On October 2, 2024, the FCC issued an update to the KDB publication titled “273109 D02 Part 25 SCS and CMRS-Bands v01r01”, replacing the previous version, v01. This update contains critical clarifications and guidelines concerning the Supplemental Coverage from Space (SCS) for devices operating under Part 25 of the FCC rules. These changes are essential for anyone involved in the equipment authorization process, particularly those dealing with Class II Permissive Changes (C2PC) for handsets and other devices.
Key Updates:
- Expiration of Temporary Waiver Process:
- The expiration of the temporary waiver process will be announced in a future public notice. This waiver is currently in effect for adding Part 25 SCS operations by software for devices already HAC-compliant under C63.19:2013.
- Clarifications on C2PC Filings:
- Devices certified before December 5, 2023, that wish to add SCS capabilities without new hardware changes can use the waiver. These devices are not required to undergo new HAC testing under C63.19:2019 as long as the changes pertain solely to software.
- When filing a Form 731 under this waiver, the “associated with a waiver” box should not be marked. This distinction is important as it removes the need for a Pre-Approval Guidance (PAG).
What You Need to File for C2PC:
When filing a C2PC under the temporary waiver, the following exhibits are required:
- Cover letter attesting that:
- The intent is to add Part 25 SCS capability through a software update only.
- There are no changes to RF emissions.
- The temporary waiver process is being used.
- Attestation that the equipment complies with Section 2.911(d) requirements.
These updates simplify the process for adding SCS capabilities to existing certified devices, provided the required conditions are met. The waiver is in place until the expiration date is officially announced, and more information may be provided during the FCC’s Workshop Week.
Important Frequency Bands for SCS Operations:
Devices eligible under this temporary waiver may operate in the following bands:
- 600 MHz: 614-652 MHz, 663-698 MHz
- 700 MHz: 698-769 MHz, 775-799 MHz, 805-806 MHz
- 800 MHz: 824-849 MHz, 869-894 MHz
- Broadband PCS: 1850-1915 MHz, 1930-1995 MHz
- AWS-H Block: 1915-1920 MHz, 1995-2000 MHz
Filing Examples:
Here are some common scenarios for adding SCS capabilities:
- New Earth Station Device: Devices certified after May 30, 2024, must follow the full Form 731 process for a new ID and include all required reports and compliance information.
- Previously Certified Device (Before June 29, 2024): Such devices can add SCS capability via C2PC using the temporary waiver process. This waiver simplifies the filing requirements, but all changes must comply with KDB Publication 178919 D01.
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