FCC Canopy Reflector Authorization Opinion

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Original Message -----

From: Joe Dichoso To: Chuck McCown Cc: Rashmi Doshi ; Raymond Laforge Sent: Friday, February 06, 2009 7:41 AM Subject: RE: type approval question


Hello Chuck,

Per the rules on Part 15 antenna modifications is in Section 15.204, only antennas of the same type can be used. For this device, antennas of the same type with the same or lower gain can be used per 15.204c(4) without testing. Any antenna with higher gain or of any type other than what is listed in the filing per 15.204(c)3 needs appropriate testing and either a class II filing by the grantee or a new filing by a third party. Testing of the higher gain antenna is needed because the emissions will be higher than what was approved.

Testing with a different antenna type (even with lower gain) is needed due to spurious emissions, not only harmonic spurious emissions but also band-edge compliance.

Regarding the use of a reflector, if this increases the range of the device or is not listed in the equipment authorization, it cannot be used.[emphasis added]

Regards,

Joe


And on 2-23-2011 more clarification was added:

From: Joe Dichoso Sent: Wednesday, February 23, 2011 7:00 AM To: Chuck McCown Cc: Rashmi Doshi ; Tom Phillips ; William Hurst ; Jim Szeliga Subject: RE: type approval question

Chuck,

We are in the process of adding info on reflectors to the KDB to further address the new issue.

I think in general though, while we may not be able to cover all instances, any time you modify the device to increase radiated power over what was approved, it is not acceptable. [emphasis added]

Thanks, Joe



From: Joe Dichoso Sent: Tuesday, February 22, 2011 11:55 AM To: Chuck McCown Cc: Rashmi Doshi ; Tom Phillips ; William Hurst ; Jim Szeliga Subject: RE: type approval question

Chuck,

Here is a KDB publication on passive reflectors.

-Joe


Publication Number: 420149 Rule Parts: 15C Publication Date: 04/28/2009

Keyword: 15.203, 15.204, Passive Repeaters, Passive Reflectors First Category: Radio Service Rules

Question: Question 1: Can passive reflectors be used with an approved Part 15 device? Question 2: Are passive bill boards or other metallic reflectors located at significant distances from the Part 15 transmitter acceptable for use? Answer:

Answer 1: Passive reflectors can only be used when the passive reflector has been authorized as an antenna[emphasis added] for the approved Part 15 device. When used with Part 15 transmitters, passive reflectors are considered part of the antenna assembly[emphasis added] of the device, per Section 15.204(c).

Answer 2: Passive repeaters such as bill board reflectors that are located at significant distances from the Part 15 transmitter, and are used to change the direction of a microwave path to overcome obstructions, are acceptable if there is no increase in resulting antenna gain and there is no interference.