Experimental licensing is crucial to Radio Frequency (RF) research, educational pursuits and proving new technologies before manufacture. Client requirements for experimental licenses vary widely both in geographic scope, desired technical limits, frequency band and time needed for experimentation. HWG includes engineers who have managed and worked at the FCC’s Office of Engineering and Technology and know how to navigate the experimental licensing process. Our experience has saved clients time and money by focusing their applications on exactly what is needed and efficiently presenting those requests to speed FCC processing. For example, some frequency bands are prohibited from the outset, and, in some cases, several experiments can be combined into a single application – greatly reducing processing time.
Weekly, the FCC issues NALs, or proposed fines, to manufacturers and vendors who fail to properly authorize equipment that generates RF emissions. NALs can be costly, with the potential for fines for each non-complying device and for each day of non-compliance. Even before the NAL, a manufacturer or vendor can face costly and burdensome information requests from an FCC investigation. And for an importer, non-compliant devices can be denied clearance at the port-of-entry.
For base station transmitters and mobile units used for licensed services, the FCC rules on equipment compliance are usually explicit. However, there are a plethora of devices that must meet FCC equipment authorization requirements (for example, a vending machine with digital circuitry). Many manufacturers become aware of such requirements only after the device is designed, built and ready for market. Backtracking to comply with equipment authorization rules can be expensive – and sometimes resulting in competitors getting to market first. Ignoring such rules is not only illegal and risky, but bad for business.
We have the experience needed to advise clients on the development of technical rules that accommodate new technologies fairly and anticipate advanced future technologies. Our team includes several of the world’s foremost experts on forging equipment authorization policy, navigating FCC equipment authorization rules, and resolving equipment authorization enforcement matters. Our capabilities can potentially save clients millions of dollars in penalties. HWG has participated in equipment authorization proceedings both here and abroad, experience we can bring to bear on virtually any equipment authorization matter.
Regulation of Communications Equipment
In addition to RF regulation, the FCC places a number of other requirements on equipment manufacturers. Telecommunications equipment, for example, is subject to disabilities and law enforcement access requirements. Some of these rules require specific performance results, while others mandate that manufacturers conduct capabilities reviews as part of the product design process. Understanding these requirements upfront can avoid unnecessary redesigns and also better anticipate customer needs.
- Advise clients on what type of experimental license should be applied for.
- Streamline and consolidate experimental licenses wide in scope to ease administrative delay.
- Advocate before the FCC the grant of “difficult” experimental requests.
- Develop alternatives to experimental licensing.
- Represent clients before the FCC on radio frequency device compliance matters, including compliance with FCC (and foreign) device certification and authorization.
- Defend a company against charges that it improperly tested RF emitting devices to avoid FCC regulations.
- Expedite the equipment authorization approval process when time to market is crucial.
- Negotiate with the FCC to limit penalties when non-compliance is proved.
- Advise clients on preparing equipment authorization applications to avoid FCC delay.
- Advise clients on disabilities access requirements, including hearing aid compatibility, TTY capability and documenting the consideration of disabilities access during product development.
- Advise clients on the Communications Assistance for Law Enforcement Act (CALEA) capability requirements.