FCC Rules Seminar Taipei, Taiwan April 2004

1
FCC Rules SeminarTaipei, Taiwan April 2004
www.atcb.com
2
AmericanTCB Taiwan

• AmericanTCB, Inc.3F, 201, Ti Ding Avenue, Sec.2,
  
• Neihu 114 Taipei, Taiwan
• Major ChenSales Manager
• Phone [phone] ext 311
• Tim Johnson 886 092039926
• www.atcb.com

3
WELCOMEand Thank You to our Sponsors

• Trivet Industrial Corporation
• Richtec Instruments Co., Ltd
• Training Research Corporation (TRC)
• EMIEMC (Item Publications)

4
Seminar Schedule and Overview

• Introduction Overview of FCC Rules
• Bill Graff 1 00-145
• Latest NPRMs and Rules Changes
• Tim Johnson 145-230
• New requirements for Specific Absorption Rate
  (SAR) Testing
• Bill Graff, ATCB 230-315
• Break 315-330
• Feature Presentation by Sponsors
• Jones Yen, Trivet Industrial Corporation
• Frank Tsai, TRC 330-400
• P.H. Yuan, Richtech 330-430
• European Update
• Mike Violette, ATCB 430-500
• QA
• 500-530
• Reception
• 530-730

5
Fundamental Rules SeminarWilliam H. Graff,
AmericanTCB
6
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.

7
FCC 47 CFR Regulations

• Part 2 General Requirements
• Part 5 Experimental Radio Service
• Part 15 Subpart C, D, and E Unlicensed Low Power
  Transmitters (802.11a/b/g, Bluetooth, etc.)
• Part 20 Common Carrier
• Part 21 Domestic Public Service
• Part 22 Public Mobile Service
• Part 24 Licensed PCS

8
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

9
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

10
FCC 47 CFR Regulations

• FCC does not regulate
• safety (except RF Exposure)
• susceptibility
• product performance

11
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

12
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

13
Licensed Radio Services Test Parameters

• In most cases - the actual Radio Service rules
  have special or unique requirements and
  additional testing parameters.

14
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

15
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.

16
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.

17
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.

18
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.

19
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

20
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 _at_ 10 Log (0.01) -20 dBc
• Other rule sections may call out -23 or -26 dBc

21
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 dB equal to the level of the unmodulated
  carrier.

22
Emissions Mask ExampleAnalog Modulation
Mask
23
Emissions Mask ExampleDigital Modulation
24
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.

25
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.

26
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 10th
  harmonic.

0
27
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.

28
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 !

29
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

30
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 TSB102
  (Digital C4FM/CQPSK Transceivers Measurement
  Method

31
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

32
Common Part 22 H Cellular Emission Designators

• 40K0F8W AMPS Cellular voice signaling tone
• 40K0F1D AMPS Cellular wideband data
• 1M25F9W CDMA (IS 95/98)
• 30K0DXW - North American digital cellular - TDMA
• 300KGXW GSM
• 300KG7W - EDGE

33
Emission Designator Calculation

• Emission Designator
• 40K0F8W - Voice SAT signal
• Voice (M2.5k, D12k), SAT (M6k, D2k)
• Pick highest frequency and add deviations and
  apply Carsons Rule 2M2D
• 2(6k) 2(12k2k) 1228 40 kHz
• 40K0F8W - Signaling Tone (ST) SAT
• ST (M10k, D8k), SAT (M6k, D2k)
• 2(10k) 2(8k2k) 2020 40 kHz
• 40K0F1D - Wideband Data
• Data (M10k, D8k), SAT (M6k, D2k)
• 2(10k) 2(82) 2020 40 kHz

34
Example Part 22 H Grant
35
Certification Checklist for Licensed Services

• Applicant Name Correct
• Test Firm
• FCC ID number
• Equipment Functional Description
• Equipment Class

36
Certification Checklist for Licensed Services

• Confidentiality Request Letter
• Letter with details to be included with
  confidentiality.
• Commonly only 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

37
Certification Checklist for Licensed Services

• Technical Information
• Rule Part(s)
• Frequency Range
• Power Output

38
Certification Checklist for Licensed Services

• Antenna Port
• (Real Connection or Integral antenna?)
• Frequency Tolerance
• Emissions
• Necessary Bandwidth Values Justified
• Emission Type Justified

39
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

40
Certification Checklist for Licensed Services

• Photos (Internal External) Technical Report
• Power Output
• (ERP/EIRP or Conducted? Peak or Average?)
• Audio Frequency Response
• Modulation Limiting

41
Certification Checklist for Licensed Services

• Frequency Stability vs Voltage
• 15 and Battery end point
• Frequency Stability vs Temperature
• -30C to 50C

42
Required Exhibits for Licensed Services

• Agent Authorization Letter
• Confidentiality Request
• Schematics
• Block Diagram
• RF Exposure Evaluation
• Operational Description
• Tune Up Procedure

43
Required Exhibits for Licensed Services

• External Photographs
• Internal Photographs
• Sample Label with FCC ID
• Label Location
• Test Setup Photographs
• Users Manual
• Test Report

44
Timothy R. Johnson, American TCB
Recent FCC Clarifications, Latest NPRMs and
Rules Changes
45
Presentation Overview

• Part 15 Recent Interpretation Issues, Reminders,
  and Application Concerns
• Part 15 Rulemaking updates
• NPRMs, Report and Orders, etc.

46
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.)

47
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 802.11g
  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

48
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.

49
AC Line Conducted Emissions for Part 15 Modules
Cont.

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

50
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.

51
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.

52
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.

53
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.

54
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.

55
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/SilverStream/Pages/pg_html_fts_res.html?le
  tter1344

56
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.

57
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.

58
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

59
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/SilverStream/P
  ages/Fpg_html_fts_res.html?letter1366
• 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
• Professional installation and specific types of
  pits

60
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 C63.4 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

61
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.

62
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
• Must be locked prior to shipment

63
15.407(d) Integral Antenna Requirement for 5.2
GHz UNII Devices Cont.

• An antenna and/or connectors inside of a
  non-accessible (there is no need for the user to
  ever open the case)
• Note that it is assumed that users will open
  desktop computers.

64
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.

65
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

66
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.

67
Configuration of Antennas for Testing

• The FCC has recently developed 2 concerns
  regarding test configurations for the antennas of
  a modular approval.

68
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

69
Configuration of Antennas for Testing Cont.
70
Configuration of Antennas for Testing Cont.

• In this example the monopole antennas should be
  supported in vertical position, e.g., using
  foamed-polystyrene blocks

71
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.

72
Configuration of Antennas for Testing Cont.
73
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.

74
Co-located Transmitters, i.e. Laptop w/ LAN
Bluetooth Cont.

• Co-Location is typically defined as when 2
  transmitter antennas are located lt 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

75
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

76
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

77
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

78
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.

79
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
  200009-13-004

80
NPRMs

• 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.

81
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 03-223
• http//hraunfoss.fcc.gov/edocs_public/attachmatch/
  FCC-03-223A1.doc
• Published December 10, 2003
• Public comments were due February 7, 2004

82
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

83
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

84
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-03-289A1.doc
• News Release
• http//hraunfoss.fcc.gov/edocs_public/attachmatch/
  DOC-241226A1.doc

85
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

86
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-04-29A1.pdf
• 1) Access broadband operational requirements
• 2) Equipment authorization and measurement
  guidelines

87
Report and Order

• Report and Order (RO)
• 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

88
2nd RO and MOO Part 15Deregulation

• New Rules in ET Docket No. 01-278, FCC 03-149
• Effective date January 8, 2004
• http//hraunfoss.fcc.gov/edocs_public/attachmatch/
  FCC-03-149A1.doc

89
2nd RO and MOO Part 15Deregulation 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

90
2nd RO and MOO Part 15Deregulation Cont.

• 5) Other changes to update and correct FCC rules.
• Incorporate the ANSI C63.17 test procedure for
  UPCS devices into the rules
• Provide exemption for certain low power devices
  lt490 kHz and FS is less than 40 dB below Part 15
  limits
• Allow user manual information on CD-ROM or on
  internet if manual is provided likewise
• FRS transmitters tested -20 to50 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 bodys
  name, designation number and date of renewal
• Miscellaneous rule corrections and deletions

91
RO UNII Devices

• New Rules in ET Docket No. 03-122
• Effective date, February 19, 2004
• http//hraunfoss.fcc.gov/edocs_public/attachmatch/
  FCC-03-287A1.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 and 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

92
RO 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

93
RO 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
  5.25-5.35 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

94
Additional References

• FCC Interpretation Database
• https//svartifoss2.fcc.gov/prod/oet/cf/ri/FccEasR
  i.cfm

95
RF Exposure TutorialWilliam H. Graff,
AmericanTCB
96
Portable vs. Mobile

• Specific definitions for RF exposure
• Mobile Greater than 20 cm
• Portable Less than 20 cm

97
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

98
MPE calculation

• MPE calculations assume a linear plane-wave
  field.
• Considered an overestimate of maximum field
  density
• Not applicable to distances under 20cm
• Cannot predict interaction with nearby structures

99
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

100
Example Systems
SPEAG
IndexSAR
Aprel/IDX
101
P1528 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 590051998
  (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

102
SAR Mapping Systems

1. control and data capture unit
2. field-probe readout electronics
3. dosimetric E-field probe
4. probe positioner
5. unwanted ambient fields
6. phantom shell with tissue-equivalent liquid,
7. device-under-test
8. device holder/positioner.

coarse scan over device outline to locate
hot-spots
103
Head Phantom

• SCC-34/SC-2 head model - SAM

M
N
(Source IEEE SCC-34/SC-2, P1528 Draft)
104
SAR Test Positions
M

• 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

105
Limitations of P1528

• Does not address all body worn configurations
• Does not address methodologies above 3GHz
• Does not address non-standard ear-held devices
  which do not conform to M to LE or RE line

106
SAR Limits

• Experiments with laboratory rats
• Scaled up to humans using known models borrowed
  from pharmaceutical industry

107
Supplement C Exposure Limits
108
Supplement C SAR Limits
109
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

110
Differences in Limits

• Limit for Controlled exposure in the head 4W/kg
  (4mW/g)
• Limit for Uncontrolled exposure in the head
  1.6W/kg (1.6mW/g)

111
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

112
Portable PTT

• Part 80, 90, 95
• FCC SAR data required for PTT above 1W radiated
  or conducted
• TCB 60mW/f(GHz)

113
Portable 15.247 and 15.407

• Below 3GHz
• FCC SAR data if above 50-100mW
• TCB 60mW/f(GHz)
• Above 3GHz
• FCC SAR data if above 50mW
• TCB cannot do
• By law, SAR data required for all portable
  UNII devices regardless of Pout

114
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

115
LMA and SAR

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

116
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

117
Simultaneous Transmission

• If radiating structures lt20cm 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 5mw

118
Above 3GHz

• IEEE P1528 does not yet define a methodology for
  SAR testing above 3GHz, therefore all SAR
  evaluation above 3GHz must go to FCC
• Expect approvals from FCC to take 90 days

119
RF Safety Documents for Issues with Human
Exposure

• ANSI C95.1
• OET 65
• OET 65-C
• FCC Part 1.1037
• FCC Part 2.1091 Mobile Devices
• FCC Part 2.1093 Portable Devices
• TCB Exclusion List

120
Future Provisions

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

121
Questions?
122
RTTE DirectiveMichael Violette, P.E.
www.atcb.com
123
European RTTE Directive
124
European RTTE Market

• RTTE equipment 58 b /year in the EU
• Machinery market gt250 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 RTTE Directive Many different
  requirements
• gt 1000 national regulations, around 30 harmonised
  EU regulations
• fragmentation of spectrum
• After RTTE Directive less fragmented
• Total sectors covered by EMC Directive 250 b

125
EU Market

• May 1st 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

126
RTTE

• For wired and wireless telecommunications
  equipment
• Covers the following aspects
• Efficient use of spectrum
• EMC
• Safety
• Includes EMC and Low Voltage Requirements

127
RTTE 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

128
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

129
RTTE Testing

• No longer requires involvement of accredited test
  house
• Test to harmonized standards
• DoC
• CE Marking
• Ship
• Non-harmonized frequencies
• Notification to Governments
• Alert Signal (Equipment Class Identifier)
• Restricted Geographical Area

130
TCF NB Opinion

• For new technologies WITHOUT harmonized standards
• Notified Body or Conformity Assessment Body
  opinion

131
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 DoC

132
Self Certification (ALL Harmonized)
133
Self Certification (Standard Harmonized,
Frequency NOT harmonized Notification required)
134
Standard NOT Harmonized, Notified Body
135
Which way to go?
136
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.as
  p
• European Radiocommunications Office link to
  National Frequency Plans
• http//www.ero.dk/EEE33BA9-9EE9-4252-AD6C-BE7EFB81
  898.W5Doc

137
Examples from CEPT 70-03
http//www.atcb.com/techlib/index.asp
138
Notification

• Applies to radio equipment using a non-harmonized
  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

139
Notification

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

140
Identify Requirements

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

141
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 ElectroMagnetic 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 and
  using spread spectrum modulation techniques

142
Getting the CE MarkingProcedure 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

143
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)

144
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

145
Example 1 Short Range Device (SRD)

• Equipment Parameters
• 433.92MHz
• Low power lt2.5mW
• Modulation FSK
• Duty Cycle lt1
• Integral Antenna
• Battery Powered
• Non-Specific Short Range Device

146
Example 1 SRDERC 70-03 Restrictions
147
Example 1 SRDERC 70-03 Technical Restrictions
148
Example 1 SRD ERC 70-03 Standards to Apply
149
Example 1 SRD ERC 70-03 Standards to Apply
150
Example 1 SRD Full RTTE Requirements

• Compliance test requirements
• Radio EN 300 220-3
• Radio and Spectral Matters
• LVD EN 60065
• EMC EN 301 489-3 (SRD)
• Emissions
• Immunity

151
Example 1 SRD Documentation

• Requirements
• Equipment complies Test report/TCF
• Generates and signs DOC
• Labels equipment
• Notifies countries before marketing (Only if
  frequencies are not harmonized)

152
Example 2Spread Spectrum WLAN/RLAN

• Equipment Parameters
• 2400-2483.5 MHz
• Power lt100mW EIRP
• Duty Cycle No Restriction

153
Example 2 RLAN ERC 70-03 Restrictions
154
Example 2 RLANERC 70-03 Technical Restrictions
155
Example 2 ERC 70-03Standard to Apply
156
Example 2 Standard to Apply
157
Example 2 RLAN Full RTTE Requirements

• Compliance test requirements
• Radio EN 300 328
• Radio and Spectral Matters
• LVD EN 60950
• EMC EN 301 489-17 (RLAN)
• Emissions
• Immunity

158
Example 3 GSM Phone
159
Example 3 GSM Phone Harmonized Standard for BS
160
Example 3 GSM Phone Harmonized Standards for
Handsets
161
RF Exposure

• Harmonised Standards for Electromagnetic Fields
• EN50360 EN50361 for handsets

162
Labeling Summary
163
RTTE 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
164
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.

165
Thank You!