1. Washington Laboratories (301) 417-0220 web: www.wll.com7560 Lindbergh Dr. Gaithersburg, MD 20879 2014/6/61 Wireless Product Testing William H. Graff, AmericanTCB

2. FCC 47 CFR Regulations Part 2 General Requirements Part 15B Unintentional Radiators Part 15C/D/E/F Intentional Radiators Part 18 ISM Devices All Other Rule Parts: Licensed Devices

3. Part 2 – General Requirements Basic reference section on how to create an FCC filing. Oldest part of the FCC rules. All necessary requirements begin with Part 2 FCC Rules predate industry standards

4. Equipment Authorizations There are three basic types of equipment authorizations: oVerification oDeclaration of Conformity oCertification

5. Verification Simplest of all Equipment Authorizations No submission to FCC Data is held by Applicant/Manufacturer Proof that equipment was tested and found to be compliant at a given point in time Examples: Broadcast Receivers, TVs, Class A Digital Devices, BPL (consumer)

6. Declaration of Conformity More complex than Verification No submission to FCC Must be done at an Accredited Laboratory Country where testing takes place must have signed MRA with USA Responsible Party must reside on US soil Examples: Class B computers and peripherals, microwave ovens for consumers,

7. Certification Used for all equipment authorizations involving Licensed or Unlicensed transmitters. Can be used optionally for Class B computers/peripherals, comsumer microwave ovens, etc. Submission to FCC database is mandatory Is more than just an engineering report. It is a legal document. Requires a detailed list of Exhibits (See 2.1033 ) Examples: All Licensed transmitters, all Unlicensed Part 15 Intentional Radiators, radar detectors, scanning receivers

8. Changes to Certified Equipment Known as Permissive Change oChanges which have no effect on RF emissions or performance [Class 1] oChanges which affect emissions or performance but still within the limits [Class 2] oChanges to RF software [Class 3] – This is only applicable to devices which qualify as Software Defined Radio (SDR)

9. Class I Permissive Change Changes which have no effect on the emission characteristics of a device No submission to FCC Test Report is created, but held by Applicant / Manufacturer Examples: Color

10. Class II Permissive Change Changes which may potentially affect the emissions of a device Submission required to FCC Examples: New PCB layout, new antenna, new host (re: modular approval)

11. Forbidden Class II Changes (requires new ID / new submission) Changes to frequency determining circuit Changes in RF power Changes from one RF category to another Changes to modulation or timing Changes in basic functionality (i.e. dual band to single band)

12. Permit-But-Ask Procedure New! as of November, 2006 FCC has initiated a new procedure for troublesome filings and new technology. Prior to any request for Certification, a TCB must request guidance from FCC on specific items to look for before granting Certification. Specifically aimed (so far) at 15.239 personal FM transmitters, WiMax devices and 3.5/4G cellphones. See FCC Memo to TCBs.

13. Licensed Transmitter Approvals

14. Licensed Radio Services General Testing Requirements FCC Part 2.1046 through 2.1057 Cover tests for all licensed devices. The basics rationale of all FCC tests originate within this section. This is the oldest of the FCC rules Built for the narrowband world, but still adaptable to broadband radio concepts

15. Licensed Radio Services Test Parameters 2.1046 - Power Output 2.1047 - Modulation Characteristics 2.1049 - Occupied Bandwidth 2.1051 - Antenna Terminal Spurious Emissions 2.1053 - Radiated Spurious Emissions 2.1055 - Frequency Stability for Temperature and Voltage Variations

16. Licensed Radio Services Test Parameters Remember that the purpose of performing the measurements required and submitting interpretations is to establish compliance with the technical requirement contained in the Radio Service Rules. These rules are pre-standards. In other words they evolved before there were generally accepted measurement standards and practices.

17. Basic Test Parameters Power Output: 2.1046 oTraditionally thought of as a caloric measurement. Use of common CW power meters were common. Great deal of measurement certainty. oPart 15 began the usage of peak reading power meters. Most unlicensed transmitter sections still require the concept of peak power unless specifically stated otherwise

18. Basic Test Parameters Modulation Characteristics 2.1047 oFor analog radio transmissions (AM, FM, SSB) understanding basic parameters such as audio response and audio low pass filter were necessary to determine compliance. Testing usually required oFor todays constant envelope digital modulation systems this is basically unnecessary, but still must be described. Testing usually not required.

19. Basic Test Parameters Occupied Bandwidth 2.1049 oOccupied Bandwidth is defined as that portion of the spectrum where 99% of the emitted energy exists. The results are used to compare modulated spectrum with emissions masks. oAlthough not explicitly specified, all Certification reports including Part 15 must have an occupied bandwidth plot oPlot should be presented for each type of modulation

20. Basic Test Parameters Antenna Terminal Spurious Emissions 2.1051 (Also known as Antenna Conducted Emissions) oView levels of conducted harmonics applied to the antenna. oAn extension of the occupied bandwidth test. Show spurious emissions to 10 th harmonic. oUnless specified elsewhere, RBW should be equal or greater than Tx emission bandwidth 0

21. Basic Test Parameters Field Strength of Spurious Emissions 2.1053 oTest includes emissions radiated from the cabinet, chassis, and associated wiring. The specification is the same emission mask under the Radio Service rules extended to the highest frequency specified in 2.1057. Traditionally a terminated transmitter is tested without antenna. oFor Licensed equipment, the substitution method described in TIA/EIA 603 is the required test procedure. oFor Part 15 emissions testing, direct measurement of field strength is accepted. Device must be tested with its antenna in place.

22. Basic Test Parameters Frequency Stability 2.1055 oDone over temperature [-30 C to +50 C] and operating voltage [+/- 15%] specifications. oBattery operated devices should also include B.E.P [Battery End Point] oUsually defined in ppm but other units such as Hz, % are accepted as defined in specific rule section. oIn most cases, frequency stability is not required for Part 15

23. Certification Checklist – Check for Accuracy Applicant name, address, contact info, email address. There must be agreement with the supplied contact information and the Grantee contact information at FCC website. Agent Authorization Letter Confidentiality Request Letter FCC ID: Equipment Class – if not known ask! Rule Part(s) Frequency Range Power Output Requested Emission Designator

24. Certification Checklist Associated Application (Composite Request) Confidentiality Request (See separate details for STC) Details to be included with confidentiality. oBlock Diagram oSchematics oOperational Description oParts/Tune Up Statement / letter supplied for special requirements or interagency coordination (if required).

25. Licensed and Unlicensed Transmitter Exhibits Certification Requirements for exhibits, labeling, etc, differ somewhat from the Licensed world. Compare 2.1033(c) [Licensed Tx] with 2.1033(b) [Part 15] for Exhibit list Compare 15.19(a)(3) with 15.19(a)(1) for label language. Devices which are Licensed transmitters only with no accociated receiver can omit all 15.19 langrage All Part 15 devices must address 15.21 and 15.105 for manual RF Exposure language is additional

26. Unlicensed Part 15 Transmitter Approvals

27. Part 15 Rule Organization oAll general rules including measurement procedures, label requirements, etc. are located in 15.xx (Subpart A) oAll Unintentional Radiators are located in Part 15.1xx of the Rules (Subpart B) oAll Intentional Radiators are located in the 15.2xx sections of the Rules (Subpart C), 15D (unlicensed PCS), 15E (UNII) and 15F (UWB)

28. Essential Part 15 Transmitter Requirements 15.203 Antenna Requirements 15.204 External amplifier restrictions 15.205 Restricted Bands 15.207 Conducted Requirements 15.209 Radiated Requirements

29. 15 C Intentional Radiators Special note: FCC 15.207 & FCC 15.209 Equivalent to 15.107 and 15.209 Class B computer limits. Unless indicated otherwise, all spurious emissions from Part 15 transmitters should be to these limits.

30. 15.203 Antenna Requirements An intentional radiator shall be designed to ensure that no antenna other than that furnished by the responsible party shall be used with the device.

31. 15.204 Power Amp Restrictions oOfficially referred to as a Transmission System oFor spread spectrum transmitters usually includes the bi-directional amplifier, DC injector, and spread spectrum transceiver under one FCC ID: oAmplifiers designed for use with Spread Spectrum Systems must be approved as part of the system and marketed as part of a complete package. Amplifiers cannot be marketed without pairing to specific transceiver. oOnly approved antennas may be sold with the product. New antenna can be added under the Class II PC process.

32. 15.205 Restricted Bands Bands are generally US Government and military The field strength of emissions appearing within these frequency bands shall not exceed the limits shown in §15.209. Basis for all radiated band edge requirements. Caution: Restricted Bands change over time

33. AC Conducted Limits 15.207 Except for battery-only powered devices, all Part 15 transmitters must have AC Conducted test. This includes Modular Approvals under DA 00-1407 Conducted emissions not required for battery powered devices that make no provisions for attachment to AC power. Follow test procedure in ANSI C63.4 Unless otherwise specified, all Intentional Radiators must meet 15.207 limits.

34. Radiated Emission Limits 15.209 Unless specified elsewhere, all Intentional Radiators must meet 15.209 limits anywhere outside of their allotted frequency band. Test set-up per ANSI C 63.4 limits. Limits identical to FCC Class B. Tighter limits apply at all band edges Watch for specific rules for the device. Intentional radiators must generally be measured to the 10th Harmonic

35. Part 15 C – Intentional Radiators 15.215 Additional Provisions to the General Radiated Emission Limitations oProlog to 15.217 to 15.255 15.215(b) Emissions outside parking space must meet Class B limits. 15.215(c) Emissions should stay within central 80% of band. 15.215(d) Emissions must take into account sweeping, hopping and other modulation techniques – including OOK

36. Part 15 C Intentional Radiators §15.217 Operation in the band 160-190 kHz. §15.219 Operation in the band 510-1705 kHz §15.221 Operation in the band 525-1705 kHz. §15.223 Operation in the band 1.705-10 MHz. §15.225 Operation within the band 13.110-14.010 MHz. §15.227 Operation within the band 26.96-27.28 MHz. §15.229 Operation within the band 40.66-40.70 MHz. §15.231 Periodic operation 40.66-40.70 MHz and above 70 MHz. §15.233 Operation within the bands 43.71-44.49 MHz, 46.60-46.98 MHz, 48.75-49.51 MHz and 49.66-50.0 MHz. §15.235 Operation within the band 49.82-49.90 MHz. §15.237 Operation in the bands 72.0-73.0 MHz, 74.6-74.8 MHz and 75.2-76.0 MHz. §15.239 Operation in the band 88-108 MHz. §15.240 Operation in the band 433.5-434.5 MHz. §15.241 Operation in the band 174-216 MHz. §15.242 Operation in the bands 174-216 MHz and 470-668 MHz. §15.243 Operation in the band 890-940 MHz. §15.245 Operation within the bands 902-928 MHz, 2435-2465 MHz, 5785-5815 MHz, 10500-10550 MHz, and 24075-24175 MHz. §15.247 Operation within the bands 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz. §15.249 Operation within the bands 902-928 MHz, 2400-2483.5 MHz, 5725-5875 MHZ, and 24.0- 24.25 GHz. §15.250 Operation of wideband systems within the band 5925-7250 MHz §15.251 Operation within the bands 2.9-3.26 GHz, 3.267-3.332 GHz, 3.339-3.3458 GHz, and 3.358- 3.6 GHz. §15.252 Operation of wideband vehicular radar systems within the bands 16.2-17.7 GHz and 23.12- 29.0 GHz. §15.253 Operation within the bands 46.7-46.9 GHz and 76.0-77.0 GHz. §15.255 Operation within the band 57-64 GHz. §15.257 Operation within the band 92-95 GHz.

37. Part 15 Most Common Sections 15.227 27MHz Toys 15.231 Momentary-On Remote Controls 15.235 49MHz Toys 15.239 88 - 108 MHz Personal FM Transmitters* 15.247 Spread Spectrum Transmitters* 15.407 UNII Devices*

38. Part 15D - Unlicensed PCS Bands 1910 - 1930 MHz 2390 - 2400 MHz Unique Antenna Connector Required 3 dBi Max (1 to 1 Power Reductions vs. antenna gain) OK for TCB approval Rarely used FCC section. But more activity this past year as this section has recently been re-written Still very complicated.

39. Part 15E - UNII Unlicensed National Information Infrastructure 5.15 - 5.25 GHz 5.25 - 5.35 GHz 5.47 - 5.725 5.725 - 5.825 GHz** 802.11a transmitters Specific power and usage limitations for each band Indoor use only in the 5.25 - 5.35 GHz band. DFS compliance required – filing to FCC **Also shared with 15.247

40. Part 15 F: UWB (Ultra-Wide Band) Adopted in April of 2002 Does not yet qualify for TCB Approval No standardized test procedures yet adopted Devices range from see-through-wall devices, ground radar for construction and safety, to low power communication. Operates over wide area of band (1 to 3 GHz wide signals)

41. Spread Spectrum Devices DTS/DSSS and FHSS (WiFi and Bluetooth)

42. Spread Spectrum Definitions Direct Sequence and DTS - use a sequential modulation to spread a narrow signal over a relative broad band. Example: 802.11b/g Frequency Hopper - uses an encoded narrow band signal that shifts in a pseudorandmly generated frequency shifts. Example: Bluetooth Hybrid – a combination of both Frequency Hopping and Direct Sequence systems

43. Spread Spectrum Frequencies oOperate in the Industrial, Scientific, and Medical bands on a secondary basis. oISM bands are global and not restricted by ITU regions oNo protection from interference o902 - 928 MHz o2400 - 2483.5 MHz o5725 - 5850 MHz

44. WiFi 802.11b/g channels FCC rule interpretations do not allow the end user to select the country or region, nor do they allow the end user to download International driver channel sets. The only legal channels are Channel 1 (2412MHz) to Channel 11 (2462 MHz)

45. FCC Rules for Spread Spectrum Transmitters Power Output 1 Watt Max (except for specific cases) EIRP 4 Watts Max (except Point to Point) Antenna Gain: limited to +6 dBi without power reduction from transmitter of 1 dB power for every 1 dB antenna exceeds 6 dBi Unique antenna connector required (except under professional installation)

46. Additional FCC Requirements For systems operating strictly as a Point to Point systems oin the 2400 - 2483.5 MHz band, the power reduction requirement is 1 dB for every 3 dB the antenna exceeds 6 dBi oin the 5725 - 5850 MHz band may employ antennas with directional gain greater than 6 dBi without reduction in transmitter output power.

47. Additional Requirements oMust Operate on Non-Interference Basis (cannot interfere with others) oMust accept that interference may affect operation – no legal recourse oOut of Band requirements including being 20 dBc down in any 100 kHz outside the Band of Operation (In reality, ~75 dBc down from peak in the Restricted Bands is probably necessary)

48. Spread Spectrum Testing oRadio testing typically performed in several parts oLab bench testing for all conducted tests oListed open field test site or Semi-Anechoic Chamber required for all radiated tests.

49. Spread Spectrum Test Software Requirements oMust be able to turn on/off transmitter, select antenna ports, and go to receive-only mode. oMust be able to select low, mid, and high channels. oMust be able to run in continuous transmit mode. This means without any carrier pulsing. If this requirement cannot be met, then additional corrections are required for many tests. oMust be able to check across all data rates and modulations. oFor Bluetooth, must be able to set to DH1, DH2, DH3

50. MIMO (802.11n) Considerations o802.11n is not a huge compliance issue. oBe sure to measure RF Pout across each chain or output port oPout on Grant will be sum of all powers. oSAR measurements are still under development by the Commission. Some guidance is available

51. Family Antenna Approvals Allows the use similar antennas without re-testing or filing a Class II Change. oExample: A 2dBi inverted-f antenna originally approved for use with a specific device. A manufacturer can substitute a 0dBi inverted-f from a different supplier without re-testing as long as conducted TX output power remains the same oIf new antenna of greater gain or different type, then Class II PC must be filed.

52. Modular Approval - DA00-1407 Must have its own FCC ID number on the module itself. oAn ID inside manual is never sufficient. An additional label is required on the outside of the final host device with wording such as: oContains Inside FCC ID: XXXxxx Must meet the Requirements of OET 65 for RF Safety

53. Full Modular Approvals By Definition, these transmitters must have own reference oscillator. In addition a separate letter on Applicant letterhead addressing all these items must accompany the filing: 1.RF shielding. 2.Buffered data input/output ports 3.Power supply regulation 4.Permanent antenna or unique connector 5.Testes in stand alone condition 6.Labeled with own ID number 7.Instructions to operator / OEM integrator 8.Must meet RF Exposure requirements.

54. Limited Modular Approval (LMA) If any of the 8 elements on the preceding slide cannot be met, a limited modular approval may be obtained in some circumstances. LMAs define special circumstances where Certification is valid Example 1: Wireless mini-PCI 802.11b/g card without voltage regulation Example 2: Wireless mini-PCI 802.11b/g card with SAR results which may apply to a specific chassis or model notebook PC host.

55. 15.203 Unique Connector Requirement Standard Connectors now include: oSMA, TNC, BNC are not allowed oMMCX, MCX and reverse SMA,TNC are possible candidates for in this list oIntegral Antenna requirements which used to be part of 15.407 have been eliminated

56. 15.204 Power Amplifier Restrictions oMust be seen as a complete end-to-end transmission system. oMust include seperately approved transmitter and antenna, in addition to amplifier. oAmplifiers designed for use with Spread Spectrum Systems must be approved as part of the system and marketed as part of a complete package. oAdditional clarification to 15.204 requirements exist in FCC Knowledgebase.

57. Spread Spectrum RF Exposure Requirements 15.247 (b)(4) : System shall be operated to ensure that public is not exposed to levels of RF emissions that exceed the recommended FCC Guidelines References: oOET 65 Supplement C oTCB July 17, 2002 Exclusion list

58. General RF Exposure Definitions Fixed or mast mounted on permanent outdoor structures. Mobile equipment - greater than 20 cm to the body Portable equipment -20 cm or less to the body. Note: A device may be subject to multiple categories depending on its use. In this specific case, particular attention must be all possible usage conditions.

59. Spread Spectrum RF Exposure Requirements Fixed and Mobile Devices must meet OET-65 MPE RF Safety Requirements (1 mW/cm 2 for 2.4 GHz Devices) Portable devices are subject to SAR evaluation when conducted or EIRP output power is greater than 60/f(GHz) if contact with antenna is possible, or 120mW/f(GHz) if a distance of 2.5cm can be assured. oDoes not apply to 15.407 UNII 802.11a. All RF category Portable 802.11a devices must undergo SAR evaluation regardless of RF Pout

60. Spread Spectrum Test System Requirements oAll reading below 1 GHz in Quasi-Peak. oAll readings in both Peak and Average above 1 GHz. oPlots of Band Edge Measurements or Marker Delta method

61. Spread Spectrum Testing Transmit Power Peak Measurement - Antenna conducted measurement Use power meter with peak head detector oNote: Certain power meters with VBW specifications less than the 6 dB bandwidth of the fundamental have caused concern and should be avoided Diode detector/signal generator substitution method with an oscilloscope. RMS measurement techniques during the period of the data burst allowed.

62. Spread Spectrum Testing Radiated Transmit Power Peak Measurement. With highest gain of each antenna family With lowest gain antenna and EUT at Max Power Spectrum Analyzer settings: oRBW = 1 MHz oVBW > RBW

63. Spread Spectrum Testing Band Edge (Radiated) Low and Highest Frequency of operation Peak Readings oRBW = 1 MHzVBW > RBW Average Readings oRBW = 1 MHzVBW = 10Hz

64. Spread Spectrum Testing Harmonics (Radiated) oFrequencies : Low, Middle, Highest channels Spectrum Analyzer settings oPeak mode: RBW = 1 MHz VBW > RBW oAverage: RBW = 1 MHz, VBW = 10 Hz. Average method assumes carrier is at 100% transmit duty cycle. Different settings may need to be employed if duty cycle is less than 100%

65. Spread Spectrum Class II changes cover: oAddition of second antenna oModification of RF Exposure report oMoving from one RF category to another is discouraged Limited test suites can be used. oi.e. PCMCIA card with new layout would require new SAR test plus radiated emissions only. No bench tests required.

66. Spread Spectrum Submittal Requirements All spurious emission data above 1 GHz taken with average detector, but peak must be provided to show compliance with 15.35(b) Data and plots (peak & average) for band edge emissions Harmonics (peak & average) to 10th harmonic TX power (radiated & conducted)

67. 15.247 Out of Band Emission Requirements In any 100 kHz bandwidth outside the frequency band in which the spread spectrum intentional radiator is operating, the radio frequency power that is produced by the intentional radiator shall be at least 20 dB below that in the 100 kHz bandwidth within the band that contains the highest level of the desired power, based on either an RF conducted or radiated measurement.

68. Transmitter Power Output Test Preferred RF Pout measurement – Peak Power Meter or RMS during period of data burst When measuring RF Conducted Power with spectrum analyzer - recommended setting of RBW > 6 dB of EUT emission bandwidth VBW > RBW

69. Band Edge Testing – below 2400 MHz oTest on Channel 1 oFor Frequencies between 2390 - 2400 MHz signals must be 20 dBc down from fundamental. oFor 2390 MHz to 2300 - signals must comply with 15.209 levels (Restricted Bands of 15.205) oMust test in all data rates.

70. Band Edge Testing – above 2483.5 MHz oUpper restricted band begins at 2483.5 MHz band edge - all signals must be compliant to 15.209 limits oDifficulties in compliance when 802.11b/g set to channel 11. This consistently is the hardest test. oSome equipment programmed to special power limits just to comply with restricted band. oMust test in all data rates

71. Harmonics \ Spurious \ Restricted Bands Testing oRequired for Each transmitter and Antenna Combination. oLowest, Middle, and Highest Frequency checked oWorst Case RF Pout/data rate checked oUp to 10th Harmonic of Fundamental oRequires Pre Amp and High Pass Filter oTesting Distance 3 meters

72. FCC Submittal Information Test Data: oMax Output Power (at Antenna port and EIRP) oQuasi-Peak < 1 GHz oBoth Peak and Average > 1 GHz oPlots of Band Edge Measurements or Marker Delta method

73. UNII Devices (802.11a)

74. UNII Devices Part 15 Subpart E Unlicensed National Information Infrastructure Rules adopted in 1997 These devices are part of the TCB Scope Frequencies of Operation o5150 - 5250 MHz (Indoor Use Only) o5250 - 5350 MHz (DFS/TPC Required) o5470 - 5725 MHz (DFS/TPC Required) o5725 - 5825 MHz (Shared with 15.247)

75. UNII Devices Part 15 Subpart E Transmitter Power Output o5150-5250 MHz Band50 mW o5250-5350 MHz Band250 mW o5470-5725 MHz Band250 mW o5725-5825 MHz Band1 Watt All RF category Portable UNII devices must have SAR testing

76. UNII Devices Part 15 Subpart E All DFS test reports must be approved by FCC Client only devices which do not have DFS but will change channels in response to commands from an access point are allowed to be approved by TCBs Client only devices must be tested with DFS capable golden transmitter Client only devices cannot be capable of ad-hoc capability

77. UNII Devices Part 15 Subpart E Antennas limited to 6 dBi gain without transmitter power reduction. Low bands may use antennas > 6 dBi, however transmit power and power spectral density must be reduced by gain of antenna that exceed 6 dBi 5.8 GHz band allows use of up to 23 dBi gain antenna for point to point systems without transmitter power reduction.

78. Contact Information William H. Graff President and Director of Engineering AmericanTCB, Inc. 6731 Whittier Ave. McLean, VA 22101 mailto: whgraff@ATCB.com Corporate Phone: (703)847-4700 Corporate FAX: (703)847-6888 Direct Mobile: +886 920399260 SKYPE: whgraff