TCB Sharing of FCC KDBs

1. TCB Sharing ofFCC KDBs Michael Derby TCB Council Chairman 9th April 2014 TCB Council

2. Introduction • Overview of the main FCC KDB types • General KDB enquiries • Proposal for improvement and education of our industry • Examples • Feedback TCB Council

3. KDB Types • Main types of KDB sent from the FCC • General information sent by the FCC • KDB 558074 for DTS, KDB 447498 for RF Exposure • Response to enquiry; specific to project • Model XYZ does ABC; can I proceed with this result? • FCC will reply; specific to that project • Will include KDBs such as PBA • Do not share these KDB responses TCB Council

4. KDB Types • Main types of KDB sent from the FCC • Response to enquiry; general guidance • In general, with “X” situation; what do I do? • Not project specific (even if you asked because of a project!) • FCC will reply; general interpretation of their rules • Often very useful to everyone • This is what we’re talking about! TCB Council

5. General KDB Enquiries • Sent to the FCC by a TCB, Test Lab or Manufacturer; for general guidance • Not specific to one project or model • Useful, informative guidance from the FCC • Would benefit the whole industry • Note that if the KDB guidance is ‘restrictive’ in any way, then it may be advantageous to share this! • This could also apply to guidance from IC TCB Council

6. KDB Sharing Proposal • We propose to gather these and share • Recipient sends them to the TCB Council • We e-mail to members, if appropriate • We present details at the subsequent workshop • At the time of writing these slides, the exact format has yet to be agreed with the FCC and Industry Canada TCB Council

7. Examples • Three examples of what we mean • Full KDB text not included at this time • Full KDB may be e-mailed to TCBC membership with agreement from the FCC and the company who submitted the KDB enquiry • Text may be copied from original KDB to provide anonymity in certain cases TCB Council

8. Limited Modular Approval • Can a module without a shield be tested in a stand-alone configuration, for LMA? • FCC: “No” • Limited Modules must be tested in a typical host device and/or configuration • For a module with no shield, this would mean testing must be performed with the module ‘inside’ the host • LMA is literally limited to a specific host or group • Module Grantee is responsible for compliance of the module in the final host product, not the OEM TCB Council

9. Non-USA Frequency Changes • Changing non-USA frequency band hardware such as 900 MHz / 1800 MHz components • Can this be a Permissive Change because those bands are not listed on the FCC Grant? • FCC: This requires a new FCC ID • This cannot be a Permissive Change • Certification covers all transmitter hardware • Changes would make it “non-identical” TCB Council

10. DTS Duty Cycle and 15.35 • KDB 558074 for DTS states that spurious emissions cannot apply 15.35(c) duty cycle • Can we use it for devices with fixed duty cycle? • FCC: This is an acceptable deviation • 15.35(c) can be applied to maximum duty cycle • Duty cycle must be source based (hard-wired) • Expect modification in next KDB 558074 TCB Council

11. Useful Proposal? • What do you think? • Do you think this is useful? • Would you be happy to receive this information? • Would you be happy to send this information? • Please send information, concerns, suggestions; and KDB replies! to the TCB Council TCB Council

12. Thank You Michael Derby TCB Council, Chairman michaeld@acbcert.com TCB Council