FCC Equipment Authorization System Correspondence
To: Sid Sanders, TEI@TIMCOENGR.COM
From: Tim Harrington, Tim.Harrington@fcc.gov
Department: FCC Equipment Authorization Branch
Regarding: FCC ID: AS5BBTRX-05
Applicant: Alcatel-Lucent USA Inc.
731 Confirmation Number: TC216321
Date of Original E-Mail: 07/19/2015
Correspondence Reference Number: 208289
This correspondence replaces and supersedes the preceding correspondence (preceding used incorrect form letter).
Correspondence Details
To: TCB
CC: Applicant
A) Regulatory Processing Requirements
Per 47 CFR 2.962(f)(1), TCBs shall process certification applications in accordance with FCC rules and policies including procedures. Further, per 2.962(f)(5)(i) (CFR version 1999-02-02 to 2015-07-14), TCBs may not certify equipment for which the application of the rules or requirements is unclear.
Since the TCB program started in 1999, TCBs have been instructed that equipment must be tested at its maximum rated output power, and that maximum output power shown by test data is then what is listed on Form-731 line entries.
Example text from FCC documents and training notes: Power on grant lines is taken to be the maximum rated output, and must be supported by testing at the maximum rated output.
B) Power Rating Discrepancy and Compliance Concerns
The highest power listed on the 4/30/12 original grant under FCC ID AS5BBTRX-05 is 25 W; that constitutes the operating maximum rated output power for which the FCC ID is valid (per the test data and representations in the filing; 2.907).
The highest power listed on the 7/9/15 permissive change grant under FCC ID AS5BBTRX-05 is 40 W.
Per 47 CFR 2.1043(a), change to the maximum power rating requires a new FCC ID (the concept that maximum rated output power cannot increase with a permissive change has been in part 2 equipment authorization rules since 1958).
Due to grant listed power higher than 25 W indicates TCB processing of this application ostensibly does not conform with 2.1043(a) and 2.962(f)(5)(i).
Action Required: No later than 12 pm US eastern time 2015 July 27, TCB please reply herein providing justification for granting this application given the preceding concerns. Alternatively, please submit letter from applicant requesting application dismissal.
C) Selected Text from FCC Policies and Procedures
- Oct. 2009 FCC-TCB training notes Dayhoff: Power listed on grant is based on measurement data and supplied in the report. Manufacturers ratings should agree with listed power.
- (Regarding amplifiers and other devices with multiple signals at output terminals): The maximum power output per carrier should be listed.
- KDB Publication 291699, 01/11/2007: Grantees must coordinate with Test labs to ensure all samples for EMC, HAC and SAR are tested at maximum output conditions as required by the applicable test procedures.
- Feb. 2001 FCC-TCB training notes Coperich: 4.) POWER OUTPUT - The power output listed on the Grant is to be a rating. This is a rating of the capability of the unit and should be supported by the test data.
- Dec. 1999 FCC-TCB training notes Coperich: POWER OUTPUT: The power output listing on the Grant is to be based on the measurement data obtained and supplied in the test report. This should agree with the manufacturers rating.
- FCC Form 731, March 1997: 8. EQUIPMENT SPECIFICATIONS: (a) Frequency range in MHz, (b) Rated RF power output in watts.
