Save WiFi/RFC

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The following are the different call for comments highlighted by the Federal Registrar's summarization of the NPRM. It might be good to quote the actual NPRM. We should make sure we organize this in a way that pulls out which specific requests for comments we should be replying to and we should be able to quote from the text of the NPRM for each of these when drafting our comment.

  • "Finally, the Commission sought comment on how to codify any filing or notification requirements that may be necessitated by the adoption of these proposals." [1]
  • "It invited commenters to discuss the costs and benefits of the rule changes proposed in the NPRM, and provide relevant supporting data, along with additional suggestions for enhancing the benefits or reducing the costs associated with the proposals." [2]
  • "It tentatively concluded that a single process would simplify the equipment authorization requirements and reduce confusion as to which process may apply to any given device, while continuing to adequately ensure compliance with the rules, and sought comment on the proposed rule revisions." [3]
  • " The NPRM sought comment on use of the specific term “Supplier's Declaration of Conformity” or “SDoC” for this new process." [4]
  • "It proposed to otherwise retain the other DoC rules (i.e. those within §§ 2.1071 through 2.1077) and to apply them to the new approval procedure, and sought comment on proposed revisions to § 2.1077 that would require all equipment to include a compliance statement with the product literature that identifies for consumers who is responsible for the device's compliance with the Commission's technical regulations. " [5]
  • "Additionally, the Commission proposed to permit certification of modular transmitters that consist of a single chip which has been tested to demonstrate compliance in a typical installation provided that the grantee includes detailed instructions for integration into other RF devices (i.e. host devices) to ensure that the ultimate configuration is consistent with the significant parameters for which it was tested. The Commission sought comment on all of these proposals." [6]
  • "The Commission sought comment on whether this regulatory regime would enable the development of this kind of product while ensuring compliance with the rules—including those related to interference, RF exposure, and hearing aid compatibility." [7]
  • "The proposals would modify the SDR-related requirements in part 2 of its rules based in part on the current Commission practices regarding software configuration control." ... "This information would be included as part of the operational description information required in the application for certification. The Commission sought comment on these proposals." [8]
  • " The Commission sought comment on two proposed broad categories of changes—those that do not require a new FCC ID and those that do. Under this regime, a manufacturer or other responsible party would evaluate the scope of changes and potentially test its modified device to determine the applicable change category." [9]
  • "28. The Commission concluded that certain device modifications (such as major changes in the design, layout or replacement of the components) would be substantial enough to require a new FCC ID that has been validated by a new grant of certification. The Commission proposed to revise § 2.1043 and remove the “electrically identical” definition from § 2.924 of the rules, and to add rules that address the modular transmitters, software-defined radio, and device change matters discussed. The Commission sought comment on these proposals." [10]
  • "35. This NPRM also seeks comment on how to address certified modular transmitters that are sold directly to consumers to be integrated into host devices or independently combined. " [11]
  • " It sought comment on ways both manufacturers of certified end products and the FCC can better distinguish among the different versions of certified modular transmitters that may be incorporated into their products from that point forward, and asked if anything, short of requiring a permissive change application for certification of the end product, should be done to track whether authorized version(s) of certified modular transmitters have been incorporated in end products." [12]
  • "37. The Commission recognized that adoption of its proposals could require parties to perform additional compliance testing on the end product with one or a combination of modular transmitters installed. However, it tentatively concluded that such costs would be outweighed by the benefits of more clearly defining responsibilities prior to certification and marketing products, which, in turn would better ensure compliance with the Commission's rules. The Commission also sought comment on whether the proposal represented the least burdensome and most efficient way to meet these goals." [13]
  • "The Commission further proposed to permit the new responsible parties to refer to test data submitted in the original grantee's filing, and sought comment on what additional portions of the original grant of certification the applicant would it be appropriate to incorporate by reference into the new application for certification." [14]
  • "50. Finally, the Commission stated that it believes that its proposals for short- and long-term confidentiality would comply with its obligations under the Freedom of Information Act (FOIA) and the Trade Secrets Act, and sought comment on that conclusion." [15]
  • "Lastly, the Commission proposed that it could specify that a provisional grant constitutes a “grant” for purposes of its importation rules. It sought comment on all of these proposals, as well as any other options it should consider." [16]
  • "56. To provide information prior to purchase, to avoid a hazard or when devices are imported, the Commission proposed that devices displaying labeling and regulatory information electronically must also place this information either on the product packaging or on a (removable) physical label placed on the device at the time of importation, marketing, and sales. The Commission tentatively concluded that its proposal would comply with the E-LABEL Act because devices with electronic displays are not usually capable of electronically providing this information in an effective manner when the devices are typically inside packaging and uncharged. The devices therefore do not have “the capability to digitally display required labeling and regulatory information” in the context for which the requirement exists. The Commission sought comment on this proposal." [17]
  • "57. The Commission stated that its proposed rules were not intended to change existing requirements to place warning statements or other information on device packaging or in user manuals or make information available at the point of sale, and tentatively concluded that such requirements are outside the scope of the E-LABEL Act. The Commission did not propose to require parties to display any information that is not already required by the rules as part of an electronic label, nor to eliminate the ability of manufacturers to continue to physically label devices if they wish to do so. It also sought comment on the costs and benefits of its proposals." [18]

INCOMPLETE -- MORE specific RFC come after this.