RT and Response

FCC ID: RI7WE865D

Cover Letter(s)

Download: PDF
FCCID_1022528

                                 Request for Additional Information for EMC Certification


Company: Telit Communications (AT4)                         Composite Device:                         Yes:           No:
   MT#: 81201                                               FCC Direct Filing:                        Yes:           No:
                                                            Permit But Ask:                           Yes:           No:
  FCC ID: RI7WE865D                                         FCC Rule Part:                            15.247
    UPN: 5131A-WE865D                                       RSS Standard:                             RSS-210
    FRN:                                                    Class II PC/Reassessment:                 Yes:           No:
                                                                                                            October 15, 2008

Dear Sara,

Thank you for your application. In order for us to process your approval, the following must be
addressed. Please provide a response in a timely manner to avoid delays or dismissals.


Technical Review:

    ¾ The Output power state that it is an average value when peak is required for DTS
      devices operating under this rule part.

    ¾ The conducted band edge plots submitted are required to meet the 20dBc requirement in
      a 100KHz RBW.

    ¾ The radiated plots submitted are not sufficient to demonstrate compliance with the
      15.205 restricted bands immediately removed from 2.4GHz ISM band.

    ¾ The applicant name, Telit Communications S.P.A, has no corresponding FRN listed with
      the FCC. Please confirm.


If you have any questions or concerns, please contact us.

Thank you!



Jennifer Sanchez
TCB Administrator
MET Laboratories, Inc.
tcbinfo@metlabs.com
www.metlabs.com


Admin Review By: Jennifer Sanchez
Technical Review By: Shawn McMillen


Please note that partial responses increase processing time and should not be submitted. The items indicated above must be
provided before processing can continue on the above referenced application. Failure to provide the requested information in a
timely manner may result in application dismissal.



  TCBJ FORM-13 EMC
                                                                                                                      4/23/2008
  Issued by: TCB Administrator


 Jenn Warnell

  From:           Sara González López [sgonzalez@at4wireless.com]
  Sent:           Friday, October 17, 2008 6:30 AM
  To:             Jennifer Sanchez
  Cc:             Jenn Warnell
  Subject:        RE: 81201 AT4 Wireless - Request for Technical Information
  Importance: High
  Attachments: RT 15 Oct 2008.pdf; Freq Hopper Guidelines.PDF; Direct Sequence Measurment Notes.pdf;
               RE: 81201 AT4 Wireless - Request for Technical Information

Hello,

1. Regarding the output power, in point 15.247 (b) (3) it is specified:

“For systems using digital modulation in the 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz bands: 1
Watt. As an alternative to a peak power measurement, compliance with the one Watt limit can be based on
a measurement of the maximum conducted output power. Maximum Conducted Output Power is defined
as the total transmit power delivered to all antennas and antenna elements averaged across all symbols in
the signaling alphabet when the transmitter is operating at its maximum power control level. Power must be
summed across all antennas and antenna elements. The average must not include any time intervals during which
the transmitter is off or is transmitting at a reduced power level. If multiple modes of operation are possible (e.g.,
alternative modulation methods), the maximum conducted output power is the highest total transmit power
occurring in any mode”.

In test report 28057RET.101 page 15 it is clearly indicated that this permitted alternative method to a peak power
measurement was used, so we believed the measurement is correct.


2. Regarding the conducted band edge plots, it is specified in point 15.247 (d):
“If the transmitter complies with the conducted power limits based on the use of RMS averaging over a time
interval, as permitted under paragraph (b)(3) of this section, the attenuation required under this paragraph shall be
30 dB instead of 20 dB”.

In test report 28057RET.101 pages 22, 23 and 24 it is shown in the plots that we applied the limit of 30 dB. This is
because the output conducted power was measured using RMS averaging over a time interval, as indicated
previously.

The reason of use of a RBW different from 100 kHz is that as there is no measurement guideline for conducted
band-edge compliance neither in point 15.247 nor in document “ Appendix C Guidance on Measurement for
Direct Sequence Spread Spectrum Systems” (see attached) we followed the document DA 00-705 released
March 30, 2000 “ Filing and Measurement Guidelines for Frequency Hopping Spread Spectrum Sytems” (see
attached) as we always did in previous accepted reports of part 15.247 which we submitted in the past.
In such document it is indicated in “Section 15.247 (c) . Band-edge compliance of RF Conducted Emissions” the
use of a RBW ≥ 1% of the span.


3. Regarding compliance of radiated emissions in the 15.205 restricted bands, in test report 28057RET.101 pages
30, 31 and 43 it is clearly indicated that no spurious signals were found in such restricted bands, which were
investigated searching for spurious signals. No plots of these bands were added besides the wide range plots we
always included in previous accepted reports of part 15.247 which we submitted in the past.
If you consider it is necessary to include such plots please confirm and we will include in future 15.247 test
reports.




10/17/2008


4. With regards to the FRN, please see attached e-mail already sent to you.

Please, tell me if this is enough or you require some more explanation.

Thanks a lot for your prompt reply.

Best regards,
Sara González
Worldwide Compliance Services
Tel.:     +34 952 619 406       - E-mail: sgonzalez@at4wireless.com
Fax:       +34 952 619 113
Web site: www.at4wireless.com - Skype: sara_gonzalez--malaga




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De: Jennifer Sanchez [mailto:jsanchez@metlabs.com]
Enviado el: jueves, 16 de octubre de 2008 0:19
Para: Sara González López
CC: Jenn Warnell; Jennifer Sanchez
Asunto: 81201 AT4 Wireless - Request for Technical Information
Importancia: Alta

Hi Sara,

During the technical review for Telit Communications, FCC ID: RI7WE865D/ IC: 5131A-WE865D, our reviewer
came across a few concerns, please see attached correspondence.

If you have any questions or concerns, please let me know.




10/17/2008


                                 Request for Additional Information for EMC Certification


Company: Telit Communications (AT4)                         Composite Device:                         Yes:           No:
   MT#: 81201                                               FCC Direct Filing:                        Yes:           No:
                                                            Permit But Ask:                           Yes:           No:
  FCC ID: RI7WE865D                                         FCC Rule Part:                            15.247
    UPN: 5131A-WE865D                                       RSS Standard:                             RSS-210
    FRN:                                                    Class II PC/Reassessment:                 Yes:           No:

Dear Sara,

Thank you for your application. In order for us to process your approval, the following must be
addressed. Please provide a response in a timely manner to avoid delays or dismissals.


Technical Review:

    ¾ In reference to the RF output power please follow the FCC DTS measurement guidance
      which is attached.

    ¾ In addition please follow the guidance provided. All conducted spurious emissions
      removed from the 2.4GHz band are required to be measured in a 100KHz resolution.

    ¾ Plots showing compliance with the restricted bands above and below the ISM band need
      to be provided to demonstrate compliance at the band edges. It is unclear with the plots
      submitted that compliance is met from 2310-2390MHz and 2483.5-2500MHz.


If you have any questions or concerns, please contact us.

Thank you!




Jennifer Warnell
TCB Administrator
MET Laboratories, Inc.
tcbinfo@metlabs.com
www.metlabs.com


Admin Review By: Jennifer Sanchez
Technical Review By: Shawn McMillen


Please note that partial responses increase processing time and should not be submitted. The items indicated above must be
provided before processing can continue on the above referenced application. Failure to provide the requested information in a
timely manner may result in application dismissal.




  TCBJ FORM-13 EMC
                                                                                                                      4/23/2008
  Issued by: TCB Administrator


 Jenn Warnell

  From:            Sara González López [sgonzalez@at4wireless.com]
  Sent:            Monday, October 27, 2008 4:14 PM
  To:              Jennifer Sanchez
  Cc:              Jenn Warnell
  Subject:         Addendum test report for FCC and IC grants for WE865-DUAL
  Importance: High
  Attachments: 28057RET201-addendumFCC.pdf; RSS-210 cross reference_WE865-DUAL.pdf; IC Annex B -
               MPE calculations for the equipment WE865-DUAL.pdf; TCBJ_FORM-4_FCC_4-25-08[1]
               __WE865-DUAL.pdf; 28057RET101.pdf; Appendix B of the IC form__WE865-DUAL.jpg

Good evening Jennifer,

you can find attached the new addendum FCC test report for WE865-DUAL.
I have also attached the test report 28057RET101.pdf

Also, you can find attached the updated version of the following documents, which are the ones affected by the
results of this new test report. The rest of the application documents for FCC and IC are the ones you already
have.




FCC:
new versions of:
                   RF Exposure information
                   TCBJ_FORM FCC


IC:
new versions of:
                   RSS-210 Cross Reference
                   Appendix B of the IC form
                   IC Annex B - MPE calculations


Please, we kindly ask you to do all your best to get FCC and IC grants within 24 hours due to these special
circumstances.

Thank you very much in advance for your great efforts.

Best regards,


Sara González
Worldwide Compliance Services
Tel.:     +34 952 619 406       - E-mail: sgonzalez@at4wireless.com
Fax:       +34 952 619 113
Web site: www.at4wireless.com - Skype: sara_gonzalez--malaga




10/28/2008


                                 Request for Additional Information for EMC Certification


Company: Telit Communications (AT4)                         Composite Device:                         Yes:           No:
   MT#: 81201                                               FCC Direct Filing:                        Yes:           No:
                                                            Permit But Ask:                           Yes:           No:
  FCC ID: RI7WE865D                                         FCC Rule Part:                            15.247
    UPN: 5131A-WE865D                                       RSS Standard:                             RSS-210
    FRN: 0009643503                                         Class II PC/Reassessment:                 Yes:           No:
                                                                                                            October 28, 2008

Dear Sara,

Thank you for your application. In order for us to process your approval, the following must be
addressed. Please provide a response in a timely manner to avoid delays or dismissals.


Technical Review:

    ¾ MPE calculations are based on the wrong max RF conducted power.
    ¾ The addendum MPE calculation is an EIRP calculation, not RF exposure calculation.
    ¾ There are no Line Conducted test setup photos. Please include the test setup photos.
    ¾ There is no 15.109 test data, procedures and test setup photos. Please include all the
         relevant 15B data for this filing.



If you have any questions or concerns, please contact us.

Thank you!



Jennifer Sanchez
TCB Administrator
MET Laboratories, Inc.
tcbinfo@metlabs.com
www.metlabs.com


Admin Review By: Jennifer Sanchez
Technical Review By: Shawn McMillen


Please note that partial responses increase processing time and should not be submitted. The items indicated above must be
provided before processing can continue on the above referenced application. Failure to provide the requested information in a
timely manner may result in application dismissal.




  TCBJ FORM-13 EMC
                                                                                                                      4/23/2008
  Issued by: TCB Administrator


    Jennifer Sanchez

    From:             Jennifer Sanchez
    Sent:             Tuesday, October 28, 2008 9:47 AM
    To:               Shawn McMillen
    Cc:               Angela Kekovski; Jenn Warnell; Jennifer Sanchez
    Subject:          RE: Addendum test report for FCC and IC grants for WE865-DUAL
    Importance: High
    Attachments: IC Annex B - MPE calculations for the equipment WE865-DUAL.pdf; CERTIF.pdf; 28057aia.002.pdf;
                 28057aib.002.pdf; 28057REM.002.pdf; RF Exposure information_WE865-DUAL_Rev1.pdf

Hi Shawn,

Please see the revised MPE and 15B report with photos.

Thanks!
Mrs. J. Sanchez
TCB Administrator
MET Laboratories (Santa Clara, CA)
408-207-4785 Direct
408-829-1603 Cell
jsanchez@metlabs.com




From: Shawn McMillen
Sent: Tuesday, October 28, 2008 8:43 AM
To: Jennifer Sanchez
Cc: Angela Kekovski; Jenn Warnell
Subject: RE: Addendum test report for FCC and IC grants for WE865-DUAL

RT 10-28-2008

    1. The product is listed as a module however there is no modular approval check sheet/cover letter. If this is an application for modular
          approval please include module check sheet/cover letter.
    2.    MPE calculations are based on the wrong max RF conducted power
    3.    The addendum MPE calculation is an EIRP calculation, not RF exposure calculation.
    4.    There are no Line Conducted test setup photos. Please include the test setup photos.
    5.    There is no 15.109 test data, procedures and test setup photos. Please include all the relevant 15B data for this filing.
.


Regards,

Shawn McMillen

Wireless Manager
MET Laboratories, Inc.
410-949-1914 (Direct)
410-310-9678 (Cell)
www.metlabs.com



10/28/2008



Document Created: 2008-10-28 15:25:00
Document Modified: 2008-10-28 15:25:00

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