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MultiPoint Newsletter - October 2014

COTS Antennas & the FCC Certification Process

Question:斗地主达人 We are integrating a Part 15 certified wireless module into our end products which will need to comply with Part 15 rules and regulations. We want to use antennas that were not tested with the module at the time of its certification without going through the FCC certification or Class II permissive change process. The antennas may be antennas we have designed, or other commercial-off-the-self (COTS) antennas. Does the FCC allow this?

Answer: The FCC grant issued for the wireless module most likely contains the grant note “Only those antenna(s) tested with the device or similar antenna(s) with equal or lesser gain may be used with this transmitter.” Furthermore, the antenna you select must be of the same type and have the same or similar in-band and out-of-band radiated emissions characteristics in all directions, per .

For example, if an inverted F-antenna with 4 dBi gain was tested as part of the original certification, you can use other inverted F-antennas of the same construction with equal or lower gain without additional FCC authorization, provided that the in-band and out-of-band radiated characteristics of the selected antenna are the same or lower than those of the original module. The antenna must comply with all applicable FCC rules, operating requirements, and grant conditions of the module’s certification.

Also, portable devices subject to SAR may require additional SAR testing if the antenna tested for the original certification is replaced.

Please note that there are instances when antenna changes are not allowed:

  • Certified transmitters that are required to monitor the bandwidth on which they are intended to transmit can only use antennas approved with the device. These include but are not limited to Part 15:
    • Subpart D Unlicensed Personal Communications Service Devices
    • Subpart E Unlicensed National Information Infrastructure Devices (UNII) Devices certified with Dynamic Frequency Selection (DFS) in the 5.25 - 5.35 and 5.47-5.735 GHz band.

 


FCC Consent Decree

Question: Following the receipt of several inquiries regarding FCC Consent Decrees, we sought the expertise of Ms. Laura A. Stefani, a regulatory attorney with Fletcher, Heald and Hildreth. The law firm provides comprehensive services in every branch of communications law, and Ms. Stefani represents clients with regard to spectrum allocation and sharing, and the regulation and licensing of equipment and services, before the Federal Communications Commission, the National Telecommunications and Information Administration, and other federal agencies. On behalf of our MultiPoint readers, we posed three questions to Ms. Stefani, who graciously responded; her answers are provided verbatim below.

  • What is an FCC Consent Decree?
  • Under what conditions does the FCC enter into such an agreement?
  • What are the typical compromise/remedial actions between the grantee and the FCC?

Answer: Consent Decrees are settlement agreements entered into between the Federal Communications Commission and a private party, such as an FCC licensee or equipment manufacturer, to resolve violations of the communications laws, including equipment certification, importation and marketing rules.

Generally, Consent Decrees consist of three main elements: a monetary payment to the U.S. Treasury; a compliance plan; and some sort of remediation plan to address non-compliant products or activities. Compliance plans generally are in place for three years; include the appointment of a “compliance officer” and a plan to educate and provide oversight over relevant employees; and require filing reports with the Commission regarding these activities. The remediation portion of the Consent Decree is situation specific. For example, for a non-compliant product, the Commission may require notification to customers, access to a software fix on a manufacturer’s website, the return of products in the distribution system, or even the recall of products from the field – all depending on the circumstances and the potential for and type of interference or other resulting problem.

Negotiating a Consent Decree can arise from several different scenarios. First, as the result of voluntary disclosure – the self-reporting of a rule violation – the FCC may ask for additional information and, if it determines that it must take action, it may suggest negotiating a Consent Decree. If this happens, the FCC may request that you enter into a “Tolling Agreement” to preserve the FCC’s right to pursue the violation, should the negotiation fail. Consent Decrees can also be negotiated after a party receives a Letter of Inquiry, a Notice of Violation, or a Notice of Apparently Liability from the FCC’s Enforcement Bureau.

There are, of course, pros and cons to entering into Consent Decrees。 In past years, the Commission often negotiated better outcomes, specifically lower fines and the characterization of the fine as a “voluntary contribution,” which allowed for a tax write off (as a business expense)。 Recently, however, this hasn’t been the case。 Consent Decrees also allow for the negotiation of a more achievable or sensible remediation plan than what the FCC might apply on its own。 And, because Consent Decrees are not always released publically, they can limit public knowledge of the violation。 Additionally, they provide for a quicker resolution of a problem, which may be beneficial to a public company needing to settle a matter before it becomes reportable to the SEC or to an entity in the midst of being acquired。 Some of the cons to entering into a Consent Decree would be if a party believes that it did not violate the rules or believes that it would be beneficial to delay a resolution。

There are two key takeaways: First, don’t avoid or procrastinate when you know there’s a problem. The earlier that you deal with the FCC, whether by making a voluntary disclosure or making a prompt and earnest response to an inquiry, generally the better the outcome. Second, Consent Decrees are voluntary, and it’s important to consider (hopefully, after the consultation of an able communications attorney) whether it makes sense in a particular situation.

For more information on Ms. Stefani, go to and to her LinkedIn profile at .


Confidentiality for Proprietary Information

Question: We will be seeking FCC equipment certification and would like to know how to request that the proprietary information about our device be held confidential, and not be available to the public. How do we do this?

Answer: The FCC published 726920 D01 Confidentiality Request Procedures on October 16, 2014, replacing all prior documents on this topic. Proprietary information may be held confidential if it meets the FCC requirements, and if your certification application includes an acceptable Confidentiality Request letter.

There are two types of confidentiality:

  • Permanent/long-term confidentiality, which is intended to safeguard trade secrets in accordance with Sections 0.457(d) and 0.459 of the FCC rules;
  • Short-term confidentiality, which is intended to allow the applicant to prepare to market, or to market, a device without disclosure of sensitive information to the public prior to the actual sale of the device.

斗地主达人A table included in the linked publication summarizes which exhibits may be held confidential for the long-term and/or short-term.

Based on your question, it sounds like you will be seeking long-term confidentiality. Assuming that your certification application meets the requirements, including an acceptable Long-term Confidentiality Request letter, the following exhibits will be held confidential:

  • Unlicensed devices: Schematics, Block Diagram, Technical Operational Description
  • Licensed devices: Schematics, Block Diagram, Technical Operational Description, Parts List, Tune Up/Alignment Procedure

In the event you are seeking confidentiality for an exhibit not listed here, you may petition the FCC if “exceptional circumstances” apply. Please see Section V of the linked document for a description of the four “exceptional circumstances” and follow the instructions provided there to petition the FCC by submitting an inquiry. Approval will be made on a case-by-case basis.

It should be noted that while under review, the application contents can only be accessed using the FCC ID# and the randomly-generated FCC Form 731 Confirmation Number created at the time of submission, generally known only to the person who submitted the application and the reviewer.

Please review the linked document in detail for other important information about confidentiality throughout the certification process, and other possible options.


Incorrect Information on FCC Grant

Question: The grant issued for our latest certification application included incorrect information about our company. How do we correct that?

Answer: When FCC grants are issued, the company name, address, contact name and title fields are auto-populated by the information in the FCC Grantee Code database. It is incumbent upon your company to update the FCC Grantee Code database when any changes occur to ensure that the FCC always has valid and current information regarding the party responsible for product compliance, which in turn appears on any grants issued under your grantee code.

Grantee code database updates are to be submitted online; the process will require both the Grantee Code and the Grantee Code Registration Number, a six digit security code required to submit updates to the Grantee Code database。

The FCC has defined three categories of Grantee Code database changes:

  • Change Address or Contact Only
  • Change Name, Including Address and/or Contact
  • Transfer of Control

Each category has its own requirements for submitting the change request, and the last, Transfer of Control, has significant impact。 Regardless of the category it’s important that you submit all of the required information。

KDB Publication 204515 D01 Grantee Code, Section C, Changing Grantee Code Information, explains the three categories of changes in detail, and provides the appropriate information and documentation requirements for each.

As stated previously, the Grantee Code Registration Number is required in order to submit any changes to the Grantee Code database. If the Grantee Code Registration Number is unknown, you must obtain it before you will be able to submit any Grantee Code database updates.

斗地主达人You may request the Grantee Code Registration Number assigned to your Grantee Code at ; select “Submit An Inquiry”, complete the required fields; for the First Category, select “Administrative Request”, and for the Second Category, select “Lost Grantee Registration KDB 204515”。

The text field needs to include specific information that is based on the requestor’s relationship to the existing contact information in the Grantee Code database, i.e. the same email address or same email domain as the registered contact, or a different email domain from the registered contact.

Section D, Lost Grantee Code Registration Number, provides further details on requesting the Grantee Code Registration Number, based on the circumstances.

Once obtained, the Grantee Code Registration Number should be archived and secured, and the Grantee Code database updates should be submitted as directed in the linked document.


Standards Updates

EU: New CENELEC Standards Recently Released

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

  • - 9/19/2014 - Audio, video and information technology equipment - Routine electrical safety testing in production
  • - 10/3/2014 - Low-voltage surge protective devices - Surge protective devices for specific application including d.c. - Part 11: Requirements and tests for SPDs in photovoltaic applications
  • - 10/3/2014 - Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
  • - 10/3/2014 - Industrial electroheating equipment - Test methods for infrared emitters
  • - 10/10/2014 - Alarm systems - Part 4: Electromagnetic compatibility - Product family standard: Immunity requirements for components of fire, intruder, hold up, CCTV, access control and social alarm systems
  • - 10/10/2014 - Explosive atmospheres - Part 1: Equipment protection by flameproof enclosures "d"
  • - 10/10/2014 - Wind turbines - Part 2: Small wind turbines
  • - 10/10/2014 - Safety requirements for secondary batteries and battery installations - Part 3: Traction batteries
  • - 10/24/2014 - Environmental testing - Part 2-75: Tests - Test Eh: Hammer tests
  • - 10/24/2014 - Electroacoustics - Audio-frequency induction loop systems for assisted hearing - Part 2: Methods of calculating and measuring the low-frequency magnetic field emissions from the loop for assessing conformity with guidelines on limits for human exposure

See for additional information.

EU: New ETSI Standards Recently Released

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

  • - (October 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Spectrum requirements for Urban Rail Systems in the 5,9 GHz range
  • - (October 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Land Mobile Service; Radio equipment using constant or non-constant envelope modulation operating in a channel bandwidth of 25 kHz, 50 kHz, 100 kHz or 150 kHz; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (October 2014) - Environmental Engineering (EE); Methodology for environmental Life Cycle Assessment (LCA) of Information and Communication Technology (ICT) goods, networks and services
  • - (October 2014) - Operational energy Efficiency for Users (OEU); Global KPIs for Data Centres
  • - (October 2014) - Environmental Engineering (EE); Environmental conditions and environmental tests for telecommunications equipment; Part 2-1: Specification of environmental tests; Storage
  • - (October 2014) - Reconfigurable Radio Systems (RRS); System requirements for operation of Mobile Broadband Systems in the 2 300 MHz - 2 400 MHz band under Licensed Shared Access (LSA)
  • - (October 2014) - Open Radio equipment Interface (ORI); Requirements for Open Radio equipment Interface (ORI) (Release 4)

See for additional information.

EU: New IEC Standards Recently Released

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

  • - (9/25/2014) - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 2-010: Particular requirements for laboratory equipment for the heating of materials
  • - (9/25/2014) - General testing procedures for medical electrical equipment
  • - (10/1/2014) - Electroacoustics - Audio-frequency induction loop systems for assisted hearing - Part 2: Methods of calculating and measuring the low-frequency magnetic field emissions from the loop for assessing conformity with guidelines on limits for human exposure
  • - (10/8/2014) - Interpretation sheet 2 - Explosive atmospheres - Part 0: Equipment - General requirements
  • - (10/8/2014) - Interpretation sheet 1 - Explosive atmospheres - Part 11: Equipment protection by intrinsic safety "i"
  • - (10/8/2014) - Low-volatge electrical installations - Part 8-1: Energy efficiency
  • - (10/9/2014) - Electromagnetic compatibility (EMC) - Part 6-7: Generic standards - Immunity requirements for equipment intended to perform functions in a safety-related system (functional safety) in industrial locations
  • - (10/15/2014) - Conformity assessment - Requirements for bodies providing audit and certification of management systems - Part 7: Competence requirements for auditing and certification of road traffic safety management systems
  • - (10/15/2014) - Corrigendum 1 - Electromagnetic compatibility (EMC) - Part 1-6: General - Guide to the assessment of measurement uncertainty
  • - (10/17/2014) - Household and similar electrical appliances - Test code for the determination of airborne acoustical noise - Part 2-5: Particular requirements for electric thermal storage room heaters

See for additional information.

FCC - Interim Plans to Approve U-NII Devices

On September 23, 2014, the FCC published , Interim Plans to Approve U-NII Devices Operating in the 5470 – 5725 MHZ Band with Radar Detection and DFS Capabilities.

FCC - Additional Modification to White Space Rules Proposed

On September 30, 2014, the FCC proposed TV stations。 The proposed changes to the rules would help facilitate the use of television bands, 600 MHz guard bands and channel 37。 The band plan adopted for the upcoming 600 MHz incentive auctions, scheduled for 2015, built in opportunities for white space use in the guard bands and channel 37。 The FCC hopes that the revised rules will promote more efficient use of TV white space while protecting incumbents from interference。

US – DOE considers Revising External Power Supply Test Procedure

On October 02, 2014, the Department of Energy (DOE) proposed revising the testing procedure for external power supplies。 The modifications considered are as follows:

  • Harmonize DOE’s test procedure with the latest version of IEC 62301 by providing specific resolution and measurement tolerances.
  • Define and clarify how to test adaptive EPSs (also referred to as “adaptive-charging”, “smart-charging” or “quick-charging” EPSs).
  • Add test configurations that can be used to avoid potential losses caused by testing cables.
  • Clarify that when testing an EPS that is incapable of being tested at one or more of the loading conditions used to calculate the average active-mode efficiency, such conditions will be omitted when calculating this metric. Instead, the average active-mode efficiency will be determined by averaging the efficiency results at each of the loading conditions that can be measured.
  • Optional test to measure the active mode efficiency at a 10% loading condition.
  • Optional recording of power factor during testing.
  • Insert a summary table (see Table) to enable one to more readily identify which standards apply to which type of EPS.
  • Expand the scope of its sampling plan for Class A EPSs to apply to those that will be subject to standards for the first time in 2016.

Canada - Release of RSS-199, Issue 2

On October 9, 2014, Industry Canada posted on its website the release of , which sets out the certification requirements for BRS radio transmitters and receivers in the band 2500-2690 MHz. RSS-199, Issue 2 replaces RSS-199, Issue 1 (January 2010) and the following changes are listed below:

  • The equipment's unwanted emission mask is modified.
  • The method used to measure the equipment's frequency stability is added.
  • The compliance requirement for equipment with multiple antennas is added.
  • The requirement for receiver standard spurious emissions has been withdrawn following decisions made under Regulatory Standards Notice 2012-DRS0126.

EU - EN 61326-1:2013 in Effect on August 14, 2015

EN 61326-1:2013, the revised EMC standard for measurement, control and laboratory use, will go into effect on August 14, 2015. Basic updates were made to the standard and the following new requirements were added:

  • Technical changes were made for the equipment under the "basic environment" requirements.
  • The air discharge ESD test level has been increased from 4KV to 8KV.
  • A requirement for immunity to magnetic fields according to IEC 61000‐4‐8 was added, but only for susceptible devices.
  • Additional details were added to the performance criteria for the immunity testing.
  • New requirements for the user manual were added.

Mexico - New Energy Efficiency Standard in Effect

As of September 19, 2014, a new standard, , went into effect and sets out the maximum electrical power limits for equipment and appliances requiring stand-by power. The standard does not apply to equipment that is within the scope of existing norms for energy efficiency. Additionally, it may not apply to highly specialized devices not intended to be sold directly to the public, or devices with a weight greater than 33 lbs. Local tests are required for certification.

Brazil - Electronic Registration System for Medical Devices in Development

Brazil's medical device market regulator, ANVISA, recently announced plans to implement a system for electronic submission of registration applications based on guidelines from the International Medical Device Regulators Forum (IMDRF)。 The IMDRF system, known as Regulated Product Submission (RPS), is being created to harmonize pre-market device submissions and approvals across different national markets。

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