Modular Approval Letter

FCC ID: N6SLFTRIND

Cover Letter(s)

Download: PDF
FCCID_1294868

Gilbarco Inc. Veeder-Root Company 7300 West Friendly Avenue PO Box 22087 Greensboro, NC 27420-2087 United States Phone: 336-547-5373 Fax: 336-292-8871 Email: bob.sykes@gilbarco.com www.gilbarco.com www.veeder.com Request for Modular Approval Date May 4, 2010 Federal Communications Commission Office of Engineering and Technology Equipment Authorization Division 7345 Oakland Mills Rd. Columbia Maryland 21046 RE: Certification Application FCC ID N6SLFTRIND To Whom It May Concern: In reference to FCC ID N6SLFTRIND, Gilbarco is requesting Modular Approval. The numbered requirements for Modular Approval are addressed below 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. The Light/MicroReader/Antenna assembly, (p/n M06143) includes a formed sheet metal shield, (p/n M06567), which was designed to provide mechanical and electrical protection for the assembly when installed. 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. The modular transmitter has two serial data lines to the M06143 Light/MicroReader/Antenna assembly. These lines pass transponder serial numbers and on/off commands for the recognition light. There are no commands from the host device that can change performance and RFID functionality of the Texas Instruments MicroReader on the M06143 assembly. One TTL line connects the module PCA to the fuel dispenser. It passes transponder serial number and authentication code to the dispenser electronics for communication to the point-of-sale (POS) system for credit verification. Once the credit is verified, the POS system instructs the transmitter module to keep the recognition light on or to shut it off.

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. The M06143 assembly includes a regulated switching power supply as part of the M06100 PCA. This power supply down converts the +24VDC supplied by the dispenser electronics to the +5VDC required by all components of the modular transmitter system. (The +24VDC from the dispenser is connected to the M06143 assembly where the regulation occurs). The regulated +5VDC is then available to feed the MicroReader and associated circuitry of the intentional radiator on the M06100 PCA. 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. This device employs a unique coupler configuration that depends on the mechanical fastener hardware to also make the electrical connection between the Antenna PCA, p/n M06074 and the circuitry of the intentional radiator electronic on the Light/MicroReader PCA M06100. This physical and electrical connection is permanent; the system is rendered inoperable if any modification of the physical connection is attempted. 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)). As the photographs and report indicates, the device was tested in a stand-alone configuration and not inside another device. It does not contain any ferrites that will not be marketed with the module. The device was tested with cables of a length typical of actual use that are greater than 10 centimeters long. The support equipment connected to the module via RS-232 com port for testing purposes was an unmodified Dell laptop PC. 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. The modular transmitter will be labeled with its own FCC ID number. It will be permanently affixed to the on the LFTRIND Assembly, p/n M06567. This label is not visible when it is installed inside another device, therefore an exterior label is provided with the required text. A separate file in this submission shows labels (with verbiage) as well as their locations on the product.

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. Intentional radiator N6SLFTRIND meets the requirements of Section 15.209. No special instructions are required to insure this intentional radiator continues to comply with the FCC rules other than the statement that modifications may not be made to this device “without the written consent of Gilbarco Inc. Unauthorized modifications may void the authority granted under Federal Communications Commission Rules permitting the operation of this device”. This statement is located in the installation manual, which has been sent as part of this grant submittal. 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. The modular transmitter operates at 134.2 kHz with less than 0.5 Watt ERP and is, therefore, excluded from Section 1.1307(b) of the FCC rules and the RF exposure requirements (300 kHz – 100 GHz, per FCC OET Bulletin 65). Sincerely, Bob Sykes EMC Engineer Gilbarco Inc.


Document Created: 2010-05-04 14:58:24
Document Modified: 2010-05-04 14:58:24
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