Well There They Go Again…
The FCC tossed out another Notice of Proposed Rulemaking (NPRM) recently (published August 6, 2015) to adjust its Certification Rules for RF products. The Commission recognizes, with a dash of artful prose, that “the RF equipment ecosystem has significantly expanded” in the past fifteen years. That is a reality and the rules continue morph to adapt to the “ecosystem.”
Tablets, phablets, wearables, washables, wireless wonders are all around us. The complexity and proliferation of devices, made possible, arguably, by the liberalization of the FCC Certification process fifteen years ago is astonishing. In our work we have seen the integration of wireless into products both pedestrian—like wireless speakers—and the sublime—we once certified a device with a wireless remote control and special “accessory” for remotely facilitating online, er, titillating “conversations.”
At any rate, the newest NPRM patches up a few holes in the Rules, but largely addresses the challenges and opportunities of the continuing integration of complex wireless devices; these certainly are not my father’s radios. The FCC recognizes that the “development of highly integrated circuitry, software-based designs and new production procedures has resulted in the use of substantially more complex RF transmitters in increasingly compact devices.”
For example, theoretical unicorns just a few years ago, a frequency-agile software-defined radio (SDR) is now a fait accompli. If you would crack open the cover of a modern mobile phone, you can find circuitry that has amazing agility to tune over many bands and channels, just using a different set of instructions from either on-board firmware, or, increasingly by instructions sent over the internet or cell networks.
As an example, one particular HTC, granted in 2013, has four distinct operating bands and ten separate channel authorizations, according to information on the FCC web site. And this is an “old” phone by some standards.
While neatening up a few things on the procedural side, a thrust of some of the recent Rulemakings (more notably the recent changes chronicled in Reality Engineering in March 2015) has been the huge impact on the wireless technology sector from Asia, notably China. I’ll explain that in a moment.
Just for grins, I did a little digging at the FCC site recently (July 2015); I was curious about the source of the Certifications over the past ten years, that is, where are the Grantees coming from? Looking at original certifications (only), the data returned some interesting (and maybe not too surprising trends). I compared 2004 with 2014.
First, a word about “Grantees” and “Grants.” A Grantee is the party that is responsible for the device; they may or may not be the manufacturer, but they hold legal responsibility for proper device function when it is placed on the market. The Grantee receives the Grant from the FCC’s system, initiated by a Telecommunications Certification Body (which started granting 100% of the applications just recently).
The device that is “granted” may have a number of grants, depending on the number of radios in the device. As mentioned before, the HTC product had 10 separate authorizations or “Grants.” So, consider that the following numbers have some skew because more devices in 2014 had multiple grants.
The Incoming Tide
Comparing the last ten years, the total number of Grants issued in 2004 was 6,630. The total number of Grants issued in 2014: 32,979. A 4X increase!
If not remarkable enough, it’s interesting to see the source of these Grants. This can be done by doing a little sorting and Kindergarten Excel work. What it yields is the following pie-chart for 2004 in Figure 1.
Looking at the same data for 2014 yields a completely differently-rendered pie in Figure 2.
Not only remarkable is the shift in distribution towards China and Taiwan, but consider the sheer volume of grants that have been issued to Grantees in those countries (I combine China, Taiwan and Hong Kong as they are already knitted together in so many ways, politics aside). In aggregate, there were a little over 2,000 Grants issued in 2004 to over thirteen thousand in 2014. This is largely accounted for by the 25-fold increase in Grants issued to Chinese entities. Amazing.
Now, what does this have to do with the FCC Rulemaking process? The reaction to this phenomenal growth is a tangled bit of technology adaptation, trade, politics, competitive advantage, protectionism and government-to-government misalignment. The March 2015 Reality Engineering column addresses the implications to test laboratories in ET Docket 13-44 RM 11652, wherein the FCC is trying to drive folks to the table to discuss Mutual Recognition, but that’s another issue altogether.
This article addresses the FCC’s reaction to technology expansion of wireless products, a complexity driven, in large part, by the devices that have been developed and produced in the factories of Asia. (Curiously, the real champion, in terms of growth, is Spain, which received 3 Grants in 2004 and 108 Grants in 2014, so its expansion beat China. Sweden’s Granting activities rose by 20X, mostly because of the activity of a single manufacturer.)
To the Matter at Hand
To get a sense of the state-of-the-art of wireless devices, at least from a regulatory and complexity point-of-view, it is instructive to read through the back-story and the perspective that has been laid out in the NPRM. As far as regulatory reading, it’s a page-turner with juicy comments and perspectives on the state of modern device design. Well, maybe you have to read between the lines, just a little.
Combining the Verification and Declaration of Conformity (DOC) process into a Supplier’s Declaration of Conformity. This is another step in the evolution of the Equipment Authorization System, where once-upon-a-time there was Type Approval and Type Acceptance. The FCC proposes to have two levels of conformity assessment: SDoC and Certification. Certification is staying the same. The implication of sDoC is that all the “responsible party” will self-declare. This (potentially) removes third-party, i.e., labs, from the equation.
To wit, the curious thing about the proposal is that “The use of accredited testing facilities would not be required under our proposal.” This is a reversal to the existing DoC process that requires laboratories that issue reports for DoCs to be accredited. Again, referring to other rules changes that were recently published, all Certification submissions must be performed in accredited labs. The thinking, I posit, is that the vast majority of devices that have been DoC’d and verified haven’t been an interference issue (they haven’t), so accreditation is not required.
The cherished FCC logo might go away! Comments are invited on sun-setting the FCC logo. This would be, in my opinion, not desirable because it will lessen my ability to explain what I do for a living at cocktail parties. She: “So, what do you do for a living, Mike?” Me, pointing to the back of my phone: “You see this little ‘FCC’ right here? That’s what I do.” She, stifling a yawn: “Oh…interesting.” So I kinda like it, but some manufacturers bum out at the label stuff they have to cram onto their product. Others “use” the FCC logo as an entry to other countries. Even if it’s not part of a great pick up line, I like it. I think it indicates a certain quality because it means the product was tested at an accredited lab, but I’m admittedly biased. As a minimum, it can be voluntary, but still have the lab accreditation component.
Also at question is whether devices that fall under sDoC might optionally be certified. Me? I think options are a good idea. Many manufacturers “use” the FCC Certification as a measure of ‘quality’ or for access to non-US markets. Having an FCC ID is cool too, at least for some.
Family matters: The FCC is also entertaining rules to allow a family of products to be certified under one ID. This is a good step forward for manufacturers who needed separate FCC IDs for variants of devices that may operate together or are all part of a modern family.
Expanding the notion of modular transmitters to all RF devices. That’s a step forward too. The idea is that flexibility can be entertained for the licensed electronics brethren as well. Further to modular transmitters, the NPRM discusses the proposal to apply Certification to a single chip. That’s cool, since many transmitters are shrinking to Lilliputian proportions. This affects a bunch of proposals around labeling too. Labeling is a PITA for the teeny-tiny tots of RF and the commission proposes a few codifications and clarifications about E-Labeling and physical labeling.
Of great interest in the radio certification community is the control and administration of the dynamically-agile radios. New designs are entirely controllable over the Internet. The big question is: what are the security protocols that should be implemented to make sure some rogue nerd, or worse, hacks into a bunch of radios and starts retuning the local police network? Could happen…they’ve hacked cars.
Some of the other proposed changes are more prosaic, clarifying duties and roles and responsibilities. Some changes are potentially very liberalizing for manufacturers, allowing changes in equipment that are much looser than current Rules. One item that had a “ponder the belly button” kind of feel, to me, was whether ANSI C63-x documents “are sufficient to address compliance testing” and (dare we?) remove specific measurement procedures in 15.31-15.35. I say “go for it, FCC.”
And finally, for importers: No More Form 740! (unless enough people say. “No! I love Form 740! It’s so easy to fill out!”)
By the time this piece hits the streets, you should still have a few days to peruse the NPRM and wax publicly about the merits and benefits of Short and Long-Term Confidentiality. Stay tuned.
The views and opinions expressed here are entirely those of the author.
Mike Violette is founder of Washington Laboratories and American Certification Body. Mike can be reached at firstname.lastname@example.org.
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