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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

 

9 October 2002
SUBJECT: GMRS Radio 2.0-3.0Watts


Hi,
We collective think that is may be possible to get a 2Watt body worn PTT radio to meet
the General Population Exposure limits but it will have to have a plastic belt clip and it
should hold the radio as far away from the body as possible. When SAR testing is done
they place the back of the belt clip against the Phantom. The highest that anyone can
remember passing the General Population requirements for SAR was 2.2Watts, so I do
not think that you will be able to get a 3.0Watt radio to meet the requirements for a body
worn EUT. Maybe for a “Face Held” at 2.5cm away from the body, but you cannot have
a microphone jack on the radio in this case. -More-

...

 

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

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

 

25 September 2003

 

 

SUBJECT: MODIFICATION of PART 2 & 15

 

REFERENCE: NPRM ET Docket No. 03-201 FCC 03-223

 

Hi,

 

It seems that we are sending one of these news bulletins everyday, but we think the information is important and in the case of the proposed changes to Part 2 & 15 I don’t think that we should wait.

 

The focus of this newsletter is NPRM ET Docket 03-201, Modification of Part 2 and 15 of the Commission’s Rules for unlicensed devices and equipment approval.

 

Using the docket number or the FCC 03-223 you can get a copy of from the FCC website if you are lucky, sometimes it comes up when I do the search & sometimes it does not. You can also download if from our website by going to the download/FCC section and finding “FCC-03-223; ET Docket No. 03-201”.

 

Here is a brief summary of items that are in this NPRM;

 

1.      Part 15 – Antennas:

a.     15.247 & 15.251: Consideration of new technologies with regards to spread spectrum antennas.

b.      15.31(h) a possible revision with regards to replacement antennas.

 

2.      Part 15 – Amplifiers: Consideration to lift the prohibition of external amplifiers for some Part 15 devices.

3.      Part 15 – Measurement Procedure for Digital Modulation. This mainly deals with the differences between 15.247 & 15.401 the UNII & THE Power Output measurements.

4.      Part 15 Modular Approval: This portion is about modifying the 8 requirements for modular approval. Also this NPRM is addressing the RF Exposure for Modular Devices.

5.      Part 2 & 15 – Special Temporary Authority: This deals with the importation of un-approved devices, currently the limit is 10 and some manufacturers want to increase that number to 200.

6.      Part 2 – Description of Measurement Facilities: This part is to change the “registration of a test site” in part 2.948 of the rules to a test site that is ACCREDATED TO ISO/IEC Guide 17025. This would significantly increase the cost for the smaller test laboratories and manufacturers that do their own testing.

7.      Part 2: Under the same heading is a requirement that parties making the measurements under the certification or DoC procedure be accredited for performing measurements.

 

If you have any question please let me know.

 

If you want to be removed from this distribution please let me know. 

 

Sid Sanders

 

In Korea Contact:                       In Japan Contact:                         In Hong Kong;

Thru Engineering                 ITM                                          Timco Engineering, Inc.

Mr. K. T. Kang                          Mr. Gene Hani                               Mr. Gilbert Lui

(02)846-5002                             (03) 3485 3713                                 (852)2330-6604

 

 Download as .pdf

 

September 17, 2003

SUBJECT:       Part 22/24 Block-edges, 802.11b/g , HAC for cell phone, Part 15.231 rules & Other Things

 

Hi,

 

Here are some updates following this month conference call with the FCC:

 

  1. FCC Modifies Effective Date for FCC 03-149:

 

“The FCC's Office of Engineering and Technology has corrected the effective date of new rules in its 2001 Biennial Review Item that are designed to ease some of the regulations governing unlicensed devices.  For example, transmitters operating under Section 15.231 will be permitted to send data with a control signal without meeting the timing restrictions and lower field strength limits in paragraph e when the rules take effect.  A second report and order and memorandum opinion and order was released in Engineering and Technology Docket No. 01‑278 in July.  In an erratum issued today, OET changed the effective dates of the new rules from 120 days after "Federal Register" publication to 30 days after publication.

Since the Federal Register is severely backlogged, it is not expected that these rules will be published until the middle to end of October.  This puts the tentative effective date for these rules sometime in November.  Please note when these rules are published because you cannot issued grants under the changed rules before they become effective.”

 

  1. Hearing Aid Compatibility Report & Order

 

“A new Rulemaking that applies to a cell phone regarding Hearing Aid Compatibility has just been adopted.”

 

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-238664A1.pdf

 

  1. Multiple Modulation Capabilities in One Device: Interpretation

 

Question: “If a device has both 802.11b (DSSS) and 802.11g (OFDM) capability, must both modulation modes be tested for EMC compliance?”

 

Answer: “Yes, if a device is capable of operating with two different modulation types, both types need to be tested.”

 

  1. Notice of Proposed Rulemaking - 2003 Part 2, 15 Biennial Review Item to be Released

 

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-238640A1.pdf

 

  1. Amendment to FCC Part 22H / 24E Block Edge Requirements

 

On 09/09/2003 The FCC wrote:

“Based on comments from manufacturers concerning our recent policy relating to block edge measurements and after further review of the updated rules under Parts 22H and 24E, we are amending the requirements for demonstrating block edge compliance.  We will only require a plot showing block edge compliance at the upper and lower band edge frequencies for both Part 22 and 24 transmitters.

 

The new FCC Rule Parts 22.917(c) and 24.238(c) read as follows:

 

(c)  Alternative out of band emission limit.  Licensees in this service may establish an alternative out of band emission limit to be used at specified band edge(s) in specified geographical areas, in lieu of that set forth in this section, pursuant to a private contractual arrangement of all affected licensees and applicants.  In this event, each party to such contract shall maintain a copy of the contract in their station files and disclose it to prospective assignees or transferees and, upon request, to the FCC.

 

Since this section allows alternative block edge limits based on an agreement between licensees sharing a service’s frequency band, we will not require an applicant to submit block edge data inside the service’s band edge frequencies. The minimum requirement needed to show block edge compliance is the upper and lower band edge frequencies only.  Submission of internal block edge data is optional.

 

Each transmitter (PCS or Cellular) will require 2 plots to show block edge compliance... one upper band edge and one lower band edge plot for each modulation type.  The plots should represent compliance with out-of-block emissions as tested using spectrum analyzer settings specified in 22.917(b) and 24.238.

 

Additional tabular data should be provided for out-of-band radiated emissions measurements.”

Download as .pdf

06/17/2003 Wednesday

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

17 June 2003

SUBJECT: CANADIAN CERTIFICATION BODY

Hi,

Canadian CB’s are getting closer, we be assessed later this month for the requirements to be a certifier for Canada.

I thought I would tell you something about this and what you should do. The requirements for us to be able to accept test report applications from you is that you must have a Canadian Registered Test Site

This is a reminder – please address all TCB related email to tei@timcoengr.com only.  Please do so regardless of who sent email to you.  This email will be monitored by the TCB at all times, but may not be monitored by the same person, so it is important to send your TCB correspondence to tei@timcoengr.com only – do not carbon copy the sender!

Please be sure that you are using the latest version of our TCB 731 form.  This can be downloaded from our web site for your use.  Also, please submit the TCB 731 form in its original Word format – it is not necessary to convert the TCB 731 form to PDF.

Effectively immediately, there will be a USD50 SUR-CHARGE  for 3rd party payments. No exceptions. Every time someone other than our customer makes the payments we spend hours in research trying to figure out where the money came from & what invoice it is for.

IF YOU WOULD LIKE TO BE REMOVED FROM THIS MAIL LIST PLEASE HIT REPLY & I WILL REMOVE YOU.

Regards,

Sid Sanders

Download as .pdf

03/29/2003 Tuesday

UNIQUE CONNECTORS

 Hi,

 It is important that you know that the FCC has added the “U.FL” connector to the list of acceptable unique connectors. This was done in a notice to us on 28 April 2003. You can get a copy of the email from http://www.timcoengr.com/Download/download.htm “Email U.FL Connector”.

 Additionally the FCC will now accept measurements of a PCMCIA wireless LAN card that has a conducted power output of 100mWatts or less tested for SAR in only one computer, previously they had been requiring that it be tested in 3 different laptop computers. You can get a copy of the email from http://www.timcoengr.com/Download/download.htm “PCMCIA WIRELESS LAN SAR TEST”.

The assessment to become a Canadian Certifier has been delayed until June, as soon as we know a firm date we will let you know.  

Regards,

Sid Sanders

 

06/26/2002 Wednesday

TIMCO designated a NB for the R&TTE Directive

* SAR: OET announces a transition period for the phantom requirements of OET 65 Supplement C

* Amendment of Part 15 of the Commission's Rules Regarding Spread Spectrum Devices

* Conducted Emissions Limits Below 30 MHz for Equipment Regulated under Parts 15 and 18 of the Commission's Rules
Features
* Brazilian and Mexican approval of wireless devices subject to certification
* CE - Harmonized standards update

* TCB exclusions and procedures list to be published

Click here for details

 

 

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