Hi Ian,

 

I don’t know if you found answers to these yet, or not.   But below are my
comments [MD]:

 

 

Michael.

 

 

From: Schroeder, Ian [mailto:ian.schroe...@dish.com] 
Sent: 27 November 2018 21:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Antenna Colocation test

 

A US only digital device product desires to incorporate various FCC
Certified modules that can all transmit simultaneously.  

All modules are certified as single modular with grant notes stating “no
co-location”.

[MD]:    Actually these days the more common Grant note is “Co-location
requires the use of FCC multi-transmitter procedures”, because “no
co-location” gives the impression that co-location is not possible.   Really
it means “You can’t co-locate until you’ve done some more work”

 

All modules will be used in accordance with their grant notes except for
co-location to other transmitters.

 

What FCC Authorization method should be used for the product, SDoC or
Certification?

[MD]:    It depends what the product is.

Let’s say that the device is some normal mobile device, IT equipment
perhaps, then the manufacturer can choose either sDoC or Certification for
the authorisation, based on this list:

https://www.ecfr.gov/cgi-bin/text-idx?SID=5ba272b1b885f2b9d0847458436d2ccc
<https://www.ecfr.gov/cgi-bin/text-idx?SID=5ba272b1b885f2b9d0847458436d2ccc&;
mc=true&node=se47.1.15_1101&rgn=div8> &mc=true&node=se47.1.15_1101&rgn=div8

If the host also has another transmitter in it, then maybe it must have
certification.

 

Is co-location testing of the host the same as FCC 15B testing of the
digital device?

[MD]:    Not quite.

 

FCC Part 15B testing of the digital device is to the limits of 15.109.   The
modules would be powered, but they do not need to be transmitting.
Typically, for example, you would test up to the 5th harmonic of the highest
clock in the device, which is probably the module’s fundamental frequency
(e.g., testing up to 12.5 GHz if it’s a 2.4 GHz module).

 

The transmitter co-location testing is performed to the transmitter limits,
such as 15.209, or -13 dBm e.i.r.p., etc.

The transmitters are all on, and transmitting.   I would say it’s not
mandatory in most cases to test all channels, all modulations, etc.   You
can look online at the module test reports, figure out which channel and
modulation is worst, and test that one.   Of course if you can’t control the
module, then you may not be able to set the channel.   Really, you’re just
putting all the transmitters on, testing the combined transmitter emissions,
to ensure you have not created a monster.

This radiated emissions test check is necessary even if you only installed
one module, by the way, and is not specific to the co-location issue.

Testing would be up to the 10th harmonic of the highest frequency
transmitter.

 

If during co-location testing there are signals related to the product
digital device portion and not any transmitter (as verified by turning all
radios off and disabling their communication path) what limit shall apply?
Transmitter spurious limits (say the least/most restrictive) or general 15B
limits (A/B depending on product type)?

[MD]:    I would say you apply the limit of the host, such as 15.109.
However, if the device is always transmitting in normal use, so the only
function is ‘the transmitter’ and the emission is under the transmitter
limit; I think you could also justify applying that limit.

 

 

Michael.

 

Ian

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: Tuesday, November 27, 2018 12:58 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] Antenna Colocation test

 

 This message originated outside of DISH and was sent by:
owner-emc-p...@listserv.ieee.org <mailto:owner-emc-p...@listserv.ieee.org>  

The RSE requirements are detailed in §2.947(f)

 

A composite system is a system that incorporates different devices contained
either in a single enclosure or in separate enclosures connected by wire or
cable. If the individual devices in a composite system are subject to
different technical standards, each such device must comply with its
specific standards. In no event may the measured emissions of the composite
system exceed the highest level permitted for an individual component.
Testing for compliance with the different standards shall be performed with
all of the devices in the system functioning. If the composite system
incorporates more than one antenna or other radiating source and these
radiating sources are designed to emit at the same time, measurements of
conducted and radiated emissions shall be performed with all radiating
sources that are to be employed emitting.

 

So a part 15 device needs to comply with part 15, and a part 22 device with
part 22, etc.

 

I interpret the clause that I underlined as saying that an intermodulation
product, it would “only” need to comply with the more relaxed limit of the
two rule parts for the two transmitters that created it.

Now, the engineer in me says that you should fix your design if you’re
creating intermodulation products, but I’m not sure this is address
specifically in any rule or KDB

 

Consideration of simultaneous transmissions for SAR are separate and covered
under SAR KDBs

 

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f
5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Grasso, Charles <charles.gra...@dish.com
<mailto:charles.gra...@dish.com> > 
Sent: 27 November 2018 19:14
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Antenna Colocation test

 

Hi – For an FCC product with multiple xmtrs  a colocation test is required
(<20cms).

 

What standard are applied for the RE test? 15.209?

 

Charles Grasso 

W: 303-706-5467

 

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