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June 26, 2000 - Issue 220 Final Edition

FCC Outlines Requirements and Policies for Unlicensed Transmitter Modules (June 26)
The FCC released a Public Notice, Part 15 Unlicensed Modular Transmitter Approval (DA 00-1407) that sets forth the requirements for approval of modular transmitter equipment designs. The FCC noted that these requirements are in addition to those normally required for an application for an intentional radiator.

The Public Notice listed specific requirements that must be addressed in the application for modular transmitter approval:
  1. "The modular transmitter must have its own RF shielding. This is intended to ensure that the module does not have to rely upon the shielding provided by the device into which it is installed in order for all modular transmitter emissions to comply with Part 15 limits. It is also intended to prevent coupling between the RF circuitry of the module and any wires or circuits in the device into which the module is installed. Such coupling may result in non-compliant operation.
  2. "The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to ensure that the module will comply with Part 15 requirements under conditions of excessive data rates or over-modulation.
  3. "The modular transmitter must have its own power supply regulation. This is intended to ensure that the module will comply with Part 15 requirements regardless of the design of the power supplying circuitry in the device into which the module is installed.
  4. "The modular transmitter must comply with the antenna requirements of Section 15.203 and 15.204(c). The antenna must either be permanently attached or employ a "unique" antenna coupler (at all connections between the module and the antenna, including the cable). Any antenna used with the module must be approved with the module, either at the time of initial authorization or through a Class II permissive change. The "professional installation" provision of Section 15.203 may not be applied to modules.
  5. "The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be inside another device during testing. This is intended to demonstrate that the module is capable of complying with Part 15 emission limits regardless of the device into which it is eventually installed. Unless the transmitter module will be battery powered, it must comply with the AC line conducted requirements found in Section 15.207. AC or DC power lines and data input/output lines connected to the module must not contain ferrites, unless they will be marketed with the module (see Section 15.27(a)). The length of these lines shall be length typical of actual use or, if that length is unknown, at least 10 centimeters to insure that there is no coupling between the case of the module and supporting equipment. Any accessories, peripherals, or support equipment connected to the module during testing shall be unmodified or commercially available (see Section 15.31(i)).
  6. "The modular transmitter must be labeled with its own FCC ID number, and, if the FCC ID is not visible when the module is installed inside another device, then the outside of the device into which the module is installed must also display a label referring to the enclosed module. This exterior label can use wording such as the following: "Contains Transmitter Module FCC ID: XYZMODEL1" or "Contains FCC ID: XYZMODEL1." Any similar wording that expresses the same meaning may be used. The Grantee may either provide such a label, an example of which must be included in the application for equipment authorization, or, must provide adequate instructions along with the module which explain this requirement. In the latter case, a copy of these instructions must be included in the application for equipment authorization.
  7. "The modular transmitter must comply with any specific rule or operating requirements applicable to the transmitter and the manufacturer must provide adequate instructions along with the module to explain any such requirements. A copy of these instructions must be included in the application for equipment authorization. For example, there are very strict operational and timing requirements that must be met before a transmitter is authorized for operation under Section 15.231. For instance, data transmission is prohibited, except for operation under Section 15.231(e), in which case there are separate field strength level and timing requirements. Compliance with these requirements must be assured."l;
  8. "The modular transmitter must comply with any applicable RF exposure requirements. For example, FCC Rules in Sections 2.1091, 2.1093 and specific Sections of Part 15, including 15.319(i), 15.407(f), 15.253(f) and 15.255(g), require that Unlicensed PCS, UNII and millimeter wave devices perform routine environmental evaluation for RF Exposure to demonstrate compliance. In addition, spread spectrum transmitters operating under Section 15.247 are required to address RF Exposure compliance in accordance with Section 15.247(b)(4). Modular transmitters approved under other Sections of Part 15, when necessary, may also need to address certain RF Exposure concerns, typically by providing specific installation and operating instructions for users, installers and other interested parties to ensure compliance."

In cases where compliance with one or more of these numbered requirements cannot be demonstrated, the FCC may grant a "Limited Modular Approval" (LMA) in "those instances where the Grantee can demonstrate that it will retain control over the final installation of the device, such that compliance of the end product is assured."

Other important information is contained in the Public Notice Part 15 Unlicensed Modular Transmitter Approval (DA 00-1407).

FCC Satellite Applications Accepted for Filing (June 26)
In the Satellite Policy Branch Report SAT-00049, the FCC listed a request by COMSAT to provide domestic land mobile and aeronautical mobile satellite services in the United States, including all fifty states, Puerto Rico and the U.S. Virgin Islands, using Inmarsat-B, -C, -M, mini-M, M4 and aeronautical terminals. Loral SpaceCom filed an application to extend its milestone dates for the Telstar 8 satellite (formerly named Telstar 6) to December 1, 2002 for completion of construction and February 1, 2003 for launch of the satellite. EchoStar DBS Corporation filed a request for Special Temporary Authority to test all 32 channels of its Echostar 6 Direct Broadcast Service satellite at 148 degrees West Longitude upon launch in July 2000 for a period of eight weeks.

Details are available in the FCC International Bureau Satellite Policy Branch Report SAT-00049.

FCC Makes Changes in 18 GHz Allocations and Licensing (June 22)
The FCC has adopted rules "rules that will permit the efficient use of spectrum for existing and future users, and will facilitate the deployment of new services in the 17.7-20.2 GHz band (18 GHz band)." The Report and Order makes several changes to the Table of Frequency Allocations in Section 2.106 of the FCC Rules. Originally the entire 18 GHz band was allocated for shared use by various terrestrial fixed and mobile services, the Fixed Satellite Service (FSS) and the Mobile Satellite Service (MSS). However, the FCC said it concludes "that, in general, separating terrestrial fixed service operations from ubiquitously deployed FSS earth stations in dedicated sub-bands would serve the public interest." The FCC did conclude "that limited frequency sharing between satellite and terrestrial services is feasible and should continue to be permitted where it serves the requirements of these services."

Some of the changes are outlined here. The Report and Order allocated 17.3-17.7 GHz to the Broadcasting-Satellite Service (BSS) for primary BSS uses, effective April 1, 2007, as specified in the ITU Radio Regulations. GSO/FSS was allocated 24.75-25.05 GHz for primary Earth-to-space use only as feeder links for the BSS in the 17.3-17.7 GHz band. The 25.05-25.25 GHz band was allocated for co-primary use between the FSS (Earth-to-space), also limited to BSS feeder links, and the fixed service.

For terrestrial fixed service use, 17.7-18.3 GHz was designated on a primary basis, 18.3-18.58 GHz on a co-primary basis (with GSO/FSS), and 19.3-19.7 GHz on a co-primary basis (MSS/FL). For geostationary orbit (GSO) FSS service, 18.58-18.8 GHz was designated on a primary basis and 18.3-18.58 GHz on a co-primary basis (with terrestrial fixed service). GSO/FSS also has a primary allocation at 19.7-20.2 GHz. For non-geostationary orbit (NGSO) FSS service, 18.8-19.3 GHz was designated on a primary basis. The MSS/FL retained co-primary status with terrestrial fixed service in the 19.3-19.7 GHz. band.

Existing terrestrial fixed service systems currently operating in spectrum being designated for exclusive satellite use will be allowed to continue to operate on a co-primary basis for a period of ten years, "subject to the overriding right of satellite providers to require terrestrial fixed stations to relocate." Procedures for relocation are detailed in the Report and Order.

The FCC authorized a blanket licensing regime for satellite earth stations in the 18.58-18.8 GHz, 18.8-19.3 GHz, 19.7-20.2 GHz, 28.35-28.6 GHz, 28.6-29.1 GHz, and 29.5-30.0 GHz frequency bands. In bands designed as primary to GSO/FSS, the Report and Order adopted "specific technical conditions concerning space station and earth station performance recommended by the Blanket Licensing Industry Working Group to ensure that intra-system interference stays within acceptable limits." The Report and Order also adopted operating parameters and conditions for NGSO/FSS systems.

The Report and Order - Redesignation of the 17.7-19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations in the 17.7-20.2 GHz and 27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite-Service Use, IB Docket 98-172, is available for downloading as text file fcc00212.txt and Microsoft Word file fcc00212.doc. An FCC News Release summarizes the Report and Order. While it can viewed as a text file, nrin0011.txt, the tables will be more legible in the Microsoft Word version, nrin0011.doc.

FCC OET Extends Effective Date of Antenna Connector Requirements (June 22)
As reported in the May 22, 2000 RF Current,the FCC Office of Engineering and Technology (OET) released a Public Notice modifying types of antenna connectors that would satisfy FCC Rules Section 15.203. This section requires transmitters authorized under Part 15 to be designed in such a way as to ensure that no antenna other than that furnished by the responsible party be used with the device.

In the Public Notice, the FCC noted that several antenna connectors that were once considered unique have now become common place and would no longer be allowed under this rule section. Manufacturers commented that this new interpretation "caught them by surprise and would cause financial hardship to redesign and retool production in light of this unanticipated requirement."

In a new Public Notice, OET Extends Effective Date of Antenna Connector Requirement (DA 00-1391), the FCC concluded additional time may be necessary to allow manufacturers to prepare for this change. The effective date of the previous Public Notice, DA 00-1087, was extended until October 1, 2000.

SATELLITE - NASA Ready to Launch "most advanced communications satellite ever designed" (June 21)
NASA is preparing to launch Tracking and Data Relay Satellite-H (TDRS-H) from Cape Canaveral Air Force Station on June 29th. TDRS-H is the first of three of what NASA called "the most advanced communications satellites ever designed." The new TDRS series will replenish the existing on-orbit fleet, which has been in service since 1983. TDRS provides communications links for the Space Shuttle, the International Space Station, the Hubble Space Telescope and other spacecraft and launch vehicles. Anthony Comberiate, TDRS Project Manager at NASA's Goddard Space Flight Center in Greenbelt, MD said, "The average age of the existing fleet is more than 10 years, which is beyond the mission design lifetime. The new series will replenish our existing fleet and allow users to migrate to the new Ka-band."

The capabilities of TDRS-H are impressive. For S-band (2.0-2.3 GHz) single access service, it has two 15-foot diameter steerable antennas for robust communications to satellites with smaller antennas and to receive telemetry and range-safety data from expendable rockets during launch. The same antennas will also be used for Ku-band 13.7-15.0 GHz data transmission with the International Space Station at rates up to 300 Mbps. Ka-band single access service at 22.5-27.5 GHz will allow data rates up to 800 Mbps for communication with the International Space Station and other missions such as future multi-spectral instruments for earth science applications. A phased antenna array will allow multiple access in the 2.0-2.3 GHz band, receiving and relaying data simultaneously from five lower data-rate users and sending commands to a single user.

TDRS-H was built and tested by Hughes Space and Communications. The total cost for the TDRS-H mission is 395 million dollars, which includes the spacecraft, launch vehicle and modifications to the White Sands, NM TDRS operational control center. Information was obtained from NASA Press Release Advanced Communications Satellite Ready to Serve New Millennium Space Projects. . Updated information may be found on the NASA TDRS Project home page .

OTHER Items of Interest

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