for Testing – Cont. atcb. com

Configuration of Antennas for Testing – Cont. • The FCC has seen that the matching of the antenna changes when placed too closely to the table top, which affects the radiation pattern. atcb. com

Co-located Transmitters, i. e. Laptop w/ LAN & Bluetooth – Cont. • Co-Location is typically defined as when 2 transmitter antennas are located < 20 cm apart from each other, and both transmitters may be active at the same time. • Each radio must be tested individually and appropriate test data submitted with the application atcb. com

Co-located Transmitters, i. e. Laptop w/ LAN & Bluetooth – Cont. • The application must also include tests for simultaneous transmission when the end use device may function with both transmitters active at the same time atcb. com

Co-located Transmitters, i. e. Laptop w/ LAN & Bluetooth – Cont. • Special care should be taken to investigate bandedge and intermodulation products • Submit antenna conducted measurements with both transmitters on, if transmitters share an antenna atcb. com

Co-located Transmitters, i. e. Laptop w/ LAN & Bluetooth – Cont. – If radiated data for simultaneous transmission is no worse (no new intermod, spurs or increased levels) than individual tests, then also submit statement that simultaneous transmission was investigated and no new emissions were found – If new emissions were found during simultaneous tests, provide data and indicate the worst case condition atcb. com

Cordless Phones • Cordless phones under Part 15 have typically been approved under several sections of the FCC rules such as 15. 233, 15. 247, and 15. 249. atcb. com

Cordless Phones – Cont. • The FCC has just released an interpretation that requires a cordless telephone that operates on two different frequency bands to be approved under two separate FCC ID numbers, one for the base and one for the handset. • For detailed information, refer to FCC Interpretation Data Base Posting 13 -004 200009 - atcb. com

NPRM’s • NPRM – Notice of Proposed Rule Making • This is a term used to denote a document that is published for public comment. The changes shown in the document are proposals only which may or may not actually become new rules and/or regulations. atcb. com

NPRM Modification of Parts 2 and 15 • Proposal to make changes to Parts 2 and 15 may be found in ET Docket No. 03 -201, FCC 03223 – http: //hraunfoss. fcc. gov/edocs_public/attachmatch/FCC-03 -223 A 1. doc • Published December 10, 2003 – Public comments were due February 7, 2004 atcb. com

NPRM Modification of Parts 2 and 15 – Cont. • 1) Work to clarify the rules for advanced antenna technologies – (i. e. phased array/steerable beam systems) in 2. 4 GHz band • 2) Modify the rules on replacement of Part 15 antennas • 3) Modify the rules on configuring transmission systems – No need to obtain separate authorization for every combination of system components. i. e. adding amplifiers • 4) Harmonize the measurement procedures for digital modulation systems under the Spread Spectrum and UNII rules atcb. com

NPRM Modification of Parts 2 and 15 – Cont. • 5) Modify the channel spacing requirements for hoppers in the 2. 4 GHz band to allow wider bandwidth hoppers • 6) Clarify and change modular approval requirements • 7) Make other changes to update or correct Parts 2 and 15 of the rules atcb. com

NPRM on Interference Temperature • Proposal in ET Docket No. 03 -237, FCC 03 -289 – – – Adopted: November 13, 2003 Released: November 28, 2003 Published January 21, 2004 Comments due April 5, 2004 Reply Comments due May 5, 2004 – http: //hraunfoss. fcc. gov/edocs_public/attachmatch/FCC-03 -289 A 1. doc • News Release – http: //hraunfoss. fcc. gov/edocs_public/attachmatch/DOC-241226 A 1. doc atcb. com

NPRM on Interference Temperature-Cont. • RM seeks comments on “Interference Temperature” approach to quantify and manage interference between different services. • Interference temperature model takes into account the cumulative radiofrequency (RF) energy from transmissions of spectrum-based devices and would set a maximum cap on the aggregate of the transmissions. – Current interference management approach is based on specifying and limiting transmit powers of individual spectrum based devices atcb. com

NPRM for Access Broadband Over Power Line Systems • Proposal to make changes to Part 15 may be found in ET Docket No. 03 -104 & 04 -37, FCC 04 -29 – http: //hraunfoss. fcc. gov/edocs_public/attachmatch/FCC-04 -29 A 1. pdf • 1) Access broadband operational requirements • 2) Equipment authorization and measurement guidelines atcb. com

Report and Order • Report and Order (R&O) • This is a term used to denote a document that includes adopted rules, provides background on reason for adoption and Effective Date. Requires publication in Federal Register atcb. com

2 nd R&O and MO&O Part 15 Deregulation • New Rules in ET Docket No. 01 -278, FCC 03 -149 – Effective date: January 8, 2004 – http: //hraunfoss. fcc. gov/edocs_public/attachmatch/FCC-03 -149 A 1. doc atcb. com

2 nd R&O and MO&O Part 15 Deregulation – Cont. • 1) Change emission levels in the restricted bands above 38. 6 GHz • 2) Allow data transmission in 15. 231 • 3) Modify the FS limits for 13 MHz RF ID systems • 4) Simplify the labeling requirement for self authorized equipment (DOC) – Removed “For Home or Office Use” and statement that a complete device was tested for compliance atcb. com

2 nd R&O and MO&O Part 15 Deregulation – Cont. • 5) Other changes to update and correct FCC rules. – Incorporate the ANSI C 63. 17 test procedure for UPCS devices into the rules – Provide exemption for certain low power devices <490 k. Hz and FS is less than 40 d. B below Part 15 limits – Allow user manual information on CD-ROM or on internet if manual is provided likewise – FRS transmitters tested -20 to+50 degrees C for frequency stability tests – Accredited labs do not have to file description of measurement facilities with the Commission. However, Certain information is still required. Name, address, contact info, accrediting body’s name, designation number and date of renewal – Miscellaneous rule corrections and deletions atcb. com

R&O UNII Devices • New Rules in ET Docket No. 03 -122 – – Effective date, February 19, 2004 http: //hraunfoss. fcc. gov/edocs_public/attachmatch/FCC-03 -287 A 1. doc Adds 255 MHz of spectrum 5. 47 -5. 725 GHz to current UNII bands Dynamic Frequency Selection (DFS) for devices in the 5. 25 -5. 35 GHz band 5. 47 -5. 725 GHz band – Interim DFS Test procedure is in the Appendix of the Rules. – Transmit power control (TPC) 5. 47 -5. 725 GHz band – According to the FCC only a statement that the device has TPC is required to be submitted in the filing. No test required atcb. com

R&O UNII Devices – Cont. • DFS and TPC are considered new technology – TCB cannot approve any device operating under the new rules • Test procedure will be updated in the near future – Currently this is considered a complex test which requires specialized equipment and software atcb. com

R&O UNII Devices – Cont. • Class II permissive change for existing equipment to add DFS & TPC – Allowed only for software change – Any hardware change requires NEW AUTHORIZATION • Transition dates; equipment operating in 5. 255. 35 GHz – 1 year, Certification filings must comply w/ new rules by February 19, 2005 – 2 years, All devices imported and marketed must comply by February 19, 2006 atcb. com

Additional References • FCC Interpretation Database: • https: //svartifoss 2. fcc. gov/prod/oet/cf/ri/Fcc. Eas. Ri. cfm atcb. com

RF Exposure Tutorial William H. Graff, American. TCB atcb. com

Portable vs. Mobile • Specific definitions for RF exposure – Mobile – Greater than 20 cm – Portable – Less than 20 cm atcb. com

What is SAR? • Close field phenomenon which occurs when an electromagnetic wave interacts with a biological medium • Occurs at less than ¼ wavelength • E and H fields are at relative maximums atcb. com

MPE calculation • MPE calculations assume a linear planewave field. • Considered an overestimate of maximum field density • Not applicable to distances under 20 cm • Cannot predict interaction with nearby structures atcb. com

SAR measurement • Requires isotropic power measurement systems • Typically use 3 axis probes in a biological “soup” • Soup has electrical characteristics nearly identical to tissue at specified frequency atcb. com

Example Systems SPEAG Index. SAR Aprel/IDX atcb. com

P 1528 § 1. 4. 2 Positioning Rationale • • Tilt Touch/cheek 2 pos. intended to encompass normal use, may not be worst-case 2 pos. are subset of 4 from ES 59005: 1998 (CENELEC), where experiences showed that 2 pos. are enough for conservative Touch position is most repeatable since it relies on two- or more point contact with phantom; accounts for RF current densities in device case regions Tilt position accounts for RF current densities in external antennas and antenna feed-regions at top of handset atcb. com

SAR Mapping Systems 1) 2) 3) 4) 5) 6) 7) 8) control and data capture unit field-probe readout electronics dosimetric E-field probe positioner unwanted ambient fields phantom shell with tissueequivalent liquid, device-under-test device holder/positioner. coarse scan over device outline to locate hot-spots atcb. com

Head Phantom • SCC-34/SC-2 head model - SAM F +30 LE ERP F RE (ERP) B 0 B -30 15 mm +20 0 N -60 M M 10 mm square EEP N ERP - ear reference point EEP - entrance to ear canal (Source: IEEE SCC-34/SC-2, P 1528 Draft) atcb. com

SAR Test Positions +30 F B 0 vertical center line RE (ERP) -30 wt/2 horizontal line +20 0 . horizontal line A B acoustic output vertical center line N -60 10 mm square wt/2 A M acoustic output bottom of handset B bottom of handset wb/2 • • point A is “test device reference point” align point A to ERP on head model align vertical center line to M-B align horizontal line to N-F atcb. com

Limitations of P 1528 • Does not address all body worn configurations • Does not address methodologies above 3 GHz • Does not address non-standard ear-held devices which do not conform to M to LE or RE line atcb. com

SAR Limits • Experiments with laboratory rats • Scaled up to humans using known models borrowed from pharmaceutical industry atcb. com

Supplement C: Exposure Limits atcb. com

Supplement C: SAR Limits atcb. com

Controlled vs. Uncontrolled • End users which have a knowledge of radio waves and can limit their exposure can use Controlled limits • End users which may have no knowledge of the limits must use Uncontrolled limits atcb. com

Differences in Limits • Limit for Controlled exposure in the head = 4 W/kg (4 m. W/g) • Limit for Uncontrolled exposure in the head = 1. 6 W/kg (1. 6 m. W/g) atcb. com

When is SAR testing required? • FCC maintains two threshold limits – one for itself and another for TCBs. • TCBs must always follow TCB Exclusion List of July 17, 2002 atcb. com

Portable PTT • Part 80, 95 • FCC – SAR data required for PTT above 1 W radiated or conducted • TCB – 60 m. W/f(GHz) atcb. com

Portable 15. 247 and 15. 407 • Below 3 GHz – FCC – SAR data if above 50 -100 m. W – TCB – 60 m. W/f(GHz) • Above 3 GHz – FCC – SAR data if above 50 m. W – TCB – cannot do – ***By law, SAR data required for all portable UNII devices regardless of Pout atcb. com

Modules • No such thing as RF category “Portable” modular approval. (Same FCC or TCB) • Full modular approvals are only permitted for RF category “Mobile” modules atcb. com

LMA and SAR • Limited Modular Approvals are permitted but only for carefully defined host platforms. • Hosts must have similar mechanical constructions. atcb. com

Three Host Method • RF category “Portable” modules are permitted under specific circumstances and specific hosts. • Testing to be performed in three each portable devices (i. e. notebook PC, PDA, etc. ) • Unlimited “Portable” modular approvals never permitted atcb. com

Simultaneous Transmission • If radiating structures <20 cm then simultaneous transmission may be of concern. • FCC evaluates co-located devices with simultaneous transmission • TCB cannot per TCB Exclusion List if second non-dominate transmitter above 5 mw atcb. com

Above 3 GHz • IEEE P 1528 does not yet define a methodology for SAR testing above 3 GHz, therefore all SAR evaluation above 3 GHz must go to FCC • Expect approvals from FCC to take 90 days atcb. com

RF Safety Documents for Issues with Human Exposure • • ANSI C 95. 1 OET 65 -C FCC Part 1. 1037 FCC Part 2. 1091 Mobile Devices FCC Part 2. 1093 Portable Devices TCB Exclusion List atcb. com

Future Provisions • Additional guidance on body-worn configurations • Release of procedure for TCBs to evaluate SAR above 3 GHz – Likely to be timed with release of DFS procedure to TCBs atcb. com

Questions? atcb. com

R&TTE Directive Michael Violette, P. E. www. atcb. com

European R&TTE Directive atcb. com

European R&TTE Market • R&TTE equipment: 58 b € /year in the EU – Machinery market: >250 b € /year – Telecommunication Services: 200 b € /year • Diverse industry – Big Companies (Nokia, Ericsson, Motorola, Siemens, Philips, Alcatel, Nortel) – Many SMEs in e. g. Short Range Radio markets • Before R&TTE Directive: Many different requirements – > 1000 national regulations, around 30 harmonised EU regulations – fragmentation of spectrum • After R&TTE Directive: less fragmented • Total sectors covered by EMC Directive: 250 b€ atcb. com

EU Market • May 1 st 2004 Members of EU: • Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, The Netherlands, Portugal, Spain, Sweden, United Kingdom, Cyprus, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia atcb. com

R&TTE • For wired and wireless telecommunications equipment • Covers the following aspects: – Efficient use of spectrum – EMC – Safety • Includes EMC and Low Voltage Requirements atcb. com

R&TTE Approval Process • CE Marking by manufacturer is allowed • Self-Declaration for many products • Reduced approval procedures and processes • Harmonized standards developed • Faster, cheaper, more market coverage for SME atcb. com

Annexes • Annex I: Things NOT covered – Cables, Receive-only broadcast, Kits, Aviation and Air Traffic, marine • Annex II: Internal Production Control – Basis for all Annexes (good documentation!) • Annex III: Annex II + Testing – Type testing • Annex IV: TCF – Notified Body (for new technologies) • Annex V: Full QA – Accredited Quality Assurance System atcb. com

R&TTE Testing • No longer requires involvement of accredited test house • Test to harmonized standards – Do. C – CE Marking – Ship • Non-harmonized frequencies: – Notification to Governments – Alert Signal (Equipment Class Identifier) – Restricted Geographical Area atcb. com

TCF & NB Opinion • For new technologies WITHOUT harmonized standards • Notified Body or Conformity Assessment Body opinion atcb. com

TCF Documentation • Product description • Conceptual design and manufacturing drawings such as schematics and subassembly drawings • A description and explanation of the drawings, schematics, and operation of the product • A list of all standards that were applied, in full or in part, to show compliance. – If standards were not used or do not exist, then a description and explanation of the solutions used to meet the essential requirements of the directive must be included • Results of design calculations and examinations • Test reports • A copy of the Do. C atcb. com

Self Certification (ALL Harmonized) atcb. com

Self Certification (Standard Harmonized, Frequency NOT harmonized Notification required) atcb. com

Standard NOT Harmonized, Notified Body atcb. com

Which way to go? atcb. com

Harmonized Frequencies (Short Range Devices) • Document CEPT 70 -03 – Lists frequencies and usage in different European countries • Published by: European Conference of Postal and Telecommunications Administrators • Available at: http: //www. atcb. com/techlib/index. asp • European Radiocommunications Office link to National Frequency Plans: – http: //www. ero. dk/EEE 33 BA 9 -9 EE 9 -4252 -AD 6 C-BE 7 EFB 81898. W 5 Doc atcb. com

Examples from CEPT 70 -03 http: //www. atcb. com/techlib/index. asp atcb. com

Notification • Applies to radio equipment using a nonharmonized frequency • If non-harmonized frequency band, the manufacturer must determine if the frequency is available for use in a particular member state • Notify each member state where the equipment is to be sold atcb. com

Notification • Notify the Spectrum Authorities in each member state • Must be made 4 weeks prior to the equipment being offered for sale. atcb. com

Identify Requirements • Market (Countries) • Restrictions (CEPT 70 -03) • Harmonized Standards? (Official Journal) • TCF/Notified Body • Test Suite atcb. com

Example ETSI/EN Standards • Available from www. etsi. org (free!) • Telecom, EMC & Radio Matters • EN 300 386: – Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; Electro. Magnetic Compatibility (EMC) requirements • ETS 300 328: – Radio Equipment and Systems (RES); Wideband transmission systems; Technical characteristics and test conditions for data transmission equipment operating in the 2, 4 GHz ISM band using spread spectrum modulation techniques atcb. com

Getting the CE Marking Procedure for Harmonized Standard • Look in ERC Report 70 -03 for Country Restrictions and Harmonized Standard • Test product to standard • Notify Spectrum Authorities • Prepare final documentation • Label device • Ship atcb. com

Classification • Class 1: equipment, which can freely move and be switched on in the Community (wired equipment, GSM, Receive-only equipment, etc. ) • Class 2: equipment, for which this is not the case (transmitters, which are to be licensed) – Marking: simple marking scheme agreed between Member States: • CE mark only for class 1 equipment (+ NB Numbers) • CE mark + for class 2 equipment (+ NB Numbers) atcb. com

Examples • Short Range Device (SRD) Operating at 433 MHz • Spread Spectrum WLAN/RLAN operating at 2. 4 GHz • GSM phone operating at 900 MHz band atcb. com

Example 1: Short Range Device (SRD) • Equipment Parameters: – 433. 92 MHz – Low power <2. 5 m. W – Modulation: FSK – Duty Cycle: <1% – Integral Antenna – Battery Powered – “Non-Specific Short Range Device” atcb. com

Example 1 SRD: ERC 70 -03 Restrictions atcb. com

Example 1 SRD: ERC 70 -03 Technical Restrictions atcb. com

Example 1 SRD: ERC 70 -03 Standards to Apply atcb. com

Example 1 SRD: ERC 70 -03 Standards to Apply atcb. com

Example 1 SRD: Full R&TTE Requirements • Compliance test requirements – Radio: EN 300 220 -3 • Radio and Spectral Matters – LVD: EN 60065 – EMC EN 301 489 -3 (SRD) • Emissions • Immunity atcb. com

Example 1 SRD: Documentation • Requirements 1. 2. 3. 4. Equipment complies: Test report/TCF Generates and signs DOC Labels equipment Notifies countries before marketing (Only if frequencies are not harmonized) atcb. com

Example 2: Spread Spectrum WLAN/RLAN • Equipment Parameters: – 2400 -2483. 5 MHz – Power <100 m. W EIRP – Duty Cycle: No Restriction atcb. com

Example 2 RLAN: ERC 70 -03 Restrictions atcb. com

Example 2 RLAN: ERC 70 -03 Technical Restrictions atcb. com

Example 2: ERC 70 -03 Standard to Apply atcb. com

Example 2: Standard to Apply atcb. com

Example 2 RLAN: Full R&TTE Requirements • Compliance test requirements – Radio: EN 300 328 • Radio and Spectral Matters – LVD: EN 60950 – EMC EN 301 489 -17 (RLAN) • Emissions • Immunity atcb. com

Example 3: GSM Phone atcb. com

Example 3 GSM Phone: Harmonized Standard for BS atcb. com

Example 3 GSM Phone: Harmonized Standards for Handsets atcb. com

RF Exposure • Harmonised Standards for Electromagnetic Fields • EN 50360 & EN 50361 for handsets atcb. com

Labeling Summary atcb. com

R&TTE Labeling Example NAME OF A COMPANY MODEL NUMBER SERIAL NUMBER FREQUENCY BAND nnnn The Notified Body Number: used when either annex III, IV or V have been used Alert symbol used when frequency is not harmonized atcb. com

Conclusions • Much simpler than in years past • CE Marking allows access to multiple markets • Frequencies increasingly harmonized • Good access to ETSI/EN standards • Worldwide product designs possible for many types of products. atcb. com

Thank You! atcb. com