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There have been 3 comment(s) made on this document:
  • Patrick Sullivan commented on 2009-11-04 17:17:28.053:
    Proposal: The Telecommunications Industry Association (TIA) urges the Commission to establish a new TCB Deferred Grant Process that will allow manufacturers to selectively share FCC equipment authorization evidence without jeopardizing pre-launch product confidentiality. Explanation: Due to customer and regional certification requirements, manufacturers often require evidence of FCC equipment authorization months before the product is marketed and available for purchase. A Deferred Grant Process will provide evidence of authorization, thus speeding innovative products to market. As a secondary alternative to such a process, TIA requests an expansion of short term confidentiality to include the remaining FCC exhibits. We believe the FCC requirement to make information (such as test reports and the other exhibits) publicly available can be delayed until the product is available in the market place. Although not as effective as the grant deferral process, expanded STC will help ensure pre-launch product confidentiality. TIA appreciates the Commission’s thoughtful consideration of this matter.
  • George Tannahill commented on 2009-10-26 13:13:15.023:

    With regard to the October 16th comments posted requesting a “TCB Defer Grant” process, the FCC is reviewing and discussing the request.  As the Commission has a requirement to make information publicly available, any changes to procedures related to what information the Commission makes available would require a rulemaking.  Also, any changes to the information requested on the FCC Form 731 would need OMB review and approval to collect additional information.

     

    Currently the FCC has a pending Notice of Inquiry on Wireless Innovation, FCC 09-66, which is regarding procedural changes at the FCC including the equipment authorization program.  The “TCB Defer Grant” process may be reviewed in conjunction with any associated change requests that are identified as part of FCC 09-66.

  • Mike Kuo commented on 2009-10-16 17:23:20.126:

    Dear FCC:

     

    I would like to suggest a new process within general public and TCB accessible sections.

     

    This new process is called " TCB Defer Grant" which is similar to OET e-filing system.  Under current TCB e-filing system, TCB does not have option to defer the grant since the grant is issued based upon the request of the applicant/grantee.  Time of issuing the grant can be easily controlled.

     

    However, many manufacturers/grantee are facing a situation as describe below:

    1.     For some of high profile consumer device, to maintain confidentiality of product is the most important aspect during the equipment authorization process.  Some of devices are not only required to demonstrate product compliance by using the grant of equipment authorization procedure, such devices are also required to meet industry conformance standards.  One of requirement before performing conformance tests is to demonstrate regulatory compliance by presenting FCC/TCB grant.  Most of manufacturers are doing regulatory compliance and conformance tests one to two months before actually announcing the product to the general public.  So how to maintain product confidentiality before launch date is difficult to achieve under current e-filing system.

    2.     When a product is subject to international regulatory approval requirements, some of regulatory authorities are required to show FCC grant of equipment authorization to speed up the review process or issue the certificate based upon FCC grant.  For those manufacturers would like to launch global market at the same date, lack of proof of FCC grant will cause the delay.

     

    In the TCB accessible sections

    1.     Form 731 section I with two additional fields for TCB to a) request this grant to be deferred (Y/N), b) enter the defer date.  The max. allowed defer date can be limited to have max.90 days.

    2.     When Defer request is selected and date entered, upon completion of Form 731 section III and clicking view grant, change the “ accept grant “ to “ accept defer grant”.  All required exhibits have to be uploaded to FCC before accept defer grant.  The defer grant can be printed by TCB but the statement on the defer grant shall not be confused by general public that such grant has been issued.  Such statement shall indicate the FCC ID has been reviewed and TCB listed on the grant has reviewed and decision has been made that this device complies with FCC rules and regulations. 

    3.     TCB shall not allow to supersede any uploaded exhibits but should allow to change confidential request type.

    4.     Defer grant date that entered in form 731 section I should be able to change by TCB.  The changing mechanism can be similar to “short term confidential maintenance screen.  FCC sent out reminder e-mail to TCB and the applicant 10 days from the defer date expired, if no action was taken by TCB, grant will be issued on the date entered in Form 731 section I.

    In the general public accessible sections:

    1.     In the public accessible area, additional search tab shall be added to be named “ TCB defer grant search “.

    2.     To search TCB defer grant, user has to enter exact FCC ID number and TC confirmation number which is similar to pending application search.  All the exhibits shall not be allowed to be viewed by general public.  In particular, defer date shall be blocked from public viewing.  The result of search shall only display the following information.  User shall not be able to view the technical parameter of defer grant.

    a.     Name of grantee

    b.     FCC ID number

    c.      TCB defer grant date

    d.     Name of TCB.

     
    Best Regards
     
    Mike Kuo / CCS

Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.