Modular Approval Letter

FCC ID: PD99260D2L

Cover Letter(s)

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FCCID_4474381

Request for Modular/Limited Modular Approval Date: September 10, 2019 X - Modular Approval Subject: Manufacturer’s Declaration for ☐ ☐ - Split Modular Approval ☐ - Limited Split Modular Approval - Limited Modular Approval Confidentiality Request for: ______PD99260D2L_____ 8 Basic Requirements – FCC Part 15.212(a)(1) For Items Marked “NO(*)”, the Limited Module Description Must be Filled Out on the Following Pages Modular Approval Requirement Requirement Met 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 FCC 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 ☒ - YES ☐ - NO(*) installed. Such coupling may result in non-compliant operation. The physical crystal and tuning capacitors may be located external to the shielded radio elements. 15.212(a)(1)(i) Details: – The module contains a metal shield which covers all RF components and circuitry. The shield is located on the top of the board next to antenna connector. See photo provided with this filing. 2. The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to ensure that the module will comply with FCC requirements under conditions of excessive data rates or ☒ - YES ☐ - NO(*) over-modulation. 15.212(a)(1)(ii) Details: – Data to the modulation circuit is buffered as described in the operational description provided with the application> 3. The modular transmitter must have its own power supply regulation on the module. This is intended to ensure that the module will comply with FCC requirements regardless of the design of the power ☒ - YES ☐ - NO(*) supplying circuitry in the device into which the module is installed. 15.212(a)(1)(iii) Details: – The module contains its own power supply regulation. Please refer to operational description filed with this application 4. The modular transmitter must comply with the antenna and transmission system requirements of §§ 15.203, 15.204(b), 15.204(c), 15.212(a), and 2.929(b). The antenna must either be permanently attached or employ a ‘‘unique’’ antenna coupler (at all connections between the module and the ☒ - YES ☐ - NO(*) antenna, including the cable). The ‘‘professional installation’’ provision of § 15.203 is not applicable to modules but can apply to limited modular approvals under paragraph 15.212(b). 15.212(a)(1)(iv) Details: – The module connects to its antenna using an UFL connector which is considered a non-standard connector. The antenna and connector specification are provided with this filing. 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 ☐ - YES ☒ - NO(*) 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)). 15.212(a)(1)(v) Details: – The module was tested in OEM host PC and is limited to installation in the host described in this filing. 053019-02a

Modular Approval Requirement Requirement Met 6. The modular transmitter must be labeled with its own FCC ID number, or use an electron display (see KDB Publication 784748). If using a permanently affixed label with its own FCC ID number, 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 ☒ - YES ☐ - NO(*) equipment authorization. If the modular transmitter uses an electronic display of the FCC identification number, the information must be readily accessible and visible on the modular transmitter or on the device in which it is installed. If the module is installed inside another device, then the outside of the device into which the module is installed must display a label referring to the enclosed module. This exterior label can use wording such as the following: “Contains FCC certified transmitter module(s).” Any similar wording that expresses the same meaning may be used. The user manual must include instructions on how to access the electronic display. A copy of these instructions must be included in the application for equipment authorization. 15.212(a)(1)(vi) Details: – There is a label on the module as shown in the labeling exhibit filed with this application. Host specific labeling instructions are shown in the installation manual .filed with this application. 7. The modular transmitter must comply with all specific rule or operating requirements applicable to the transmitter, including all the conditions provided in the integration instructions by the grantee. 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 ☒ - YES ☐ - NO(*) 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. 15.212(a)(1)(vii) Details: – The module complies with FCC Part 15C requirements. Instructions to the OEM installer are provided in the installation manual filed with this application. 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 ☒ - YES ☐ - NO(*) 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. 15.212(a)(1)(viii) Details: – The module meets mobile/portable conditions levels as shown in the RF exposure test report filed with this application. 053019-02a

Limited Module Description – When Applicable * If a module does NOT meet one or more of the above 8 requirements, the applicant may request Limited Modular Approval (LMA). This Limited Modular Approval (LMA) is applied with the understanding that the applicant will demonstrate and will retain control over the final installation of the device, such that compliance of the end product is always assured. The operating condition(s) for the LMA; the module is only approved for use when installed in devices produced by grantee. A description regarding how control of the end product, into which the module will be installed, will be maintained by the applicant/manufacturer, such that full compliance of the end product is always ensured should be provided here. Details: The module was tested in the OEM host PC and is limited to installation in the PC described in this application. Software Considerations – KDB 594280 / KDB 442812 (One of the following 2 items must be applied) Requirement Requirement Met 1. For non-Software Defined Radio transmitter modules where software is used to ensure compliance of the device, technical description must be provided about how such ☒ - Provided in Separate ☐ - N/A control is implemented to ensure prevention of third-party modification; see KDB Cover Letter Publication 594280. Details: The firmware of the device cannot be modified or adjusted by the end user as described in a separate cover letter filed with this application. 2. For Software Defined Radio (SDR) devices, transmitter module applications must ☐ - Provided in Separate provide a software security description; see KDB Publication 442812. ☒ - N/A Cover Letter Details: <example –N/A> Split Modular Requirements Requirement Provided in Manual 1. For split modular transmitters, specific descriptions for secure communications between front-end and control sections, including authentication and restrictions on ☐ - Provided in Separate ☒ - N/A third-party modifications; also, instructions to third-party integrators on how control is Cover Letter maintained. Details: <example – N/A > 053019-02a

OEM Integration Manual Guidance – KDB 996369 D03 Section 2 Clear and Specific Instructions Describing the Conditions, Limitations, and Procedures for third-parties to use and/or integrate the module into a host device. Requirement ☒ - No, If No, and LMA applies, the applicant can optionally choose to not make the following detailed info public. However there still needs Is this module intended for to be basic integration instructions for a users manual and the sale to third parties? ☐ - YES information below must still be included in the operational description. If the applicant wishes to keep this info confidential, this will require a separate statement cover letter explaining the module is not for sale to third parties and that integration instructions are internal confidential documents. Items required to be in the manual – See KDB 996369 D03, Section 2 As of May 1, 2019, the FCC requires ALL the following information to be in the installation manual. Modular transmitter applicants should include information in their instructions for all these items indicating clearly when they are not applicable. For example information on trace antenna design could indicate “Not Applicable”. Also if a module is limited to only a grantees own products and not intended for sale to third parties, the user instructions may not need to be detailed and the following items can be placed in the operational description, but this should include a cover letter as cited above. 1. List of applicable FCC rules. KDB 996369 D03, Section 2.2 a. Only list rules related to the transmitter. 2. Summarize the specific operational use conditions. KDB 996369 D03, Section 2.3 a. Conditions such as limits on antennas, cable loss, reduction of power for point to point systems, professional installation info 3. Limited Module Procedures. KDB 996369 D03, Section 2.4 a. Describe alternative means that the grantee uses to verify the host meets the necessary limiting conditions ☐ - All Items shown to b. When RF exposure evaluation is necessary, state how control will be maintained such the left are provided in that compliance is ensured, such as Class II for new hosts, etc. the Modular Integration 4. Trace antenna designs. KDB 996369 D03, Section 2.5 Guide (or UM) for Full a. Layout of trace design, parts list, antenna, connectors, isolation requirements, tests for Modular Approval (MA) design verification, and production test procedures for ensuring compliance. If or LMA. confidential, the method used to keep confidential must be identified and information provided in the operational description. 5. RF exposure considerations. KDB 996369 D03, Section 2.6 ☒ - An LMA applies a. Clearly and explicitly state conditions that allow host manufacturers to use the module. and is approved ONLY Two types of instructions are necessary: first to the host manufacturer to define for use by the grantee in conditions (mobile, portable – xx cm from body) and second additional text needed to be their own products, and provided to the end user in the host product manuals. not intended for sale to 6. Antennas. KDB 996369 D03, Section 2.7 3rd parties as provided in a. List of antennas included in the application and all applicable professional installer a separate cover letter. instructions when applicable. The antenna list shall also identify the antenna types Therefore the (monopole, PIFA, dipole, etc – note that “omni-directional” is not considered a type) information shown to the 7. Label and compliance information. KDB 996369 D03, Section 2.8 left is found in the a. Advice to host integrators that they need to provide a physical or e-label stating theory of operation. “Contains FCC ID: “ with their finished product 8. Information on test modes and additional testing requirements. KDB 996369 D03, Section 2.9 a. Test modes that should be taken into consideration by host integrators including clarifications necessary for stand-alone and simultaneous configurations. b. Provide information on how to configure test modes for evaluation 9. Additional testing, Part 15 Subpart B disclaimer. KDB 996369 D03, Section 2.10 Sincerely, By: __________________________ __Steven C Hackett______________________ Sr. Regulatory Engineer/Agent for HP (Signature/Title1) (Print name) 053019-02a



Document Created: 2019-10-10 09:48:54
Document Modified: 2019-10-10 09:48:54
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