FCC_request_modular_approval_LISAU201

FCC ID: XPYLISAU201

Cover Letter(s)

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FCCID_4434896

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD Request for Modular/Limited Modular Approval Date: August 20, 2019 Subject: Manufacturer‘s Declaration for — Modular Approval C — Split Modular Approval C — Limited Modular Approval J — Limited Split Modular Approval Confidentiality Request for: XPYLISAU201 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 K —ves O —No® between the RF circuitry ofthe 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 locatedexternal to the shielded radio elements. 15.212(a)(1)(i) Details: <example — The module contains a metal shield which covers all RF components and circuitry. The shield is located on the top ofthe board next to antenna connector> The modular transmitter must have buffered modulation/data inputs (ifsuch inputs are provided) to o ensure that the module will comply with FCC requirements under conditions of excessive data rates —veEs 0 —Nno® or over—modulation. 15.212(a)(1)(ii) Details: <example— Data to the modulation circuit is buffered as described in the operational description provided with the application> 3. The modular transmitter must haveits own power supply regulation on the module. This is intended to ensure that the module will comply with FCC requirements regardless ofthe design of the power ) — YES C —NO(®) supplying circuitry in the device into which the module is installed. 15.212(a)(1)(iii) Details: <example— The module contains its own power supply regulation. Please refer to schematicfiled 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 —yE$ antenna, including the cable). The ‘*professional installation*" provision of§ 15.203 is not C — No applicable to modules but can apply to limited modular approvals under paragraph 15.212(b). 15.212(a)(D(iv) Details: <example— The module connects to its antenna using an UFL connector which is considered a non—standard connector. A list ofantennas tested and approved with this device may befound in users manual provided with the application> 5. The modular transmitter must be tested in a stand—alone configuration, i.c., 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 ofthe device into whichit is eventually installed. Unless the transmitter module will be battery powered, it must comply with the AC line conducted requirements found in Section 13.207. AC or DC powerlines and data input/output lines connected to the module must not contain ferrites, unless they will be marketed with the module (see Section —veEs O —NnoC) 15.27(a)). The length ofthese lines shall be lengthtypical of actual use or, ifthat lengthis unknown, at least 10 centimeters to insure that thereis 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: <example— The module was tested stand—alone as shown in test setup photographsfiled with this application> 053019—02a

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD 053019—02a

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD Modular Approval Requirement Requirement Met 6. The modulartransmitter must be labeled with its own FCC ID number, or use an electron display (see KDB Publication 784748). Ifusing a permanently affixed label with its own FCC ID number, ifthe 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: XYZMODELL." Any similar wording that expresses the same meaning may be used. The Grantee may cither provide such a label, an example ofwhich must be included in the application for equipment authorization, or, must provide adequate instructions along withthe module which explain this requirement. In the latter case, a copy ofthese instructions must be —ves 0 —no included in the application for equipment authorization. Ifthe modulartransmitter uses an electronic display ofthe FCC identification number, the information must be readily accessible and visible on the modular transmitter or on the device in whichit is installed. If the module is installed inside another device, then the outside ofthe 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. 13.212(a)(1)(vi) Details: <example— 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 withall specific rule or operating requirements applicable to the transmitter, including all the conditions provided in the integration instructions by the grantee. A copy ofthese 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 K —yes 0 —No) transmitteris authorized for operation under Section 15.231. For instance, data transmission is prohibited, except for operation under Section 15.231(c), in which case there are separate field strengthlevel and timing requirements. Compliance with these requirements must be assured. 15.212(a)(1)(vii) Details: <example— 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(6, 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 —veEs 0 — No 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: <example— The module meets Portable exclusion levels as shown in the RF exposure information filed with this application.> 053019—02a

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD Limited Module Description — When Applicab le * If a module does NOT meet one or more ofthe 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 andwill retain control over the final installation ofthe device, such that compliance ofthe 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 thatfull compliance of the end product is always ensured should be provided here. Details: <example — N/A> 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 ofthe device, technical description must be provided about how C] — Provided in Separate such control is implemented to ensure prevention ofthird—party modification; see O — N/A Cover Letter KDB Publication 594280. Details: <example— Thefirmware of the device can not be modified or adjusted by the enduser as describedin a separate cover letter filed with this application. > For Software Defined Radio (SDR) devices, transmitter module applications must C] — Provided in Separate provide a software security description; see KDB Publication 4428 12. O — /A Cover Letter Details: <example —N/A> Split Modular Requirements Requirement Provided in Manual 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 O — wA Cover Letter is maintained. Details: <example — N/A > 053019—02a

THIS MUST BE SIGNED BY THE APPLICANT/AGENT AND SHOULD BE PLACED ON APPROPRIATE LETTERHEAD OEM Integration Manual Guidance— KDB 996369 DO3 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 C — No, If No, and LMA applies, the applicant can optionally choose to not make the following detailedinfo public. However there still is thiemodute intended for needs to be basic integration instructions for a users manual and sale to third parties? — YES the information 20 \ below. must still . be included Ma in the operational 5 j 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 DO3, 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 DO03, Section 2.2 a. Only list rules related to the transmitter. Summarize the specific operational use conditions. KDB 996369 DO3, Section 2.3 > a. Conditions suchas limits on antennas, cable loss, reduction of power for point to point systems, professional installation info 3. Limited Module Procedures. KDB 996369 DO3, Section 2.4 a. Describe alternative meansthat the grantee uses to verify the host meets the necessary limiting conditions b. When RF exposure evaluation is necessary, state how control will be maintained such that compliance is ensured, such as Class II for new hosts, etc. 4. Trace antenna designs. KDB 996369 DO3, Section 2.5 a. Layout oftrace design, parts list, antenna, connectors, isolation requirements, tests for design verification, and production test procedures for ensuring compliance. If confidential, the method used to keep confidential must be identified and information provided in the operational description. 5. RF exposure considerations. KDB 996369 DO03, Section 2.6 a.Clearly and explicitly state conditions that allow host manufacturers to use the module. Two types of instructions are necessary: first to the host manufacturer to define conditions (mobile, portable — xx em from body) and second additional text needed to be provided to the end user in the host product manuals. 6. Antennas. KDB 996369 DO3, Section 2.7 a. List of antennas included in the application and all applicable professional installer instructions when applicable. The antenna list shall also identify the antenna types (monopole, PIFA, dipole, etc — note that "omni—directional" is not considered a type) 7. Label and compliance information. KDB 996369 DO3, Section 2.8 a. Advice to host integrators that they need to provide a physical or e—label stating "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 simultancous 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, _ By: ‘fi‘ £ 3 Roseelan Sathiyaseclan (Signature/Title‘) (Print name) ! — Must be signedby applicant contact given for applicant on the FCCsite, or by the authorized agent if an appropriate authorized agent letter has been provided. Letters should be placed on appropriate letterhead. 053019—02a


Document Created: 2019-08-20 10:38:52
Document Modified: 2019-08-20 10:38:52
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