Title: Wireless Product Testing William H. Graff, AmericanTCB
1Wireless Product TestingWilliam H. Graff,
AmericanTCB
2FCC 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
3Part 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
4Equipment Authorizations
- There are three basic types of equipment
authorizations - Verification
- Declaration of Conformity
- Certification
5Verification
- 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)
6Declaration 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,
7Certification
- 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
8Changes to Certified Equipment
- Known as Permissive Change
- Changes which have no effect on RF emissions or
performance Class 1 - Changes which affect emissions or performance but
still within the limits Class 2 - Changes to RF software Class 3 This is only
applicable to devices which qualify as Software
Defined Radio (SDR)
9Class 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
10Class 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)
11Forbidden 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)
12Permit-But-Ask ProcedureNew! 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.
13Licensed Transmitter Approvals
14Licensed 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
15Licensed 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
16Licensed 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.
17Basic Test Parameters
- Power Output 2.1046
- Traditionally thought of as a caloric
measurement. Use of common CW power meters were
common. Great deal of measurement certainty. - Part 15 began the usage of peak reading power
meters. Most unlicensed transmitter sections
still require the concept of peak power unless
specifically stated otherwise
18Basic Test Parameters
- Modulation Characteristics 2.1047
- For 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 - For todays constant envelope digital
modulation systems this is basically unnecessary,
but still must be described. Testing usually not
required.
19Basic Test Parameters
- Occupied Bandwidth 2.1049
- Occupied 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. - Although not explicitly specified, all
Certification reports including Part 15 must have
an occupied bandwidth plot - Plot should be presented for each type of
modulation
20Basic Test Parameters
- Antenna Terminal Spurious Emissions 2.1051
- (Also known as Antenna Conducted Emissions)
- View levels of conducted harmonics applied to the
antenna. - An extension of the occupied bandwidth test. Show
spurious emissions to 10th harmonic. - Unless specified elsewhere, RBW should be equal
or greater than Tx emission bandwidth
0
21Basic Test Parameters
- Field Strength of Spurious Emissions 2.1053
- Test 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. - For Licensed equipment, the substitution method
described in TIA/EIA 603 is the required test
procedure. - For Part 15 emissions testing, direct measurement
of field strength is accepted. Device must be
tested with its antenna in place.
22Basic Test Parameters
- Frequency Stability 2.1055
- Done over temperature -30 C to 50 C and
operating voltage /- 15 specifications. - Battery operated devices should also include
B.E.P Battery End Point - Usually defined in ppm but other units such as
Hz, are accepted as defined in specific rule
section. - In most cases, frequency stability is not
required for Part 15
23Certification 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
24Certification Checklist
- Associated Application (Composite Request)
- Confidentiality Request (See separate details for
STC) - Details to be included with confidentiality.
- Block Diagram
- Schematics
- Operational Description
- Parts/Tune Up
- Statement / letter supplied for special
requirements or interagency coordination (if
required).
25Licensed 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
26Unlicensed Part 15 Transmitter Approvals
27Part 15 Rule Organization
- All general rules including measurement
procedures, label requirements, etc. are located
in 15.xx (Subpart A) - All Unintentional Radiators are located in Part
15.1xx of the Rules (Subpart B) - All Intentional Radiators are located in the
15.2xx sections of the Rules (Subpart C), 15D
(unlicensed PCS), 15E (UNII) and 15F (UWB)
28Essential 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
2915 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.
3015.203 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.
3115.204 Power Amp Restrictions
- Officially referred to as a Transmission System
- For spread spectrum transmitters usually includes
the bi-directional amplifier, DC injector, and
spread spectrum transceiver under one FCC ID - Amplifiers 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. - Only approved antennas may be sold with the
product. New antenna can be added under the Class
II PC process.
3215.205 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
33AC 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.
34Radiated 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
35Part 15 C Intentional Radiators
- 15.215 Additional Provisions to the General
Radiated Emission Limitations - Prolog 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
36Part 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.
37Part 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
38Part 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.
39Part 15E - UNIIUnlicensed 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
40Part 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)
41Spread Spectrum DevicesDTS/DSSS and FHSS(WiFi
and Bluetooth)
42Spread 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
43Spread Spectrum Frequencies
- Operate in the Industrial, Scientific, and
Medical bands on a secondary basis. - ISM bands are global and not restricted by ITU
regions - No protection from interference
- 902 - 928 MHz
- 2400 - 2483.5 MHz
- 5725 - 5850 MHz
44WiFi 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)
45FCC 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)
46Additional FCC Requirements
- For systems operating strictly as a Point to
Point systems - in the 2400 - 2483.5 MHz band, the power
reduction requirement is 1 dB for every 3 dB the
antenna exceeds 6 dBi - in the 5725 - 5850 MHz band may employ antennas
with directional gain greater than 6 dBi without
reduction in transmitter output power.
47Additional Requirements
- Must Operate on Non-Interference Basis (cannot
interfere with others) - Must accept that interference may affect
operation no legal recourse - Out 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)
48Spread Spectrum Testing
- Radio testing typically performed in several
parts - Lab bench testing for all conducted tests
- Listed open field test site or Semi-Anechoic
Chamber required for all radiated tests.
49Spread Spectrum Test Software Requirements
- Must be able to turn on/off transmitter, select
antenna ports, and go to receive-only mode. - Must be able to select low , mid, and high
channels. - Must 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. - Must be able to check across all data rates and
modulations. - For Bluetooth, must be able to set to DH1, DH2,
DH3
50MIMO (802.11n) Considerations
- 802.11n is not a huge compliance issue.
- Be sure to measure RF Pout across each chain or
output port - Pout on Grant will be sum of all powers.
- SAR measurements are still under development by
the Commission. Some guidance is available
51Family Antenna Approvals
- Allows the use similar antennas without
re-testing or filing a Class II Change. - Example 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 - If new antenna of greater gain or different type,
then Class II PC must be filed.
52Modular Approval - DA00-1407
- Must have its own FCC ID number on the module
itself. - An ID inside manual is never sufficient.
- An additional label is required on the outside of
the final host device with wording such as - Contains Inside FCC ID XXXxxx
- Must meet the Requirements of OET 65 for RF Safety
53Full 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 - RF shielding.
- Buffered data input/output ports
- Power supply regulation
- Permanent antenna or unique connector
- Testes in stand alone condition
- Labeled with own ID number
- Instructions to operator / OEM integrator
- Must meet RF Exposure requirements.
54Limited 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.
5515.203 Unique Connector Requirement
- Standard Connectors now include
- SMA, TNC, BNC are not allowed
- MMCX, MCX and reverse SMA,TNC are possible
candidates for in this list - Integral Antenna requirements which used to be
part of 15.407 have been eliminated
5615.204 Power Amplifier Restrictions
- Must be seen as a complete end-to-end
transmission system. - Must include seperately approved transmitter and
antenna, in addition to amplifier. - Amplifiers designed for use with Spread Spectrum
Systems must be approved as part of the system
and marketed as part of a complete package. - Additional clarification to 15.204 requirements
exist in FCC Knowledgebase.
57Spread 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
- OET 65 Supplement C
- TCB July 17, 2002 Exclusion list
58General 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.
59Spread Spectrum RF Exposure Requirements
- Fixed and Mobile Devices must meet OET-65 MPE RF
Safety Requirements (1 mW/cm2 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. - Does not apply to 15.407 UNII 802.11a. All RF
category Portable 802.11a devices must undergo
SAR evaluation regardless of RF Pout
60Spread Spectrum Test System Requirements
- All reading below 1 GHz in Quasi-Peak.
- All readings in both Peak and Average above 1
GHz. - Plots of Band Edge Measurements or Marker Delta
method
61Spread Spectrum Testing
- Transmit Power Peak Measurement - Antenna
conducted measurement - Use power meter with peak head detector
- Note 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.
62Spread 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
- RBW 1 MHz
- VBW gt RBW
63Spread Spectrum Testing
- Band Edge (Radiated) Low and Highest Frequency of
operation - Peak Readings
- RBW 1 MHz VBW gt RBW
- Average Readings
- RBW 1 MHz VBW 10Hz
64Spread Spectrum Testing
- Harmonics (Radiated)
- Frequencies Low, Middle, Highest channels
- Spectrum Analyzer settings
- Peak mode RBW 1 MHz VBW gt RBW
- Average 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
65Spread Spectrum
- Class II changes cover
- Addition of second antenna
- Modification of RF Exposure report
- Moving from one RF category to another is
discouraged - Limited test suites can be used.
- i.e. PCMCIA card with new layout would require
new SAR test plus radiated emissions only. No
bench tests required.
66Spread 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)
6715.247 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.
68Transmitter 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 gt 6 dB of
EUT emission bandwidth VBW gt RBW
69Band Edge Testing below 2400 MHz
- Test on Channel 1
- For Frequencies between 2390 - 2400 MHz signals
must be 20 dBc down from fundamental. - For 2390 MHz to 2300 - signals must comply with
15.209 levels (Restricted Bands of 15.205) - Must test in all data rates.
70Band Edge Testing above 2483.5 MHz
- Upper restricted band begins at 2483.5 MHz band
edge - all signals must be compliant to 15.209
limits - Difficulties in compliance when 802.11b/g set to
channel 11. This consistently is the hardest
test. - Some equipment programmed to special power limits
just to comply with restricted band. - Must test in all data rates
71Harmonics \ Spurious \ Restricted Bands Testing
- Required for Each transmitter and Antenna
Combination. - Lowest, Middle, and Highest Frequency checked
- Worst Case RF Pout/data rate checked
- Up to 10th Harmonic of Fundamental
- Requires Pre Amp and High Pass Filter
- Testing Distance 3 meters
72FCC Submittal Information
- Test Data
- Max Output Power (at Antenna port and EIRP)
- Quasi-Peak lt 1 GHz
- Both Peak and Average gt 1 GHz
- Plots of Band Edge Measurements or Marker Delta
method
73UNII Devices (802.11a)
74UNII Devices Part 15 Subpart E
- Unlicensed National Information Infrastructure
- Rules adopted in 1997
- These devices are part of the TCB Scope
- Frequencies of Operation
- 5150 - 5250 MHz (Indoor Use Only)
- 5250 - 5350 MHz (DFS/TPC Required)
- 5470 - 5725 MHz (DFS/TPC Required)
- 5725 - 5825 MHz (Shared with 15.247)
75 UNII Devices Part 15 Subpart E
- Transmitter Power Output
- 5150-5250 MHz Band 50 mW
- 5250-5350 MHz Band 250 mW
- 5470-5725 MHz Band 250 mW
- 5725-5825 MHz Band 1 Watt
- All RF category Portable UNII devices must have
SAR testing
76UNII 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 gt 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.
78Contact Information
- William H. Graff
- President and Director of Engineering
- AmericanTCB, Inc.
- 6731 Whittier Ave.
- McLean, VA 22101
- mailto whgraff_at_ATCB.com
- Corporate Phone (703)847-4700
- Corporate FAX (703)847-6888
- Direct Mobile 886 920399260
- SKYPE whgraff