Your Questions, Our Answers: FCC Transition Plan for U-NII Devices

Dan Crowder, TCB Manager

Today's Elite Expert is Dan Crowder, our Certification Department Supervisor and FCC/CE Mark Team Leader.  Dan is a senior EMC Engineer actively involved in transmitter standards development--including ANSI C63.10 and ANSI C63.26, the TCB Council, and the IEEE EMC Society. Read below to see what he has for us this week. 

As some may have heard, the FCC has made some major changes to rule parts that pertain to U-NII (Unlicensed National Information Infrastructure) type devices. The specific rules and guidance documents can be found on the FCC website. The purpose of this blog is to provide answers to some specific questions that have been asked.

Question 1: What are the effective dates for the U-NII rules adopted by the Commission in ET Docket No. 13-49 (FCC 14-30)? 

Answer 1: The new U-NII rules in the Report and Order ET Docket No. 13-49 are effective from June 2, 2014. Applications for certification of new devices under the new U-NII rules can begin after the effective date. In adopting the revised rules, the Commission also established a transition time period during which devices may be approved under rules in effect prior to June 2, 2014 (“Old Rules”) or after the effective date (“New Rules”). 

Source: www.which.co.uk

Permissive Change: § 2.1043 addresses the conditions for Class II and Class III permissive changes for equipment that has not been modified through changes in hardware. Such changes are permitted by software only. KDB Publication 178919 provides some additional guidance for permissive changes. In the following references to Class II permissive changes also include Class III permissive changes for SDR radios unless specifically noted.

Question 2: What is the transition period during which “Old Rules” can be used to show compliance? 

Answer 2: Applications for new devices can be filed under the “Old Rules” until June 2, 2015; after this date, applications for all new devices must be filed under the “New Rules”. Class II or Class III permissive changes for devices approved under the “Old Rules” may be filed under the “Old Rules” until June 2, 2016 (two years after the effective date of the rules). After June 2, 2016, all applications for new device and permissive changes for previously approved devices must meet the “New Rules” for operation in all grant-listed U-NII sub-bands. 

Question 3: How long can the devices approved, under the “Old Rules”, be marketed without a new application? 

Answer 3: Devices approved under the “Old Rules” may be marketed until June 2, 2016. All devices marketed sold, manufactured, imported or newly installed in the USA must meet the “New Rules” after June 2, 2016. Devices already in use and installed are grandfathered.

Question 4: Are there different test compliance procedures under the “Old Rules” and the “New Rules”? 

Answer 4: Yes, for details see the appropriate KDB Publications. KDB Publication 905462 lists the appropriate guidance documents for devices subject to DFS requirements. KDB Publication 789033 provides guidance for EMC testing. KDB Publication 594280 provides guidance on software configuration control and security. In addition, appropriate compliance guidance should be followed for devices subject to RF exposure evaluation. 

Question 5: How long will devices continue to be approved under the “Old Rules”? 

Answer 5: June 2, 2015 is the last day to file new FCC ID applications under the “Old Rules”. June 2, 2016 is the last day to file permissive change applications under the “Old Rules”. All devices marketed, imported or sold after June 2, 2016 must meet the “New Rules”.

Question 6: Do we have to update filings for all operating devices? 

Answer 6: No, but devices approved under the “Old Rules” are subject to the transition requirements and cannot be marketed, manufactured, imported, sold or newly installed after June 2, 2016. Devices already in use and installed are grandfathered.

With the changes that FCC has made for U-NII devices, I am sure that many other questions will come up. FCC has done a great job providing guidance to make the transition process as simple as possible.

Do you have any questions about FCC rule changes, wireless testing, or other related topics? Please share your comments or questions below and our expert, Dan Crowder, will get back to you.

Automotive Standards Development 2014 Recap

Today, Elite's EMC Lab Manager Craig Fanning fills us in on what's been brewing in Automotive and Military standards so far this year. As a featured speaker at this year's ROACH Conference in Seattle, he presented a “Review of Automotive Standards Utilizing Reverberation” and participated in the “Emerging Technologies in EMI/EMC testing” panel discussion.  He also attended several other meeting concerning EMC standards this spring and was kind enough to pass along some notes and a couple snapshots  Read below to see what he has for us this week.

Automotive standards development at the North American and International levels continues to be hectic in 2014. The SAE EMC committees had a meeting in January of 2014 and will be having another in April. At the international level, CISPR/D WG1, CISPR/D WG2 and ISO/TC22/SC3/WG3 had their first of two meetings scheduled for 2014 in February. 

 

Craig at the IEEE EMC Society Seattle sponsored ROACH meeting

Experts from eight countries convened at the ETS Lindgren facility in Cedar Park, Texas to continue work on the CISPR 12, CISPR 25, ISO 11451-xx, ISO 11452-xx, and ISO 7637-x standards. ETS Lindgren was kind enough to host the meetings per the request of the CISPR and ISO USTAG Delegates. The meetings were a great success and a lot of progress was made towards next revisions of the subject standards. The CISPR/D and ISO committees greatly appreciated the support of ETS Lindgren and their staff again for the meetings. The next international level meetings for these standards groups will be held in Frankfurt, Germany in October 2014.

  

The  Chapter hosted the Reverberation Chamber, Open Area Test Site and Anechoic Chamber (ROACH) Users Group meeting in Seattle, Washington in March 2014. The ROACH meetings are a “think tank” for key players in the EMC industry. Standards updates and new technologies regarding reverberation chamber, anechoic chamber and TEM cell testing were presented. This meeting drew experts from around the world. The experts were there to make presentations and were also available for sidebar discussions. This meeting was a great opportunity for people in the EMC industry to talk “shop” with others in the industry. Pat Hall and I had a great time both during and after the formal meetings. Take a look at that pile of Pacific coast seafood… 

Pacific Seafood Feast for the Sake of Science!

Do you have any questions about EMC Standard Changes, Testing in Reverberation Chambers, or other related topics? Please share your comments or questions below and this week's expert, Craig Fanning, will get back to you as soon as possible.

Hidden Gems on the Web: Killer EMC Resources

Okay let's be honest, we all find ourselves drawn to web resources like Wikipedia and YouTube because it's just so easy to find what you need. No doubt, these and other websites help us be more productive at our jobs with quick answers and explanations to basic technical questions and interests.  But what if you need more detailed and trustworthy information? 

Here at Elite, we regularly connect with several government and private web sites and want to make sure our customers have access to the best ones. On the Elite website, we've posted several helpful links to build your knowledge database and be confident in the information you use. Three of our favorite sites include...

• "Quick Assist" website- Provides military standards and handbook
• "FCC OET" website- Connects you with the FCC OET Knowledge Data Base
• "Europa" website- Supplies European Union CE Marking information

Why SAE EMC Standards Are Being Withdrawn

Craig Fanning, EMC Lab Manager

Today's Elite Expert is Craig Fanning. Our EMC Lab Manager since 1995, Craig has overseen scores of test projects over the past 27 years with the company. He is also an iNARTE Certified EMC Laboratory Engineer and author of several papers for the IEEE EMC Symposium.  Finally, as a member of SAE EMI and EMR Committees, as well as a US National Committee technical advisor for CISPR-D, he undoubtedly likes to stay active in the EMC community. Read below to see what he has for us this week.

Users of SAE EMC standards may have noticed that many of the SAE J551 and SAE J1113 standards have been withdrawn over the past few years. These withdrawn standards are no longer being revised and updated. As these standards are withdrawn, the base standard of the series (SAE J551-1 or SAE J1113-1) is updated to indicate that the particular SAE standard has been withdrawn. The base SAE standard also directs the user to reference the equivalent CISPR or ISO standard. Unfortunately this results in having to purchase the more expensive international standard which replaced the SAE standard.

So, why are the SAE EMC standards being withdrawn???  A few years ago, SAE noticed that some of the SAE EMC standards were, for the most part, technically identical to some equivalent CISPR and ISO (international) standards.  This became a concern of SAE as they do not want to get into copyright conflicts with the international standards bodies. Therefore, the SAE EMC committee was given the directive to start withdrawing any SAE standards which were technically identical to an international standard.
 

How did this similarity of SAE and International standards come to happen??? The SAE EMC committee has developed many vehicle and component EMC standards over the years. The SAE standards were referenced mainly by the North American vehicle manufacturers in their corporate EMC standards. As the NA vehicle manufacturers evolved to Worldwide vehicle manufacturers, the trend to reference SAE standards in their corporate standard changed to the desire to reference international standards (if they existed) in their corporate standards.

Many of the same experts involved in the SAE EMC committee in the United States are also involved with at the International Standards development level (CISPR and ISO standards). During meetings at the international level, the need to develop a standard to address a particular field issue may be discussed. If an SAE standard which addressed the issue already existed, then the international standards committee would use the SAE standard as the basis for development of a new CISPR or ISO standard. Although the process to publish the international standard would take several years, the two standards (SAE and International) would eventually become very similar.

What is the long term benefit of using international standards over the SAE standards??? Although it may seem like a burden to purchase a more expensive CISPR or ISO standard, the use of the international standards does have its benefits. The test methods used to evaluate the EMC performance of vehicles (and vehicle modules) should be similar around the world to assure consistent performance. Products initially developed for sale in the North American market may also be more easily marketed worldwide when tested against the international standards.  

Ultimately, standardization helps to assure consistent performance and reliability no matter where the product is being used. By using international standards to evaluate the EMC performance of products (when available), this will help the product manufacturers to better achieve the consistent performance and reliability desired by the consumer. 

Do you have any questions about EMC Standard Changes, EMC Testing, or other related topics? Please share your comments or questions below and this week's expert, Craig Fanning, will get back to you as soon as possible.  

A New & Improved Standard for Unlicensed Transmitters? - C63.10-2013 Review

Dan Crowder, TCB Supervisor

Today's Elite Expert is Dan Crowder, our Certification Department Supervisor and FCC/CE Mark Team Leader.  As a senior EMC Engineer actively involved in transmitter standards development--including ANSI C63.10 and ANSI C63.26, the TCB Council, and the IEEE EMC Society, Dan's seen his fair share of transmitter issues and solutions. Read below to see what he has for us this week.

C63.10-2013 was released back in September and has received quite a bit of praise – but it has some caused some controversy as well.

The purpose of C63.10 was to put all the test methods for unlicensed transmitters into one document. The first version of the standard was released in 2009 and included what was considered to be “non-confrontational” test methods. The standard was adopted by the FCC and Industry Canada for the testing of unlicensed transmitters. Four years later, version two has been released and includes the so called “confrontational” test methods.

The standard covers every type of transmitters that fall into the unlicensed category. The test methods have been gathered from a multitude of resources including the FCC, Industry Canada, manufactures, test laboratories and certification bodies from around the world.  Very detailed instructions have been provided for some very complicated transmitters including digital transmission systems that include transmitter power control and dynamic frequency selection. These procedures were only published in various FCC knowledge database documents that were sometimes tedious to dig up.

Another useful tool is a reference table included in Annex A. The table steps through the FCC Part 15 rules one by one and cross-references sub-clauses in the standard to point out specific tests that pertain to the specific rule part.

This standard along with C63.4 can be used as test methods for almost every unlicensed transmitter.

As a test laboratory, you should lookout for procedures that have not been adopted by the regulating bodies. One that stands out in my eyes is the formula for distance correction factor for frequencies below 30MHz.

Overall, C63.10-2013 is a huge improvement over any previous document or documents for test procedures for unlicensed transmitters.

Do you have any questions about transmitter standards, certification, or other related topics? Please share your comments or questions below and our expert, Dan Crowder, will get back to you.