Anders - 

The primary purpose of restricting co-location is related to rf exposure.  The
individual grants allow for use of the devices based on (typically) a
calculation of the rf exposure.  Adding a second transmitter increases the rf
exposure and may require an increased minimum separation distance  between the
antennas and people.

If the two modules do not share a antenna and cannot operate at the same time
then they are not co-located.  Also, if the antennas for the modules have
adequate separation (typically 20cm, but it could be more if the individual
modules require a greater distance) they are not considered co-located and you
can use the modules without having to obtain additional approvals.  

There are a three options that come to mind with getting the device approved
with both modules operating together:  
The first is to contact the module manufacturers and see if they can file a
change with the FCC to allow co-location of module A with module B (and vice
versa) in your specific host system.  Both grants would need to allow
co-location with the other device in your host system.  The FCC IDs for the
each module would need to be displayed on the outside of the device.
The second is to work with the module manufacturers to obtain an FCC ID under
your company name for each module to allow co-location in your host device. 
Typically the modular approval would then be limited to allowing installation
in devices you make and limited to specific host systems.  The FCC IDs for the
each module would need to be displayed on the outside of the device.
The third is to obtain a grant for your device that covers both the modules. 
You would have only one FCC ID for your product covering both modules.

For all 3 cases you would need to re-evaluate radiated emissions for both
modules in your device, possibly AC conducted emissions and re-evaluate the rf
exposure of the combination device.  Direct measurements on the rf port for
power, bandwidth etc etc could be taken from the original module reports.  You
will need to obtain instructions to place the module into suitable test modes.

If you are looking for Industry Canada approval life is a little easier since
there will be no co-location restriction (assuming both modules have modular
approval under Industry Canada's certification scheme).  This is because
Industry Canada leave rf exposure to the manufacturer ... so you would need to
evaluate rf exposure for the end product and provide appropriate warnings to
the end user.

Good luck - using pre-approved modules can make life easier, but only if you
can use the modules without breaking any of the restrictions !


Mark

At 01:18 AM 1/8/2008, Anders Svensson B wrote:



Dear experts, 

I have found that the FCC grants (FCC part 15) for WLAN modules and GSM
modules have a restriction that says that they must not be co-located with
other antenna or transmitter.

In our coming product we have two modules which is co-located, how do we solve
this problem? Our thoughts right now is to use the modules FCC grants and do a
FCC Self Declaration for the transmitting part for our units (i.e. no own FCC
id for our product).  

For my understanding: 
Why do the modules FCC grants have this restrictions? 
Can the manufacturer update the FCC grants without this restrictions and that
are needed for that?
Have we any more solutions to solve this? 

Any inputs is very much appreciated 

Thanks 

Regards 
Anders 

  


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