|
TIMCO
Engineering Inc.
849 NW State Road 45
PO Box 370
Newberry, Florida 32669
888.472.2424 Fax: 352.472.2030 email:
sid@timcoengr.com
13 August 2003
SUBJECT: Replaceable Crystals Part 95 C R/C
Devices & Other Things
Hi,
In the FCC/TCB Council conference of 8/11/2003
Richard Fabina discussed the problem of 95.645, this is the rule that
prohibits “User Replacement Crystals” is a Part 95 R/C device. He
admitted that the FCC had set the precedent of approving this type of
device & that some TCB had also approved these type of devices. However,
he said that it must stop.
We are asking the FCC to allow for a transition
period of at least a month for those people that have product in the
pipeline, but we have not received an answer about that as of this
moment & we thought that it was important enough to get this message out
to everyone.
I am not attaching a copy of the FCC Rule 95.645,
but I am putting on our web site or you can ask me & I will send it to
you.
http://www.timcoengr.com/Download/FCC/downloadFCC.asp
The FCC said that they would not dismiss any
already approved, but that if it was not approved that we should not
approve it.
Permissive change filing requirements for changes to the
ANTENNA for Part 15 devices
The following filing requirements assume that there
are no changes to the device such as hardware or software changes, other
than the antenna which can only be made by the grantee. Depending on
the specific hardware or software change(s), a new filing may be
required.
1) Any
antenna with a higher gain than the antenna(s) with which the device was
originally approved requires a Class II permissive change filing.
2) If
an antenna is of the same type and has a lower gain than the antenna (s)
originally approved and tests show that the emission levels or reported
RF safety levels are not increased, a Class I permissive change is
allowed. If either the emission levels or reported RF safety levels
increase, a Class II permissive change is required.
3) If
an antenna is of the same type, same specifications, and same gain as an
antenna originally approved but is made by a different manufacturer, a
Class I permissive change is permitted.
4) If
an antenna is a different type, has a lower gain than an originally
approved antenna and tests show that the spurious emission levels or
reported RF safety levels are not increased, then a Class I permissive
is permitted. Although a Class II permissive change filing is not
required in this case, it is recommended that a Class II permissive
change be filed in order to keep a complete list of approved antennas in
the filing.
SAR Test Configurations for Unusual Handset Shapes
Question: With regards
to determining reference lines for SAR testing of handsets, what type of
devices do the recommendations for reference lines under "Device
Operating Next to a Person's Ear" on Page 41 of Supplement C apply? How
are reference lines for other devices determined?
Response: Supplement C
Page 41 reference line definition applies only to what is referred to as
"most wireless handsets", meaning conventional styled portable phones --
flat and rectangular or in a typical clam-shell style. For these
conventional shaped phones the alignment point is the intersection of
vertical & horizontal center lines on the phone. The ear piece may be
somewhat off centered but not by a substantial distance.
For phones with
non-conventional shapes, the IEEE SCC-34/SC-2 committee which drafted
P1528 allowed or considered alternative alignment procedures. When
alternative phone alignment is applicable for SAR evaluation, the intent
is to test according to normal use configurations.
Determining normal
usage configurations or positions may require judgmental interpretation.
For this reason, until procedures to determine normal use configurations
are provided, TCBs should query the FCC during their review for a
determination or confirmation of necessary test positions for devices
with unconventional shapes. The TCB should assure that all determined
test positions are evaluated. For a particularly unusual device shape,
the FCC reserves the right to require the filing for Certification to be
submitted to the FCC.
If an antenna is a different type, has a lower gain
than an originally approved antenna and tests show that the spurious
emission levels or reported RF safety levels have increased, a
Class II permissive change is required.
EQUIPMENT CODES ON 731 FORM: It would help
us in our continuing effort to keep our cost down if everyone would put
Equipment Codes on their 731 forms, you can download a copy of the FCC
equipment codes from our web site,
http://www.timcoengr.com/Download/FCC/downloadFCC.asp
IF YOU WOULD LIKE TO BE REMOVED FROM THIS MAIL LIST
PLEASE HIT REPLY & I WILL REMOVE YOU.
Regards,
Sid Sanders
Download as
.pdf |