FCC policy and procedure updates, it’s a big one

Logo of the United States Federal Communications Commission, used on their website and some publications since the early 2000s. (Photo credit: Wikipedia)

The Knowledge Database section of the Office of Engineering and Technology (OET) web site has a significant number of new publications today. The new updates impact technical requirements such as software defined radios, RF safety and Digital Transmission Systems (DTS) measurement procedures. Other updates cover administrative issues as well as  guidance and policy for Telecommunication Certification Bodies.

While the FCC continually updates these policies and procedures as needed, we tend to see the most significant changes going into the spring and fall seasons. Part of the reason for this is the TCB council holds regular training workshops in the spring and fall. The FCC is generally in attendance, and uses the opportunity to update the community on policy matters and technical issues. The training workshops become sort of a deadline for publication in this way. We also see a number of updates just following the training workshops as questions and comments begin to hit the FCC.

You can visit the OET KDB site at https://apps.fcc.gov/oetcf/kdb/index.cfm. Below is a categorized summary with excerpts of the updates for your convenience. If these issues are important to you, I suggest regular checks of the FCC KDB publications to stay current with the rules.

1. Administrative

a. Permissive Change Policy

i. 10/24/2012: D01 Permissive Change Policy v05r02 has been changed to 178919 D01 Permissive Change Policy v05r03 to allow TCBs to approve third party software upgrades as PBA. Permissive changes and RF exposure considerations has been changed to reference the published RF exposure KDB procedures.

b. Permit But Ask List

i. 10/24/2012: 388624 D02 Permit But Ask List v11 replaces 388624 D02 Permit But Ask List v10 Several changes have been made to the document to clarify the types of devices subject to the PBA review process.

c. Software Defined Radio Application Guide

i. 10/24/2012 442812 D01 SDR Apps Guide v02 has been changed to 442812 D01 SDR Apps Guide v02r01. Removed the requirement for non-SDR to file a Class II permissive change directly with the Commission.

d. TCB Exclusion List

i. 10/25/2011 628591 D01 TCB Exclusion List v12r02 replaces 628591 D01 TCB Exclusion List v12r01. Removed Access Broadband over Power Line (BPL) devices (Part 15 Subpart G);

ii. 10/24/2012 D01 TCB Exclusion List v13 replaces 628591 D01 TCB Exclusion List v12r02. Clarified requirements for devices subject to RF Exposure requirements; removed non-SDR Class II permissive change applications for certain types of devices.

e. SAR Listings on Equipment Authorization Grants

i. 10/24/2012: 690783 D01 SAR Listings on Grants v01r01 has been changed to 690783 D01 SAR Listings on Grants v01r02 to reflect changes made to RF exposure guidance.

2. Technical

a. Mobile and Portable Devices RF Exposure Procedures and Equipment Authorization Policies

i. 10/24/2012: 447498 D01 General RF Exposure Guidance v04 has been changed to 447498 D01 General RF Exposure Guidance v05. The new version (v05) is a major revision to version 04.

b. Guidance for Performing Compliance Measurements on Digital Transmission Systems (DTS) Operating Under §15.247

i. 10/04/2012: 558074 D01 DTS Meas Guidance v01 has been changed to 558074 D01 DTS Meas Guidance v02. V02 is a major change to the v01 guidance with additional measurement options.

c. Restrictions on Software Configuration for devices not approved as Software Defined Radios

i. 10/24/2012 Publication: 594280 D01 Software Configuration Control v01r01 has been changed to 594280 D01 Software Configuration Control v01r02 Removed for Non SDR the requirement to file a Class II permissive change directly with the Commission.

d. SAR Evaluation Considerations for Laptop, Notebook, Netbook and Tablet Computers

i. 10/24/2012: 16217 D04 SAR for laptop and tablets v01 replaced previous guidance:616217 D01 SAR for Laptop with Screen Ant v01r01, 616217 D02 SAR Policy Laptop with Screen Ant v01r01and 16217 D03 SAR Supp Note and Netbook Laptop v01

e. SAR Evaluation Considerations for Wireless Handsets

i. 10/24/2012: 6648474 D04 SAR Handsets Multi Xmiter and Ant v01 replaces 48474 D01 SAR Handsets Multi Xmiter and Ant v01r05 and 648474 D02 SAR Polcy Handsts Multi Xmiter Ant v01r01

f. Emissions Testing of Transmitters with Multiple Outputs in the Same Band (e.g., MIMO, Smart Antenna, etc)

i. 10/25/2011: 662911 D01 Multiple Transmitter Output v01 changed to 662911 D01 Multiple Transmitter Output v01r01 to add references to new attachment 662911 D02 in the second paragraph of the document and in the INTRODUCTION section. The referenced attachment identifies an exception to the requirement for summing emissions across outputs in certain cases involving devices that drive cross-polarized antennas and identifies the need to sum radiated emissions across polarizations in certain other cases.

g. MIMO with Cross-Polarized Antenna

i. NEW POLICY AND PROCEDURE

h. Guidelines for Compliance Testing of Unlicensed National Information Infrastructure (U-NII) Devices Part 15, Subpart E

i. Too many to list, see KDB

i. SAR Evaluation Considerations for LTE Devices

i. 10/24/2012 941225 D05 SAR for LTE Devices v02 replaces 941225 D05 SAR for LTE Devices v01. Version v02 represents a major revision to version v01.

REF:

Office of Engineering and Technology Laboratory Division Knowledge Database (KDB)

R&TTE Directive List of Harmonized standards updated

A new list of “Harmonised” standards has been published in the Official Journal of the European Union with reference to the Radio and Telecommunications Terminal Equipment  Directive 1999/5/EC .

Below is a table of the most recent updates, or go directly to the full Publication of titles and references of harmonised standards under the directive.

 

ESO (1)	Reference and title of the harmonised standard (and reference document)	Reference of superseded standard	Date of cessation of presumption of conformity of superseded standard Note 1	Article of Directive 1999/5/EC
Cenelec	EN 50360:2001/A1:2012 (new) Product standard to demonstrate the compliance of mobile phones with the basic restrictions related to human exposure to electromagnetic fields (300 MHz - 3 GHz)	Note 3	13/02/2015	Article 3(1)(a)
Cenelec	EN 60730-1:2011 (new) Automatic electrical controls for household and similar use -- Part 1: General requirements IEC 60730-1:2010 (Modified)			Article 3(1)(a) (and Article 2 2006/95/EC) + Article 3(1)(b)
Cenelec	EN 61000-3-12:2011 (new) Electromagnetic compatibility (EMC) -- Part 3-12: Limits - Limits for harmonic currents produced by equipment connected to public low-voltage systems with input current > 16 A and <= 75 A per phase IEC 61000-3-12:2011	EN 61000-3-12:2005 Note 2.1	16/06/2014	Article 3(1)(b)
ETSI	EN 300 220-2 V2.4.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD); Radio equipment to be used in the 25 MHz to 1 000 MHz frequency range with power levels ranging up to 500 mW; Part 2: Harmonized EN covering essential requirements under article 3.2 of the R&TTE Directive	EN 300 220-2 V2.3.1 Note 2.1	28/02/2014	Article 3(2)
ETSI	EN 300 328 V1.8.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); Wideband transmission systems; Data transmission equipment operating in the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive	EN 300 328 V1.7.1 Note 2.1	31/12/2014	Article 3(2)
ETSI	EN 301 489-17 V2.2.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment; Part 17: Specific conditions for Broadband Data Transmission Systems	EN 301 489-17 V2.1.1 Note 2.1	31/05/2014	Article 3(1)(b)
ETSI	EN 301 489-34 V1.3.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 34: Specific conditions for External Power Supply (EPS) for mobile phones	EN 301 489-34 V1.1.1 Note 2.1	28/02/2014	Article 3(1)(b)
ETSI	EN 301 559-2 V1.1.2 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM);Short Range Devices (SRD); Low Power Active Medical Implants (LP-AMI) operating in the frequency range 2 483,5 MHz to 2 500 MHz;Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive			Article 3(2)
ETSI	EN 301 843-1 V1.3.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for marine radio equipment and services; Part 1: Common technical requirements	EN 301 843-1 V1.2.1 Note 2.1	31/05/2014	Article 3(1)(b)
ETSI	EN 301 893 V1.7.1 (new) Broadband Radio Access Networks (BRAN); 5 GHz high performance RLAN; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive	EN 301 893 V1.6.1 Note 2.1	31/12/2014	Article 3(2)
ETSI	EN 302 288-2 V1.6.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices; Road Transport and Traffic Telematics (RTTT); Short range radar equipment operating in the 24 GHz range; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive	EN 302 288-2 V1.3.2 Note 2.1	31/12/2013	Article 3(2)
ETSI	EN 302 774 V1.2.1 (new) Broadband Wireless Access Systems (BWA) in the 3 400 MHz to 3 800 MHz frequency band;Base Stations;Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive	EN 302 774 V1.1.1 Note 2.1	31/12/2013	Article 3(2)

NOTE: Date Format is the European Date Format DD/MM/YYYY (List is an excerpt for the list provided at http://ec.europa.eu/enterprise/policies/european-standards/harmonised-standards/ and only represents new items)

For links to this and lists for other directives, please visit Compatible Electronics’ European Conformity Assessment page.

EMC Directive List of Harmonized standards updated

A new list of “Harmonised” standards has been published in the Official Journal of the European Union with reference to the Electromagnetic Compatibility Directive 2004/108/EC .

Below is a table of the most recent updates, or go directly to the full Publication of titles and references of harmonised standards under the directive.

ESO(1)	Reference and title of the harmonised standard (and reference document)	Reference of superseded standard	Date of cessation of presumption of conformity of superseded standard Note 1
Cenelec	EN 50083-2:2012 (new) Cable networks for television signals, sound signals and interactive services -- Part 2: Electromagnetic compatibility for equipment	EN 50083-2:2006 Note 2.1	21/06/2013
Cenelec	EN 50550:2011 Power frequency overvoltage protective device for household and similar applications (POP) EN 50550:2011/AC:2012 (new)
Cenelec	EN 60730-1:2011 (new) Automatic electrical controls for household and similar use -- Part 1: General requirements IEC 60730-1:2010 (Modified)	EN 60730-1:2000 and its amendments Note 2.1	01/10/2013
Cenelec	EN 60947-3:2009/A1:2012 IEC 60947-3:2008/A1:2012 (new) Low-voltage switchgear and controlgear -- Part 3: Switches, disconnectors, switch-disconnectors and fuse-combination units	Note 3	21/03/2015
Cenelec	EN 61000-3-12:2011 (new) Electromagnetic compatibility (EMC) -- Part 3-12: Limits - Limits for harmonic currents produced by equipment connected to public low-voltage systems with input current > 16 A and <= 75 A per phase IEC 61000-3-12:2011	EN 61000-3-12:2005 Note 2.1	16/06/2014
Cenelec	EN 61439-3:2012 (new) Low-voltage switchgear and controlgear assemblies -- Part 3: Distribution boards intended to be operated by ordinary persons (DBO) IEC 61439-3:2012
Cenelec	EN 61800-3:2004/A1:2012 IEC 61800-3:2004/A1:2011 (new) Adjustable speed electrical power drive systems -- Part 3: EMC requirements and specific test methods	Note 3	19/12/2014
ETSI	EN 300 386 V1.6.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; ElectroMagnetic Compatibility (EMC) requirements	EN 300 386 V1.5.1 Note 2.1	30/11/2015
ETSI	EN 301 489-34 V1.3.1 (new) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 34: Specific conditions for External Power Supply (EPS) for mobile phones	EN 301 489-34 V1.1.1 Note 2.1	28/02/2014

NOTE: Date Format is the European Date Format DD/MM/YYYY (List is an excerpt for the list provided at http://ec.europa.eu/enterprise/policies/european-standards/harmonised-standards/  and only represents new items)

 

For links to this and lists for other directives, please visit Compatible Electronics’ European Conformity Assessment page.

Update to Radio Equipment Rules proposed by European Commission

Outside the Berlaymont building of the European Commission (Photo credit: Wikipedia)

The European Commission proposed on Wednesday to update the Radio Equipment Directive. The proposal has three main goals;

1. To Strengthen the level of Compliance with the Directive
2. To Clarify the Directive
3. To Simplify the Directive

Market surveillance will be a big part of the primary objective to strengthen the level of compliance. The new requirements will clearly spell out the responsibilities and obligations for every market player be it the manufacturer or importer. Simplification will come in the form of reduced administrative overhead such as suppression of notification requirements of certain products. The proposal also introduces some new requirements such as control of Software, and Interoperability with accessories, and networks.

The new R&TTE directive is also to be aligned with the New Legislative Framework (NLF). The NLF negotiations were conducted at the Member States level, and without consideration for specific Directives. As a result many of the New Approach Directives have become misaligned with the NLF. In late 2011 a package of 9 other recast draft directives, “aligned” with the NLF have been submitted to the EU Council and Parliament.

· Low Voltage Directive 
· EMC Directive
· ATEX Directive
· Lifts Directive
· Simple Pressure Vessels Directive
· Measuring Instruments Directive
· Non-automatic Weighing Instruments Directive
· Civil Explosives Directive
· Pyrotechnic Articles Directive
 
Ref:
Draft RE directive
http://europa.eu/rapid/press-release_IP-12-1109_en.htm
http://ec.europa.eu/enterprise/sectors/rtte/documents/legislation/review/index_en.htm
http://ec.europa.eu/enterprise/policies/single-market-goods/regulatory-policies-common-rules-for-products/new-legislative-framework/

Crackdown on jammers continue with “NOJAM” and action against sellers on Craigslist

No one I know (Photo credit: Mickipedia)

The FCC has a new weapon in its continued efforts to aggressively enforce the law with respect to the sale and use of illegal radio jammers. The new weapon is a dedicated jammer tip hotline, 1-855-55-NOJAM. The hotline is intended to make it easier for the general public to report offenders.

The Press Release announcing the new hotline encourages the public to call the hotline if;

• you are aware of the ongoing use of a cell, GPS, or other signal jammer;
• your employer operates a jammer in your workplace;
• you observe a jammer in operation at your school or college;
• you observe an advertisement for a jammer at a local store; or
• you observe a jammer being operated on your local bus, train or other mass transit system.

In the Press Release, Michele Ellison, Chief of the Enforcement Bureau, said: “We need consumers to be our eyes and ears. Jammers do not just weed out noisy or annoying conversations and disable unwanted GPS tracking, they can prevent 9-1-1 and other emergency phone calls from getting through in a time of need.”

On the same day of the announcement, the Enforcement Bureau took action against another six individuals for advertising and selling signal jammers on the popular classified ad web site Craigslist.org. The actions come with a warning that the FCC intends to impose “Substantial Monetary Penalties” for similar violations going forward.

So how much will that $45 illegal jammer really cost? The Consumer Alert issued within an FCC Enforcement Advisory  explains penalties can exceed $100,000 per violation.

More about the activities related to jammer enforcement can be found on the Commission web site, http://www.fcc.gov/encyclopedia/jammer-enforcement.

REF:

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DOC-316795A1.pdf

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DOC-316796A1.pdf

http://transition.fcc.gov/Daily_Releases/Daily_Business/2012/db1015/DA-12-1642A1.pdf

Domestic Unlicensed Modular Radio Approval

Transmitter (Photo credit: Thorius)

What is a modular approval, how does one qualify for one, and what are some of the advantages and disadvantages in selecting to pursue a modular radio approval. I’ve addressed these questions in summary form here, and I provide some links for further reading.

A modular approval allows the approved product to be installed in different host devices, without the need for additional testing or authorization for the transmitter for each host system. Note that the host itself may still require authorization or reauthorization depending on the host, but the transmitter would not need to be recertified for each host.

There are 4 types of modular approvals;

1. Single-Modular transmitter

2. Limited Single-Modular transmitter

3. Split-Modular transmitter

4. Limited Split-Modular transmitter

A single-modular device is a device in a single package, and a split-modular is one where the radio front end and the control elements section may be separate.

The use of the word “Limited” indicates that the device may have certain grant conditions or be reliant on a specific host configuration for compliance. Integrators are cautioned to pay close attention to these limitations.

To qualify for modular approval, the device must comply with 8 specific conditions. For a Single-modular transmitter, the device is a self contained, physically delineated component that can demonstrate compliance independent of the host.

1. Radio circuitry must be shielded

2. Modulation / data inputs must be buffered.

3. Power supply regulation on the module

4. Permanent antenna or unique connector

5. Must demonstrate compliance stand alone (outside host)

6. Labeled with its own permanently fix FCC ID, or have electronic display capability

7. Must comply with applicable rules, and with grantee provided conditions

8. Must comply with applicable RF exposure requirements

A limited modular approval may be granted when a device does not meet all 8 of the conditions, but may rely on a specific host and applicable operating conditions for compliance. For instance, the shielding, buffered I/O or power regulation may be provided by a specific host. In these cases the module would be “Limited” to the specific host providing those requirements.

The first and probably most obvious benefit to a modular approval is that the radio module would not need to be recertified for every host installation, thus saving time and money when incorporating radio functions into multiple host devices. Other advantages may include;

· Changes to the host don’t affect the radio certification (except on “Limited modular”)

· Time to market for a new host is considerably less if the product does not require certification

· Ease of managing the radio certification, one FCC ID instead of many.

· Flexibility with installation within the host (except maybe on “Limited modular”)

· If the module is the product, it’s more attractive for an integrator to use a pre-certified device.

· The radio may be “End-User” replaceable (potential upgrade or repair)

Some items that may be negative points to a modular approval;

· Radio generally more expensive due to shielding, buffered i/o and power regulation

· Depending on host/antenna placement, transmitter power may be less than non-module type

· Integrating multiple transmitters (co-location) within a single host can be problematic

Things to pay attention to when using an already approved module;

· Be aware of the type of module and grant conditions or restrictions

· The term “Modular approval” is specific, if unsure check the FCC ID and look at the grant

· Follow all installation instructions and warnings provided by the grantee

Other things to possibly consider are RF exposure and/or hearing-aid compatibility, for devices with specific antennas, or specific host/enclosure configurations. The FCC has published a “Transmitter Module Equipment Authorization Guide”, KDB 996369, and I recommend reading through the guide if considering the modular approach.

To check a prospective module’s FCC approval, have the FCC ID ready and visit;

https://apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm

Keep in mind, the first 3 characters of the FCC ID are the Grantee Code, and note that the numbers 1 or 0 will never be part of the grantee code (to avoid confusion with the letters i and o). The grant will clearly indicate “Modular Approval” or “Limited Modular Approval” (LMA) if the device is so approved. At the time of writing this article, the FCC system only searches based on the legacy system of 3 digit grantee codes, however, the FCC is moving to a 5 digit grantee code system real soon – see http://www.emcrules.com/2012/06/fcc-running-out-of-grantee-codes.html

Compliance testing and certification costs of a Single-Modular transmitter are comparative to that of a non-modular approval of the same radio in most cases, in some cases it could be less expensive due to the simplified test setup and configuration of the module. Time and cost of Limited-Modular devices can vary depending on the host.

Of course this all applies to domestic FCC certification, but what about other regions?

Canada has a very similar approach to radio modules, see RSS-Gen, section 3.2.2 for details. In Europe, there is no “Modular Approval” process as the system is based on self-certification, but a somewhat similar approach can be taken, please see my article “Radio module integration and R&TTE compliance” for dealing with radio modules under the R&TTE Directive.

Free electromagnetic compatibility (EMC) seminar in Orange County

IEEE Logo (Photo credit: Wikipedia)

It’s not often you get something for nothing these days, remember the old phrase, “There ain't no such thing as a free lunch”, well, this one will surely interest any engineers out there responsible for product compliance or EMC, and the best part is It's free. Mark your calendar!

The Orange County IEEE EMC chapter is hosting a presentation by  Mr. Kenneth Wyatt, Sr. EMC engineer with Wyatt Technical Services, LLC.

For over 20 years Mr. Wyatt has worked as a senior EMC engineer with Hewlett-Packard and Agilent Technologies. Kenneth is a senior member of the IEEE and a long time member of the EMC Society.

The presentation is titled “EMC Troubleshooting Kit, Workbench Measurements and Common Problems”.  This free and valuable presentation focuses on pre-compliance measurements and techniques, an indispensible tool set for anyone responsible for product compliance.

For more information, date time and location, and to register, please see IEEE vTools Meetings.