TCB Sharing of FCC KDBs

1
TCB Sharing ofFCC KDBs

• Michael Derby
• TCB Council Chairman
• 9th April 2014

2
Introduction

• Overview of the main FCC KDB types
• General KDB enquiries
• Proposal for improvement and education of our
  industry
• Examples
• Feedback

3
KDB Types

• Main types of KDB sent from the FCC
• General information sent by the FCC
• KDB 558074 for DTS, KDB 447498 for RF Exposure
• Response to enquiry specific to project
• Model XYZ does ABC can I proceed with this
  result?
• FCC will reply specific to that project
• Will include KDBs such as PBA
• Do not share these KDB responses

4
KDB Types

• Main types of KDB sent from the FCC
• Response to enquiry general guidance
• In general, with X situation what do I do?
• Not project specific (even if you asked because
  of a project!)
• FCC will reply general interpretation of their
  rules
• Often very useful to everyone
• This is what were talking about!

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General KDB Enquiries

• Sent to the FCC by a TCB, Test Lab or
  Manufacturer for general guidance
• Not specific to one project or model
• Useful, informative guidance from the FCC
• Would benefit the whole industry
• Note that if the KDB guidance is restrictive in
  any way, then it may be advantageous to share
  this!
• This could also apply to guidance from IC

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KDB Sharing Proposal

• We propose to gather these and share
• Recipient sends them to the TCB Council
• We e-mail to members, if appropriate
• We present details at the subsequent workshop
• At the time of writing these slides, the exact
  format has yet to be agreed with the FCC and
  Industry Canada

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Examples

• Three examples of what we mean
• Full KDB text not included at this time
• Full KDB may be e-mailed to TCBC membership with
  agreement from the FCC and the company who
  submitted the KDB enquiry
• Text may be copied from original KDB to provide
  anonymity in certain cases

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Limited Modular Approval

• Can a module without a shield be tested in a
  stand-alone configuration, for LMA?
• FCC No
• Limited Modules must be tested in a typical host
  device and/or configuration
• For a module with no shield, this would mean
  testing must be performed with the module
  inside the host
• LMA is literally limited to a specific host or
  group
• Module Grantee is responsible for compliance of
  the module in the final host product, not the OEM

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Non-USA Frequency Changes

• Changing non-USA frequency band hardware such as
  900 MHz / 1800 MHz components
• Can this be a Permissive Change because those
  bands are not listed on the FCC Grant?
• FCC This requires a new FCC ID
• This cannot be a Permissive Change
• Certification covers all transmitter hardware
• Changes would make it non-identical

10
DTS Duty Cycle and 15.35

• KDB 558074 for DTS states that spurious emissions
  cannot apply 15.35(c) duty cycle
• Can we use it for devices with fixed duty cycle?
• FCC This is an acceptable deviation
• 15.35(c) can be applied to maximum duty cycle
• Duty cycle must be source based (hard-wired)
• Expect modification in next KDB 558074

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Useful Proposal?

• What do you think?
• Do you think this is useful?
• Would you be happy to receive this information?
• Would you be happy to send this information?
• Please send information, concerns, suggestions
  and KDB replies! to the TCB Council

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Thank You

• Michael Derby
• TCB Council, Chairman
• michaeld_at_acbcert.com