FCC REGULATIONS

FCC Updates Part 15 of the Technical Rules

David A. Case

Technological advances lead to more changes to FCC rules.

As part of its biennial review, the Federal Communications Commission (FCC) has adopted changes to Parts 2 and 15 of the technical rules. On June 25, 2003, under ET Docket 01-278, FCC made the changes to reflect technological changes such as the advent of software-defined radio and increased Internet use by the general public. The review, under Notice of Proposed Rule Making (NPRM) 01-278, also dealt with some minor cleanup in Parts 2 and 18 of the rules. One issue was addressed in Part 90. This report was the second Report and Order (R&O) and Memorandum Opinion and Order issued as part of this proceeding.

The First R&O

The first R&O, which was released in 2002, addressed the requirements for radar detectors and emissions above 1 GHz for these devices. Before the release of this R&O, radar detectors were covered under receiver specifications, and these devices were not required to be tested or to be certified if operating above 960 MHz. However, due to the increased interference from the radar detectors' local oscillators to some satellite service receivers, FCC ruled that these devices needed to meet the FCC Class B limits in the 11.7 to 12.2 GHz band. FCC further required that after October 27, 2003, radar detectors not meeting the emissions limits for this band could no longer be marketed or sold. This deadline was extended by a request for a 30-day waiver. Additional issues addressed in the original NPRM were, for the most part, dealt with in the second R&O.

The Second R&O

In the second R&O, FCC removed some of the frequencies in the bands above 38.6 GHz from the restricted band table. Several parts of the spectrum above 38.6 GHz were removed. These bands were mainly the second and third harmonics for those systems operating in the 24.0 to 24.5 GHz band. FCC also decided not to address any changes in the Part 15 emissions limits over 2 GHz.

The R&O also removes the restriction prohibiting transmission of voice or data for devices operating under Part 15.231. Under the original Part 15 regulations, only those devices that met the requirements under section (e) of Part 15.231 could transmit voice or data. The new regulations will allow systems operating under the other sections of Part 15.231 to transmit voice or data as well. The commission did not, however, accept the proposed changes to duty-cycle averaging under this proposal.

Also addressed in this R&O were modifications to rules for radio-frequency identification (RFID) systems. FCC had proposed adoption of different limits for operation in the 13.553 and 13.567 MHz bands. The proposal increases the maximum power from 10,000 to 15,848 µVm at 30 m in the 13.410- 13.553 MHz band. It also increases maximum power from 30 to 334 µVm at 30 m for the 13.710-14.010 MHz band. In the restricted 13.36-13.41 MHz band, the new rules will also permit emissions (other than just spurious emissions) for RFID.

The R&O also addressed modifications to the Declaration of Conformity (DoC) labels for products. For Class B products, FCC has eliminated the requirement for manufacturers to add the phrase "for home and office use" to the DoC. Devices assembled with certified components must still keep the label. In addition, the warning information required under Part 15.19 is still required on the label.

The R&O also addressed appropriate formats for the FCC warnings and information needs to be provided to end-users. If the device comes with a paper or CD manual, the information must be included in those formats. If the manuals are available only via the Internet, or if the device does not have the capability of reading a CD or connecting to the Internet, then information, including RF safety information, can be provided to the end-user over the Internet.

FCC agreed to drop the requirements for certification of intentional radiators operating below 490 KHz. The device's emissions must be at least 40 dB below the applicable Part 15 limits. which can be demonstrated either by measurement or by calculation.

Also modified were the Part 2 testing requirements for Part 95 family radio services. This change allows these devices to test over the frequency range 462-468 MHz and at a temperature range of -20° to +50°C instead of -30° to +50°C. These new parameters test systems over a range that is more typical for these devices. The FCC changes should help reduce vendor costs for these parts.

In addressing test requirements for Part 15.31 of the technical rules, FCC has adopted ANSI C63.4-2001 as the replacement for the 1992 version. FCC also clarified the requirements for testing below 30 MHz and now stipulates that only a loop antenna may be used for measuring for Part 15 compliance. Note that FCC still allows measurements from 27 to 30 MHz to be made with a biconical antenna provided that the antenna has been calibrated below 30 MHz. This further clarification should relieve both FCC and the telecommunications certification bodies (TCBs) from the occasional headache of requiring a retest of systems below 30 MHz when done with a rod antenna.

FCC also adopted ANSI C63.17 for testing unlicensed personal communications system (PCS) devices under Subpart D. This standard was developed specifically for testing these types of devices.

To streamline the process for accrediting labs, FCC removed the requirement for them to file their normalized site attenuation (NSA) curves and information. However, the accreditation agency must provide FCC with the information on the lab's accreditation. The R&O also addresses some modifications to the bandwidth in Part 2.202 (see Table I). As part of this R&O, FCC also made some minor corrections to other sections of Parts 2 and 18.

Remaining Issues

Several issues must still be clarified under this R&O. Some issues are still open under the Part 15 biennial review NPRM 02-312.Technically, NPRM 02-312 was disposed of in late 2002, so the remaining issues will likely turn up as comments filed in other rule makings. Among these issues is a request to eliminate Part 15.203, which addresses unique connectors for Part 15.247 and Part 15.407 devices. Another lingering issue is the removal of the integrated antenna requirement for Part 15.407(a) devices. Also requested is a better definition of professional installer under Part 15.203. The process continues. Filings will likely request clarification of some of the changes covered in ET Docket 01-278.

David A. Case, NCE, NCT, is senior regulatory engineer for Cisco Systems Corporate Compliance EMC Standards and Operations. He can be reached via e-mail at davecase@cisco.com.