The FCC has two different approaches to part 15 and to licensed modules, but many of the same issues apply to both. The FCC for example only has ONE modular approval docket DA001407 and that deals ONLY with part 15 modules. However, the FCC also recognizes that licensed devices may also be of a modular nature and so, while there really is no modular approval docket for licensed devices like there is for unlicensed part 15 devices, modular transmitters are allowed in the licensed world. There are a few issues dealing with modular transmitters in the licensed rule parts.
Licensed transmitters may be approved as modules for installation into the final devices provided the following criteria are met: 1 The final device is designed for mobile or fixed operation (Portable is not permitted – this is in reference to rf exposure more than anything) 2 The maximum antenna gain to allow compliance with RF exposure requirements is listed on the Grant of Certification for the modular transmitter 3 The licensed module must have a FCC ID label on the module itself. That FCC ID label must be visible through a window on the final device or it must be visible when an access panel, door or cover is easily removed. If not, a second label must be placed on the outside of the final device that contains the following text: "Contains FCC ID: xxxyyyzzz.” 4 The Grant should include the following words in the device description or grant notes: “modular transmitter” or “transmitter module” You should notice that unlike the unlicensed DA001407 modular approval docket, since this is a licensed device, you do not have to limit the antenna except to the max gain. Any type antenna, any type connector etc can be used. In fact, removable antenna device do not even have to have an antenna connected for any of the testing. Power can be conducted antenna terminal power and radiated spurious emissions, even though erp/eirp done to TIA603C, only have to have the antenna port connected to a ‘dummy load’. The gain of the antenna can be ‘calculated’ to yield the appropriate MPE etc. You should also notice that there is no such thing as a licensed portable modular transmitter. Thanks Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com <http://www.atcb.com> 703-847-4700 fax 703-847-6888 direct - 703-880-4841 From: [email protected] [mailto:[email protected]] On Behalf Of Bill Owsley Sent: Friday, September 05, 2008 10:34 AM To: 'Rudd, Adam'; [email protected]; [email protected] Subject: RE: Radio module integration (Part 22/24) In looking at the reference example, the transmitter appears to fit into the PCI port of a laptop, much the same as wireless network card fits into one. So does "modular" have more to do with being unlicensed, or would it have more to do with how it is used? - Bill You can say what you want about the South, but you never hear of anyone retiring and moving North!!! --- On Fri, 9/5/08, dward <[email protected]> wrote: From: dward <[email protected]> Subject: RE: Radio module integration (Part 22/24) To: "'Rudd, Adam'" <[email protected]>, [email protected] Date: Friday, September 5, 2008, 11:42 AM Hi Adam While the FCC does have a policy statement about licensed modular transmitters using “"Contains FCC ID: xxxyyyzzz” on the outside of a host device, it does not have a policy about full transmitters (i.e. non-modular). If the licensed transmitter is not a modular transmitter but has an FCC ID then the FCC has no requirements about placing the ID number on the system and it is sufficient that the FCC ID is on the outside of the licensed transmitter. Thanks Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com <http://www.atcb.com/> 703-847-4700 fax 703-847-6888 direct - 703-880-4841 From: [email protected] [mailto:[email protected]] On Behalf Of Rudd, Adam Sent: Friday, September 05, 2008 6:11 AM To: [email protected] Subject: Radio module integration (Part 22/24) Gentlemen, Does the FCC have any regulations or guidance for integrating a radio device into a larger system, specifically for a part 22/24 radio where the device will be concealed from view? Per 15.212, there is a lot of criteria involving the device having a Grant with Modular Approval and then if the integrator conceals the radio module’s FCC ID from view we must put a label on the outside that says “Contains FCC ID:xxxxxx”. I’m quite familiar with these requirements for 802.11 and RFID radio devices. But that code section is strictly for unlicensed part 15 transmitters. What about licensed Part 22 and 24 transmitters such as cellular radio devices such as: FCC ID N7NAC875 https://fjallfoss.fcc.gov/oetcf/eas/rep rts/ViewExhibitReport.cfm?mode=Exhibits RequestTimeout=500&calledFromFrame=N&ap lication_id=184431&fcc_id=%27N7NAC875%27 <https://fjallfoss.fcc.gov/oetcf/eas/re orts/ViewExhibitReport.cfm?mode=Exhibit &RequestTimeout=500&calledFromFrame=N&a plication_id=184431&fcc_id=%27N7NAC875%27> Note: Does not have “modular approval”, but that was a requirement under part 15.212… which may or may not be applicable here. I have submitted an inquiry with the FCC OET. But that usually take a couple weeks to get a responce. I am hoping someone here might be able to point me toward the rule section of Part 22 and 24 that would provide guidance. Thank you! Adam Rudd - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
