An Update on U.S. and Canada Wireless Rulemakings. Greg Kiemel Department Manager

An Update on U.S. and Canada Wireless Rulemakings Greg Kiemel Department Manager

Outline Regulatory Approval Trends Latest News FCC ISED (f/k/a IC) Compliance Considerations 2

Regulatory Approval Trends

FCC Approval Trends Virtually all radios sold in the U.S. require FCC certification. To keep up with the increasing number of applications, the FCC created the Telecommunications Certification Body (TCB) program in June 2000. TCBs certify wireless products under the authority of the FCC. FCC Report and Order (FCC 14-208) released 12/30/14 made TCBs the only route to certification. The FCC will no longer accept applications for certification. 4

TCB Application Trend 50000 40000 Approvals 30000 20000 10000 0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 FCC TCB Year Source: https://apps.fcc.gov/oetcf/eas/reports/genericsearch.cfm 5

Application Trends Jan 1, 2016 Dec 31, 2016 TCBs issued 51475 Approvals, FCC 13 6

ISED Approval Trends Virtually all radios sold in Canada require Innovation, Science and Economic Development (ISED) certification. Formerly known as Industry Canada (IC). To keep up with the increasing number of applications, IC created the Certification Body (CB) program in March 2004. CBs certify wireless products under the authority of ISED. ISED will still accept applications for certification, but they push for the use of Certification Bodies (CBs). Like TCBs, CBs provide a faster, more convenient option than submitting an application directly to ISED. 7

Latest News FCC 14-208 & FCC 16-74

FCC Report and Order (FCC 14-208) FCC 14-208 was released Dec 30, 2014, but did not go into effect until July 13, 2015 (30 days after publication in the Federal Register on June 12, 2015). https://apps.fcc.gov/edocs_public/attachmatch/fcc-14-208a1.pdf The R&O made the following changes to the equipment authorization program: FCC will no longer accept applications for certification. All grants will be issued by TCBs. Codified a pre-approval guidance procedure, currently known as the permit but ask (PBA) procedure, that TCBs must follow when certifying equipment based on new technology that requires consultation with the FCC Clarifies a TCB s responsibilities in performing market surveillance of products it has approved; Specifies steps for addressing instances of deficient TCB performance, including appropriate sanctions for deficiencies that do not warrant rescinding a TCB s authority to issue a grant of Certification; Modified the rules to reference new standards (ISO/IEC 17065) used to accredit TCBs 9

FCC Report and Order (FCC 14-208) The R&O changes continued: Requires labs that test for certification or DoC to be accredited. Codified a procedure through which the Commission currently recognizes new laboratory accreditation bodies; Updated references to industry measurement procedures in the Commission s rules (e.g. ANSI C63.4-2014 and ANSI C63.10-2013); Provides greater flexibility to enable the FCC s OET to address minor technical issues that may be raised when updating to the latest versions of industry standards that are referenced in Parts 2, 5, 15, and 18 of the Commission s rules 10

FCC 14-208: Accredited Testing Laboratories After the transition date, testing in support of certification or a Declaration of Conformity (DoC) must be performed by an accredited testing laboratory that is FCC recognized and has the appropriate scope of accreditation. The following options are available for a testing laboratory to be recognized as an accredited laboratory: 1. Testing laboratories located in the United States may be recognized by the FCC if they are accredited by one of the following FCC recognized accreditation bodies: NVLAP, A2LA, ACLASS or LAB. 2. Testing laboratories located outside of the United States may be recognized by the FCC if they are designated as an accredited testing laboratory under the terms of government-to-government Mutual Recognition Agreement (MRA). 3. Testing laboratories located in non MRA countries are not FCC recognized as accredited under the current procedures. [FCC 14-208 has since been modified by FCC 16-74. Under FCC 16-74, accreditation by FCC-recognized accrediting bodies is also accepted.] FCC / OET is working on updates to the related KDB publications to address the scope of accreditation required to perform the testing according to the standards the Commission has recognized or incorporated by reference. It is anticipated that it will be necessary for testing laboratories to update their scope of accreditation to list additional standards (measurement procedures). [ Test lab roles and responsibilities has now been released under KDB 974614. Test labs must update their scope of accreditation to meet KDB 97614 requirements.] 11

FCC 16-74: Memorandum Opinion and Order and Order on Reconsideration Released: June 15, 2016: I. INTRODUCTION 1. In this Memorandum Opinion and Order and Order on Reconsideration, we describe how we will implement the rules that govern how we recognize laboratories as accredited and authorized to perform the compliance testing associated with applications for equipment certification and the bodies that accredit those laboratories; 1 we also extend the transition period by which time all laboratories that test for equipment authorization must have FCC-recognized accreditation to perform such testing. [Extended by 1 year see below]. FCC 2.950(e) changed to: (e) The Commission will no longer accept applications for 2.948 test site listing as of July 13, 2015. Laboratories that are listed by the Commission under the 2.948 process will remain listed until the sooner of their expiration date or through July 12, 2017 and may continue to submit test data in support of certification applications through October 12, 2017. Laboratories with an expiration date before July 13, 2017 may request the Commission to extend their expiration date through July 12, 2017 12

FCC 14-208: Transition Dates See 47 CFR 2.950 for the transition dates: (a) As of July 13, 2015 the Commission will no longer accept applications for Commission issued grants of equipment certification. (f) Measurement facilities used to make radiated emission measurements from 1 GHz to 40 GHz shall comply with the site validation option of ANSI C63.4-2014, (clause 5.5.1a)1)) which references CISPR 16-1-4:2010-04 (incorporated by reference, see 2.910) by July 13, 2018. [Prior to that date, the test facility used can use either site validation option in ANSI C63.4-2014 clause 5.5.] (g) Measurements for intentional radiators subject to part 15 of this chapter are to be made using the procedures in ANSI C63.10-2013 (incorporated by reference, see 2.910) by July 13, 2016. [Can be used now] (h) Measurements for unintentional radiators are to be made using the procedures in ANSI C63.4, except clauses 4.5.3, 4.6, 6.2.13, 8.2.2, 9, and 13 (incorporated by reference, see 2.910), by July 13, 2016. 13

Latest News FCC 14-30

FCC Report and Order (FCC 14-30) New rules for U-NII devices (e.g. 802.11an) became effective on June 2, 2014. Transition period, see FCC KDB 926956: Starting June 2, 2015, new approvals must be to the new rules. Starting June 2, 2016, permissive changes must be to the new rules. Also products previously certified under the old rules can t be marketed unless they meet the new rules (C2PC application required). Indoor-only restriction removed from the 5.2 GHz band. Also increased the output power in that band. Extended the upper frequency edge of the 5.8 GHz band to match FCC 15.247. They are now both 5725 5850 MHz Harmonized the rules between 15.247 and 15.407 for DTS device operating in the 5.8 GHz band. U-NII device software must be secured to prevent its modification New DFS radar waveform and new test requirements. Removed the restriction on TDWR band of operation (5600 5650 MHz) 15

5.8 GHz Fixed Point to Point Transmitters Subsequent rulemaking relaxed the transition period for 5.8 GHz fixed point to point devices and the emission limits in the adjacent bands: Current requirement is found in FCC 15.407(b)(4)(i): the maximum emissions outside of the frequency bands of operation shall be attenuated in accordance with the following limits: All emissions shall be limited to a level of 27 dbm/mhz at 75 MHz or more above or below the band edge increasing linearly to 10 dbm/mhz at 25 MHz above or below the band edge, and from 25 MHz above or below the band edge increasing linearly to a level of 15.6 dbm/mhz at 5 MHz above or below the band edge, and from 5 MHz above or below the band edge increasing linearly to a level of 27 dbm/mhz at the band edge FCC 15.407(b)(4)(ii) state: Devices certified before March 2, 2017 with antenna gain greater than 10 dbi may demonstrate compliance with the emission limits in 15.247(d), but manufacturing, marketing and importing of devices certified under this alternative must cease by March 2, 2018. Devices certified before March 2, 2018 with antenna gain of 10 dbi or less may demonstrate compliance with the emission limits in 15.247(d), but manufacturing, marketing and importing of devices certified under this alternative must cease before March 2, 2020. 16

FCC 14-30: Output Power in the 5.2 GHz Band The new rules permit much greater output power in the 5.2 GHz band. Also, operation outdoors is now permitted. Outdoor and indoor access points can be up to 1 W conducted output power and 17dBm PSD assuming the max gain is 6 dbi. If the antenna gain is greater than 6 dbi a corresponding reduction in output power and PSD is required. Outdoor access points with gains greater than 6 dbi, the max EIRP at any elevation above 30 degrees from the horizon must not exceed 21 dbm Fixed point-to-point access points can be up to 1 W conducted output power and 17 dbm PSD assuming the max gain is 23 dbi. If the antenna gain is greater than 23 dbi, a corresponding reduction in output power and PSD is required. Power increase for mobile and portable client devices no indoor/outdoor restrictions Conducted output power can be up to 250mW and 11dBm PSD assuming max gain is 6 dbi. If the antenna gain is greater than 6 dbi a corresponding reduction in output power and PSD is required. 18

FCC 14-30: Additional Application Requirements Software Security, Antenna elevation plots, and attestations for master devices are new types of exhibits required for FCC applications When applying for a Class II Permissive Change (C2PC) for a device certified under the old rules, a DTS device operating in the 5.8 GHz band will require changes to both the DTS and NII grants. Various C2PC scenarios for testing depending on the type of device 19

FCC Concern Wireless Charging

Wireless Inductive Charging The FCC has concerns about RF Exposure and the proper authorization procedures: All wireless charging designs need to be reviewed by the FCC for RF exposure guidance prior to equipment authorization this includes both Part 15 and 18 devices. Sooner is better! FCC KDB 680106 provides the guidelines: https://apps.fcc.gov/oetcf/kdb/forms/ftssearchresultpage.cfm?id=41701&switch=p The initial inquiry shall include the following: In the "Subject" line, fill the field as follows: Seeking guidance for wireless chargers; complete product description, including coil diameters, number of turns and current; the rule part(s) the device will operate in and the reasoning for rule part(s); planned equipment authorization procedure; drawings, illustrations; frequencies; radiated power; operating configurations conditions for human exposure In some cases measurements and / or numerical modelling will be required to demonstrate compliance. 21

FCC Part 15 vs Part 18 Depending on the operating configurations, wireless power transfer devices may need to be approved under FCC Rule Parts 15, 18 or both. Devices that transmit telecommunications are authorized under Part 15, but may not transmit in the 90-110 khz band, which is restricted under 15.205. Part 18 of the rules permit devices operating in the Industrial, Scientific and Medical (ISM) band to generate and use RF energy locally to perform work. For consumer devices this operation must be in close proximity and the RF energy must not be used for communications. Systems that use load impedance changes also called load modulation on the client device at the fundamental transfer frequency with limited communication for the sole purpose of load management may be authorized under Part 18. 22

Latest News RSS-102

ISED s RSS-102 Industry Canada published a new standard, RSS-102, Issue 5: 2015 on March 19, 2015. http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf01904.html RSS-102, Issue 5 went into effect immediately for the purposes of certifying new equipment. All devices currently certified that are manufactured, imported or sold in Canada must be in compliance with the revised standard 180 days after its publication on the Industry Canada website (Sept 15, 2015) no matter when they were originally certified Some requirements will not be in force immediately for Nerve Stimulation devices as detailed in Notice 2015-DRS001 http://www.ic.gc.ca/eic/site/ceb-bhst.nsf/eng/tt00106.html Biggest changes are to Section 2.5.1 Exemption limits for SAR evaluation. Many devices that were previously exempt from SAR evaluation are now required to be tested. Of particular concern are Bluetooth, Zigbee, and Wi-Fi devices. 28

RSS-102, Issue 5 SAR Exemption Limits Table 1 limits are based upon the following: Output power level shall be the higher of the maximum conducted or equivalent isotropically radiated power (e.i.r.p.) source-based, time-averaged output power. Linear interpolation shall be applied for the applicable separation distance. For test separation distance less than 5 mm, 5 mm can be applied to determine if a routine evaluation is required. For limb-worn devices where the 10 gram value applies, the exemption limits are multiplied by 2.5 For medical implants devices, the exemption limit for routine evaluation is set at 1 mw 29

RSS-102, Issue 5 SAR Exemption Limits 30

Compliance Considerations

Research Objectives for your Target Market Spectrum Allocation Frequency Bands Output power Data vs. Voice Modulation type Licensed vs. Unlicensed Specifications and Test Methods EMC and RF Safety Equipment Authorization process System or modular approval Self Declaration or submittal to spectrum authority Labeling and User Info 32

Write a Test Plan Compliance Objective Certification, Class II permissive change, or audit. Target markets U.S., Canada, EU, etc. Brief product description List of standards including version and year. Any applicable interpretations or procedures from spectrum authorities. Complete List of operating modes including modulation types, data rates, power levels, and antennas. Detailed equipment configuration for each test Operating instructions 33

Make EMC a Design Consideration The focus of EMC design: grounding, filtering, component selection, PCB layout, and shielding. Single solutions don t exist; but rather a combination of suppression techniques are required. Don t wait until the end of the design cycle to test. One test result is worth one thousand expert opinions Wernher Von Braun 34

Common Design Pitfalls Poor antenna matching Lack of shielding Design objectives or omissions that conflict with regulatory requirements Output power versus operating band RF Exposure Listen Before Talk, Duty Cycle, or Dynamic Frequency Selection (DFS) 35

Get Expert Testing & Approval Services Partner with an EMC laboratory that is accredited for foreign specifications Permits testing in-country to obtain global approvals. For example Japan and Korea wireless can be tested locally. Easy access to someone who is familiar with the requirements of your target market Confirm that your EMC laboratory has experience with your product s technology (Medical, Wireless, ITE, etc.). How many Wi-Fi and Bluetooth devices have they tested? Ask if your EMC laboratory is equipped for the latest EMC test requirements. For example, medical devices require: Radiated Immunity to 6 GHz, 10V/m with uniform field Radiated Immunity in the 4th edition "IMMUNITY to proximity fields from RF wireless communications" Radiated Emissions testing at 10 meters 36

Thank You! For more information, please contact: Kim Valleen kim.valleen@element.com Renee Chavez renee.chavez@element.com Alee Langford alee.langford@element.com Ph. (888) 364-2378 www.element.com 37