WAP3052_ACB-FORM-FCC-Modular-Letter 0911

FCC ID: WAP3052

Cover Letter(s)

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FCCID_4442710

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                                          s SemICOnd UCtOr



                                       Request for Modular/Limited Modular Approval

Date: September 10, 2019


Subject: Manufacturer‘s Declaration for               — Modular Approval                    C — Split Modular Approval
                                                   C] — Limited Modular Approval            — Limited Split Modular Approval

Confidentiality Request for:               FCC ID: WAP3052

                                             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
     . The modular transmitter must have its own RF shielding. Thisis intended to ensure that the module
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       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
                                                                                                               X — YEs   C — NOC®)
       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 physical erystal 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>

       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        X — YEs      C — NOC®)
       or 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>

       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        X — YEs      C — NOC®)
       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 schematic filed with this application>

       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
                                                                                                                             C — NOC®)
       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: < antenna is PCB antennafrom what is shown on External and Internal photo >

       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       X — YEs      C — NOC®)
       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 stand—alone as shown in test setup photographs filed with this application>




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             Cypress Semiconductor




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     egemme EMBEDDED IN TOMORROW® Cypres
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                                  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           — YES    U —NOC®)
     included in the application for 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 exhibitfiled 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
                                                                                                               — YESs   U —NOC®)
     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.
      15.212(a)(1)(vii)

     Details: <The module complies with FCC Part 15C requirements. Instructions to the OEM installer are provided in the
     installation manualfiled 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           — YES    U —NOC®)
     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. 15.212(a)(1)(viii)

     Details: <The module meets Portable exclusion levels as shown in the RF exposure information filed with this application.>




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      egemme EMBEDDED IN TOMORROW® Cypres
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                                              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 con trol
 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: < N/A>




               Software Considerations — KDB 594280 / KDB 442812 (One of the following 2 items must be applied)
                                       Requirement                                                  Requirement Met
     . For non—Software Defined Radio transmitter modules where software is used to
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       ensure compliance of the device, technical description must be provided about how C] — Provided in Separate
       such control is implemented to ensure prevention of third—party modification; see
                                                                                                                                 — NA
                                                                                               Cover Letter
       KDB Publication 594280.

      Details: <The firmware of the device can not 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            C] — Provided in Separate
     provide a software security description; see KDB Publication 442812.                                                        — NA
                                                                                                     Cover Letter

       Details: <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      C] — Provided in Separate
     third—party modifications; also, instructions to third—party integrators on how control
                                                                                                                                 — NA
                                                                                                     Cover Letter
     is maintained.

       Details: <N/A >




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  ewaeeE CY PR ES S
         sesemme—« Cypress Semiconductor

                                  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
                                                                                                    L — No,
                                                                       If No, and LMA applies, the applicant can optionally choose to
                                                                      not make the following detailed info public. However there still
      Is this module intended for                                     needs to be basic integration instructions for a users manual and
      sale to third parties?                                           the 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 DO03, 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
                                                                                                                 C] — 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 DO3, Section 2.5
                                                                                                                 Guide (or UM) for Full
              a.   Layout of trace design, parts list, antenna, connectors, isolation requirements, tests for
                                                                                                                    Modular Approval
                   design verification, and production test procedures for ensuring compliance. If
                                                                                                                      (MA) 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 DO3, Section 2.6
                                                                                                                   C] — An LMA applies
                 a.   Clearly and explicitly state conditions that allow host manufacturers to use the           and is approved ONLY
                      module. Two types of instructions are necessary: first to the host manufacturer to         for use by the grantee in
                      define conditions (mobile, portable — xx em from body) and second additional text          their own products, and
                      needed to be provided to the end user in the host product manuals.                          not intended for sale to
  6.   Antennas. KDB 996369 DO03, Section 2.7                                                                   3 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
  7.   Label and compliance information. KDB 996369 DO03, Section 2.8                                            the 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 DO03, 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 DO03, Section 2.10



Sincerely,        /e dq n             [_ ]-

By:                                   System Engineer                                 Yedan Li




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                              (Signature/Title‘)                            (Print name)




\ — Must be signed by applicant contact given for applicant on the FCC site, or by the authorized agent if an appropriate
    authorized agent letter has been provided. Letters should be placed on appropriate letterhead.


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Document Created: 2019-09-10 10:57:37
Document Modified: 2019-09-10 10:57:37

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