How to Create a Part 15C Report

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How to Create a Part 15C Report
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What is Part 15C?

• Part 15C is the Rule section set aside for
  Intentional Radiators
• Covers low power devices which are License
  Exempt
• Part 15D, E, and F devices also are considered
  Intentional Radiators and follow the outline of
  this chapter. Only Part 15C devices are
  considered here because they generally are more
  common

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What is an Intentional Radiator

• An Intentional Radiator is the legal term used by
  FCC to cover all cases of low power license
  exempt transmitters. These transmitters typically
  are used for short range communications, remote
  control, or field disturbance sensors.
• Each rule has it is own requirements.

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Test Report Construction Notes

• All Part 15C devices use ANSI C63.4 as a basis
  for report construction.
• All Part 15C reports use all information in the
  previous Part 15B presentation, and then adds
  more requirements.
• See How to Create a Part 15B Report

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Building a Test Report

• All Part 15 filings use ANSI C63.4 as a guide for
  building Test Reports.
• See Section 10 for general report requirements.
• Details of the measuring equipment and OATS are
  required.
• Photographs of the Test Setup are necessary.

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Required Exhibits

• AmericanTCB has its own easy-to-use application
  form in MS Word format for use in all filings. A
  completed Application is required before any work
  can proceed.
• In addition to the Test Report a number of
  specific Exhibits are required.

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Exhibits which accompany all filings

• Label
• Internal Photographs
• External Photographs
• Cover Letters
• Operational Description
• Schematics
• Block Diagrams
• Manual
• Test Setup Photographs
• Can be held Confidential

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Additional Exhibits

• Part 15C Spread Spectrum transmitters (802.11g
  and Bluetooth) are required to submit RF Exposure
  information because the Rules allow relatively
  high power.
• Part 15D (Unlicensed PCS) and Part 15E (802.11a)
  also have specific RF Exposure requirements

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RF Exposure

• RF Exposure is a complex area and is relatively
  one of the newest sections of the Rules.
  Requirements are still changing and may need
  additional care before testing or filing
• Check and consult with ATCB to determine if any
  recent regulatory changes

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Finding FCC Regulations

• The Government Printing Office now provides
  on-line FCC Rules.
• These are the most recent available and usually
  are the best for updates
• http//ecfr.gpoaccess.gov/cgi/t/text/text-idx?cec
  frtpl2Findex.tpl

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Laboratory Test Procedures

• The FCC does not maintain a current listing of
  test procedures for Part 15C devices.
• FCC prefers to use industry standards from IEEE.
  However, many changes are not documented
  adequately.
• Check with ATCB for proper current testing
  methodologies.

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Restricted Bands

• Certain protected frequency bands are considered
  vital to our national interests. No transmitter
  may have any fundamental emissions within the
  specified bands in the following table
• Only radiated spurious emissions which meet the
  Class B limits are permitted

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Antennas

• FCC considers Part 15 transmitters to be approved
  as a unified system from the transmitter, coax
  and antenna.
• Only antennas approved with the device are
  allowed to be used.
• New or additional antennas are permitted but only
  through the Class II Permissive Change process

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Antenna Connectors

• Antenna connectors accessible by the end user
  must be unique.
• The idea is that they should discourage the end
  user from ever utilizing any non-approved
  antennas
• Must fail the Radio Shack test

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Amplifiers

• Amplifiers are not permitted to be added to any
  Part 15 transmitter except in very explicit
  situations.
• Amplifiers must be paired with specific,
  separately approved and Certified unlicensed
  intentional radiators only.
• Very specific and restrictive marketing
  requirements apply.

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Controls

• End users must not be given any ability to change
  the operating parameters to operate outside of
  its operational parameters.
• For 802.11g devices, this means that the end user
  must not be given access to country codes to
  allow operations on Channels 12 or 13.

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Modular Approvals

• Modular Approvals and Limited Modular Approvals
  (LMA) are permitted under the Rules.
• These allow third party manufacturers to
  incorporate Certified transmitters into their
  equipment easily
• Specific additional documentation requirements
  are required.
• See ATCB for the latest changes to Modular
  Approval interpretations

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Questions?

• whgraff_at_atcb.com
• major_at_atcb.com
• jerry_at_atcb.com