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MultiPoint Newsletter - August 2011 Issue

Dear Colleague,

We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC, IC and CE requirements. The particulars of the product for certification must be considered with respect to the applicability of these questions and answers. We hope you find our update valuable and welcome your feedback if you have any special needs or questions. Call us at 703.689.0368 for your testing requirements. You can view archived issues of MultiPoint at our website.

FCC – Permissive Change Guidelines

Question: The FCC permissive change guidelines state that modifications that increase the output power at the antenna terminal or Effective Radiated Power/Effective Isotropic Radiated Power (ERP/EIRP) can require a Class II permissive change, or even a new FCC ID, if the change in value is significant enough.  The FCC’s current guidelines also seem to indicate that even without any overt changes made to the radio, PCB or antenna by the manufacturer, and unbeknownst to the manufacturer, the output power at the antenna terminal or ERP/EIRP may increase, raising a compliance issue.  Apparently any number of things could contribute to a change in power as described, including manufacturing variability, unknown part change by a vendor, a cabling issue, etc.  Can you elaborate on the applicable FCC policies?

Answer: The FCC rules state that a new FCC ID is required per 47CFR 2.1043 when the output power at the antenna terminal or EIRP/ERP changes by any amount, as a result of changes in circuitry that generate, multiply and stabilize the transmitter’s frequency, modulation circuits, etc.

Please note that notwithstanding these statements, under its Class II permissive change policy , the FCC does allow certain variations in electrical or mechanical construction.

For instance, the FCC would allow the addition of a new frequency band in the case of a change in the FCC rules, or an increase in power, in response to a change in FCC rules, subject to any applicable, new technical requirements implemented by the FCC.

An example of this is a certified UNII device that now can operate in a newly defined UNII frequency band, and is subject to a higher output power limit.  This device is eligible to be reviewed under the Class II permissive change policy if the requirements of are met.

Acceptable Class II permissive changes for devices/antenna systems originally approved under Part 15 include but are not limited to new antenna types, or higher gain antennas, provided they meet the requirements of .

While the FCC allows second-source component usage, a change in vendor could be cause for a Class II permissive change; it will depend on the emissions produced as a result of the change.  The only way to know is to test the second-source component(s) in the device.  If the electro-magnetic characteristics have degraded, then a Class II permissive change would be needed.

If the second-source component change results in a change in power, then it would or could be considered a change in the transmitter, and perhaps require a new FCC ID.

斗地主达人This would be determined by the differences between the original and second-source component.  If the second-source component and original are identical, their only difference being that they are made by different chip manufacturers, this difference could be considered a manufacturer tolerance issue.  However, the original and second-source devices would have to be identical, not just in placement and functionality, but electrically and mechanically identical.  There really is no way to determine if there was an actual change in the transmitter without knowing the exact differences between the original and second-source components.

In years of interfacing with the FCC on second-source component Class II permissive changes for unlicensed and licensed devices, we have found that the FCC typically allows variations of 0.5 dB in output power at the antenna terminal and 3 dB in ERP/EIRP, demonstrated via intentional radiator testing.

However, please note that these variations are strictly unofficial numbers and are not included in the FCC’s rules or policies.  The allowable variance in the manufacturer’s tolerance can only be determined by contacting the FCC directly with the necessary information, and requesting their written confirmation.

Japan – Modular Approval Process

Question: We are a transmitter module manufacturer.  Does the Ministry of Information (MIC) Japan have a modular approval process similar to those of the FCC and IC?

Answer: The answer is that while Japan does not have such a defined policy, MIC, the Japanese regulatory agency, does allow modules to be approved under certain circumstances.  Basically, Japan allows transmitters to be certified when they meet the requirements of Article 2 of the Japanese Radio Law.  This article defines radio equipment to be radiotelegraphy, radiotelephony or other electric equipment used for transmission and/or reception of radio waves.  MIC has stated that Certification Bodies may approve radio equipment that are composed of and contain three components:

  • Antenna
  • Frequency and modulation circuitry
  • Control part circuitry

Certification of a modular transmitter is possible if the following requirements are met:

  1. Equipment has an antenna, high frequency circuitry, modulation circuitry, auxiliary equipment (indicator, etc.) and control circuitry.
  2. The control circuitry can include external equipment connected to it under certain interface conditions.
  3. At the time of entering into market, all parts are completely installed in the equipment.  This means the radio is installed in the final host.
  4. If the equipment is intended to be connected to or installed in external devices when used, the construction of the equipment must be such that it is easily disconnected from the external equipment using a connector, and the device must be obviously identified as specified radio equipment.  This also means that a module soldered onto the host or host board would not be allowed certification in Japan.

As long as the modular transmitter meets the above requirements, then it may be certified for use in Japan.  Any application for certification of a modular transmitter would necessarily need to show how the device meets the above stated requirements.

FCC – 911 & E911 Requirements for Mobile Phones

Question: What is the FCC’s requirement for mobile phones in the U.S. to support Global Positioning System/Assisted Global Positioning System (GPS/A-GPS) for E911 service?

Answer: The FCC has several requirements for mobile phone support of 911 or E911.  All wireless network providers must be in compliance with the E911 requirements by September 11, 2012.

However, as far back as 2005, in the second phase of E911, about 95% of the network operators were supposed to have E911 capabilities.  This meant that wireless network providers had to be able to provide to the Public Safety Answering Point (PSAP), the latitude and longitude of the mobile phone, within 300 meters, within 6 minutes of initiation of the 911 call.

Those wireless network providers who did not have this capability in 2005 were fined, or were supposed to have been fined。

While CDMA has and can use internal handset location features such as GPS, other providers opted to use Assisted GPS (A-GPS).

With a GPS-enabled mobile phone, the wireless network provider uses the radio signals from satellites alone to locate the caller by downloading the GPS A&E (Almanac and Ephemeris).  The downloading of the GPS A&E can take up to 12.5 minutes due to very poor signal conditions in cities where these signals may suffer multipath propagation, attenuation by atmospheric conditions, trees and building walls, including reflection off of buildings, which undermines the GPS-enabled phone’s ability to provide location coordinates.

An Assisted GPS-enabled mobile phone uses data readily available from the network provider server, eliminating the GPS A&E download and related issues of GPS-enabled phones.  The data from the server improves the performance of the Assisted GPS-enabled mobile phone receiver’s time-to-first-fix (TTFF).  This data includes but is not limited to the following:

  1. Information to acquire more satellites quickly.
  2. Orbital data or almanac for the GPS satellites to the A-GPS-enabled mobile phone, thus enabling the A-GPS-enabled mobile phone to lock to the satellites more rapidly in some instances.
  3. Network precise time.
  4. The A-GPS-enabled mobile phone can capture a snapshot of the GPS signal, with approximate time, for the server to later process into a position.
  5. Accurate, surveyed coordinates for the cell site towers allow better knowledge of local ionospheric conditions and other conditions affecting the GPS signal than the GPS receiver alone, to enable more precise calculation of position.
  6. Calculation of position by the server using information from the GPS receiver.
  7. The assisted server can compare reliable satellite signals and fragmented satellite signals relayed to it.

Both the GPS and A-GPS methods are accepted by the FCC, provided they yield accurate results compliant with the time requirements of 6 minutes from the time of the 911 call to identify the longitude and latitude of the initiating mobile phone within 300 meters, and provide this data to the Public Safety Answering Point (PSAP).

Paraguay – Regulatory Requirements for 802.11b/g

Question: We manufacture an 802.11b/g cable modem wireless router and would like to obtain approvals for Paraguay; what are the applicable regulations?

Answer: The 802.11b/g approval process in Paraguay requires the documents listed below.  First, some general notes about the approval process:

  • The lead time is approximately 50 business days from the time all documents are received in Paraguay.
  • The certification and certificate holder service fees are product dependent.
  • The certificate is valid for 5 years.
  • The label marking requirement is either FCC or the CE logo mark.
  • Process requires authorization of a homologation representative in Paraguay and a detailed signature authentication process using a notary public.

802。11b/g approval for Paraguay requires the following documents:

  1. Technical Specifications (Datasheet, Brochures)
  2. Circuit Diagrams (Schematics)
  3. Bill of Materials
  4. Block Diagrams, briefly explaining the function of each block (Operational Description)
  5. User Manual in Spanish or English
  6. Photos - Internal and External, including one photo showing the model number
  7. Manufacturer’s Company Name, Mailing Address, Contact Name, Title, Email, Phone
  8. Factory’s Company Name, Mailing Address, Contact Name, Title, Email, Phone
  9. Brand, Type and Model Number you want to see on the certificate
  10. FCC test reports and grants, ETSI test reports and Letters of Opinion, CE Declaration of Conformity, EMC test reports, or safety certificates and test reports from any Nationally Recognized Testing Laboratories (NRTLs).

Letter of authorization for a Paraguay representative to act on your company’s behalf to process the homologation application.  This signed letter or apostille, an international certification comparable to a notarization in U.S. domestic law, must eventually be notarized by the Paraguay consulate in the country in which the letter originates.  However, the first step in the process is for your signature to be authenticated and notarized by a notary public.  The Consulate of Paraguay in the country of origin must then authenticate your signature.  The original letter, along with authenticating documents, must be sent by courier to Comision Nacional de Telecomunicaciones, Asuncion, Paraguay.

Standards Updates


This is a shortened list of the CENELEC standards published during the past month:

  • - (7/21/2011) - High-voltage switchgear and controlgear - Part 1: Common specifications
  • - (7/21/2011) - Liquid crystal display devices - Part 5-2: Environmental, endurance and mechanical test methods - Visual inspection of active matrix colour liquid crystal display modules
  • - (7/21/2011) - Secondary cells and batteries containing alkaline or other non-acid electrolytes - Secondary lithium cells and batteries for portable applications
  • - (7/26/2011) - Railway applications - Urban guided transport management and command/control systems - Part 2: Functional requirements specification
  • - (7/28/2011) - Lightning protection system components (LPSC) - Part 5: Requirements for earth electrode inspection housings and earth electrode seals
  • - (7/29/2011) - Digital addressable lighting interface - Part 209: Particular requirements for control gear - Colour control (device type 8)
  • - (7/29/2011) - Electric components - Reliability - Reference conditions for failure rates and stress models for conversion
  • - (8/15/2011) - Evaluation and qualification of electrical insulation systems
  • - (8/15/2011) - Terrestrial digital multimedia broadcasting (T-DMB) receivers - Part 2: Interactive data services using BIFS
  • - (8/16/2011) - Basic principles for graphical symbols for use on equipment - Part 3: Guidelines for the application of graphical symbols
  • - (8/2/2011) - Radio data system (RDS) - Receiver products and characteristics - Methods of measurement
  • - (8/3/2011) - Medical electrical equipment - Part 2-31: Particular requirements for the basic safety and essential performance of external cardiac pacemakers with internal power source
  • - (8/8/2011) - Nuclear power plants - Control rooms - Supplementary control points for reactor shutdown without access to the main control room
  • - (8/8/2011) - Nuclear power plants - Instrumentation and control important to safety - Data communication in systems performing category A functions
  • - (8/8/2011) - Nuclear power plants - Instrumentation and control systems important to safety - Surveillance testing

See CENELEC 斗地主达人for additional information.


This is a shortened list of the IEC standards published during the past month:

  • - (7/26/2011) - Mechanical structures for electronic equipment - Thermal management for cabinets in accordance with IEC 60297 and IEC 60917 series - Part 2: Design guide: Method for determination of forced air-cooling structure
  • - (7/26/2011) - Piezoelectric, dielectric and electrostatic devices and associated materials for frequency control, selection and detection - Glossary - Part 3: Piezoelectric and dielectric oscillators
  • - (7/28/2011) - Amendment 44 - Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 3: Gauges
  • - (7/28/2011) - Lamp caps and holders together with gauges for the control of interchangeability and safety - 12-month subscription to online database comprising all parts of IEC 60061
  • - (7/28/2011) - Process management for avionics - Aerospace and defence electronic systems containing lead-free solder - Part 23: Rework and repair guidance to address the implications of lead-free electronics and mixed assemblies
  • - (7/28/2011) - Process management for avionics - Aerospace and defence electronic systems containing lead-free solder - Part 3: Performance testing for systems containing lead-free solder and finishes
  • - (8/10/2011) - Semiconductor devices - Mechanical and climatic test methods - Part 30: Preconditioning of non-hermetic surface mount devices prior to reliability testing
  • - (8/11/2011) - Integrated circuits - Measurement of electromagnetic emissions - Part 8: Measurement of radiated emissions - IC stripline method
  • - (8/11/2011) - Medical electrical equipment - Part 2-13: Particular requirements for basic safety and essential performance of an anaesthetic workstation
  • - (8/19/2011) - Winding wires - Test methods - Part 5: Electrical properties

See for additional information。


This is a shortened list of the CENELEC standards published during the past month:

  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 2: CDMA Direct Spread (UTRA FDD) User Equipment (UE)
  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 3: CDMA Direct Spread (UTRA FDD) Base Stations (BS)
  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 6: CDMA TDD (UTRA TDD) User Equipment (UE)
  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 11: CDMA Direct Spread (UTRA FDD) (Repeaters)
  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 15: Evolved Universal Terrestrial Radio Access (E-UTRA FDD) (Repeaters)
  • - (July 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 18: E-UTRA, UTRA and GSM/EDGE Multi-Standard Radio (MSR) Base Station (BS)
  • - (July 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Technical characteristics of Smart Metering (SM) Short Range Devices (SRD) in the UHF Band; System Reference Document, SRDs, Spectrum Requirements for Smart Metering European access profile Protocol (PR-SMEP)
  • - (August 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference Document; Short Range Devices (SRD); Part 2: Technical characteristics for SRD equipment for wireless industrial applications using technologies different from Ultra-Wide Band (UWB)
  • - (August 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Expanded measurement uncertainty for the measurement of radiated electromagnetic fields
  • - (August 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range; Part 1: Technical characteristics and methods of measurement
  • - (August 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (August 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Compliance tests for cognitive interference mitigation for use by UHF RFID using Detect-An

See 斗地主达人ETSI website for additional information.

US - Next Generation 9-1-1

On August 10, 2011, during the Association of Public Safety Communications Officials (APCO) conference in Philadelphia, Pennsylvania, FCC Chairman Genachowski announced the FCC’s five-step action plan to chart the transition to Next Generation 9-1-1 (NG911) services。  NG911 is the modernization of the United State’s existing 911 emergency service - it supports seamless, end-to-end IP-based communication of emergency-related voice, text, data, photos, and video between the public and 911 operators。  NG911 provides the additional benefits of increased public access, enhanced information for first responders, and increased reliability of NG911 networks。

Within the scope of the five-step action plan, the FCC plans to:

  • Develop automatic location accuracy mechanisms for NG911.
  • Develop a NG911 governance framework.
  • Facilitate the completion and implementation of NG911 technical standards.
  • Develop a NG911 Funding Model.
  • Enable consumers to send text, photos, and videos to 911 operators.

The FCC is expected to launch a rulemaking in September 2011 to consider how to accelerate NG911 adoption, help answer practical and technical questions about how to enable text, photo, and video transmission to 911, and how to ensure adequate broadband infrastructure to deliver the bandwidth 911 operators will need to provide NG911. 

Canada – Open Consultation on 71-76 GHz, 81-86 GHz and 92-95 GHz bands

斗地主达人On July 23, 2011, Industry Canada announced in Canada Gazette notice SMSE-010-11 its second round of consultations on the uses of spectrum in the 71-76 GHz, 81-86 GHz and 92-95 GHz bands by fixed services.   The wireless industry approached Industry Canada to make the bands available to support the deployment of broadband applications.

Industry Canada made the following statement in support of the consultation: “The unique propagation conditions that exist in these millimetre-wave frequency bands and the use of highly directional pencil-sized beams can provide for gigabit capacity in a spectrum environment where close proximity deployments can be achieved while minimizing the potential for interference.”

斗地主达人This consultation provides an opportunity for industry to comment on the future use of these bands by the fixed service, including designation, band plan, technical characteristics and the licensing approach.  All comments should be submitted no later than October 21, 2011. 

US, Mexico, Canada – Major Spectrum Sharing Agreements

On August 1, 2011, the FCC announced a finalized spectrum sharing agreement with Industry Canada and Mexico’s  Secretariat of Communications and Transportation.  The agreement provides for the sharing of commercial mobile broadband spectrum in the 700 MHz band alongside the US-Canadian and US-Mexican border regions.  The sharing agreement will help deployment of mobile wireless broadband systems near the US-Canadian and US-Mexican borders.  Licensees on both sides of the borders can access the 698-758 MHz and 776-788 MHz bands.

Additionally, the FCC agreed upon a spectrum sharing deal with Industry Canada for the 800 MHz band. The technical sharing principles for the 800 MHz band will help conclude the 800 MHz re-banding by US public safety and commercial licensees which operate along the US-Canadian border.

Australia – ACMA Updates Telecommunications Compliance and Labeling Information Booklet

斗地主达人On August 17, 2011, the Australian Communications and Media Authority (ACMA) published a booklet entitled “Telecommunications Compliance and Labeling Information for Suppliers of Telecommunications Customer Equipment and Cabling Products.”  The booklet provides a great source of information on ACMA’s telecommunications regulatory and compliance requirements.  Specifically, the booklet discusses applicable standards, record keeping obligations, compliance records affected by product modification, labeling requirements such as A-tick, C-Tick and RCM, as well as enforcement and penalties.

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