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User Manual | Users Manual | 317.06 KiB | May 27 2021 / November 30 2021 | delayed release | ||
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Int Photos | Internal Photos | 203.55 KiB | May 27 2021 / November 30 2021 | delayed release | ||
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Internal Photos | Internal Photos | 624.35 KiB | August 12 2022 / August 30 2022 | |||
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Ext Photos | External Photos | 517.70 KiB | May 27 2021 / November 30 2021 | delayed release | ||
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External Photos | External Photos | 495.96 KiB | August 12 2022 / August 30 2022 | |||
| 1 2 3 | ID Label/Location Info | 71.83 KiB | May 27 2021 / June 03 2021 | |||||
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Agency Authorization Letter | Cover Letter(s) | 88.80 KiB | August 12 2022 / August 30 2022 | |||
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C2PC Letter | Cover Letter(s) | 373.14 KiB | August 12 2022 / August 30 2022 | |||
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Confidentiality Request | Cover Letter(s) | 406.33 KiB | August 12 2022 / August 30 2022 | |||
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MPE Report | RF Exposure Info | 421.02 KiB | August 12 2022 / August 30 2022 | |||
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Power of Attorney Letter | Cover Letter(s) | 372.82 KiB | August 12 2022 / August 30 2022 | |||
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Pro Installation Declaration | Cover Letter(s) | 384.32 KiB | August 12 2022 / August 30 2022 | |||
| 1 2 3 | Schematics | Schematics | August 12 2022 | confidential | ||||
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Test Report | Test Report | 1012.90 KiB | August 12 2022 / August 30 2022 | |||
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Test Setup Photos | Test Setup Photos | 287.28 KiB | August 12 2022 / August 30 2022 | |||
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Authorized Signature | Cover Letter(s) | 155.17 KiB | May 27 2021 / June 03 2021 | |||
| 1 2 3 | Block Diagram | Block Diagram | May 27 2021 | confidential | ||||
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Confidentiality Letter | Cover Letter(s) | 96.75 KiB | May 27 2021 / June 03 2021 | |||
| 1 2 3 | Grantee Declaration for Waiver | Operational Description | May 27 2021 | confidential | ||||
| 1 2 3 | Operation Description | Operational Description | May 27 2021 | confidential | ||||
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Power of Attorney Letter | Cover Letter(s) | 19.70 KiB | May 27 2021 / June 03 2021 | |||
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Setup Photos | Test Setup Photos | 828.03 KiB | May 27 2021 / November 30 2021 | delayed release | ||
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Waiver DA 21-407 | Cover Letter(s) | 181.00 KiB | May 27 2021 / June 03 2021 | |||
| 1 2 3 | Cover Letter(s) | January 13 2021 |
| 1 2 3 | User Manual | Users Manual | 317.06 KiB | May 27 2021 / November 30 2021 | delayed release |
Vehicle opening and closing Three Types of Keys This vehicle supports three types of keys:
Authenticated phone - You can set up your personal smartphone to communicate with your vehicle using Bluetooth. Supports automatic locking and unlocking as well as several other functions using the Tesla mobile app. An authenticated phone is the preferred key because you never need to remove it from your pocket or purse. Key card - Tesla provides a key card that communicates with your vehicle using short range radio-frequency identification
(RFID) signals. The key card is used to "authenticate" your phone to work with your vehicle and to add or remove other key cards, phones, or key fobs. In situations where your authenticated phone has a dead battery, or is lost or stolen, use your key card to unlock, drive, and lock your vehicle Key fob - An accessory sold separately, similar to a traditional key fob, that allows you to press buttons to open the front and rear trunks, and unlock, lock, and drive your vehicle. Your vehicle also have UWB function for passive entry function. The door handle will present when you approaching your vehicle while you carrying your keyfob. Your vehicle supports a total of 19 keys, which can include authenticated phones, key cards, and up to four key fobs. Caution: Remember to bring a key with you when you drive. Although you can drive your vehicle away from its key, you will be unable to power it back on after it powers off. Authenticated Phone Using your phone is the most convenient way to access your vehicle. As you approach, your phone's Bluetooth signal is detected and doors unlock when you press a door handle. Likewise, when you exit and walk away with the phone, doors automatically lock Before you can use a phone to access your vehicle, follow these steps to authenticate it:
1. Download the Tesla mobile app to your phone. 2. Log into the Tesla mobile app using your Tesla Account user name and password. Note: You must remain logged in to your Tesla Account to use your phone to access your vehicle. 3. Ensure that your phone's Bluetooth setting is turned on. Note: Your vehicle communicates with your phone using Bluetooth. To authenticate your phone or use it as a key, the phone must be powered on and Bluetooth must be enabled. Keep in mind that your phone must have enough battery power to run Bluetooth and that many phones disable Bluetooth when the battery is low. 4. Ensure that Allow Mobile Access (Controls > Safety & Security > Allow Mobile Access) is enabled. 5. In the Tesla mobile app, touch PHONE KEY then touch START to search for your vehicle. When your vehicle is detected, the mobile app asks you to tap your key card. 6. Tap the key card against the your vehicle card reader on the door pillar or center console. When your vehicle detects your key card, the mobile app confirms that your phone has been successfully authenticated. Touch DONE. If the key card is not successfully scanned within approximately 30 seconds, the mobile app displays an error message. Touch PHONE KEY on the app again to retry. To view a list of keys that can currently access your vehicle, or to remove a phone, touch Controls > Locks. Note: Authenticating your phone allows you to use it as a key to access your vehicle. To use the phone hands-free, access your phone's contacts, play media from it, etc., you must also pair and connect to it using the Bluetooth settings. Note: Your vehicle can connect to three phones simultaneously. Therefore, if more than one phone is detected and you want to use, or authenticate, a different phone, move the other connected phone(s) out of range or turn off its Bluetooth setting. Note: Unlike the mobile app, once a phone has been authenticated, it no longer requires an internet connection to communicate with your vehicle. Authenticated phones communicate with your vehicle using Bluetooth. Note: Although Bluetooth typically communicates over distances of up to approximately 9 meters, performance can vary based on the phone you are using, environmental interference, etc. Note: If multiple vehicles are linked to the Tesla Account, you must switch the mobile app to the vehicle that you want to access before you can use the phone as a key. Key fob If you have purchased the key fob accessory (available for purchase from Tesla stores or online at www.tesla.com/shop), you can quickly familiarize yourself with this key by thinking of it as a miniature version of your vehicle, with the Tesla badge representing the front. The key has three buttons that feel like softer areas on the surface. 1. Front trunk - Double-click to open the front trunk. 2. Lock/Unlock All - Single-click to lock doors and trunks (all doors and trunks must be closed). Double-click to unlock doors and trunks. 3. Trunk - Double-click to open the rear trunk. Hold down for one to two seconds to open the charge port door. Once inside, power up your vehicle by pressing the brake pedal within two minutes of pressing the unlock button on the key fob (see Starting and Powering Off on page 46). If you wait longer than two minutes, you must press the unlock button again, or place the key fob near the card reader located behind the cup holders on the center console. When your key fob is detected, the two minute authentication period restarts. When approaching or leaving your vehicle carrying the key fob, you do not need to point the key fob at your vehicle as you Consumer Information 361 press a button, but you must be within operating range. Radio equipment on a similar frequency can affect the key. If this happens, move the key at least 30 cm away from other electronic devices (phone, laptop, etc). If the key fob does not work (for example, its battery is dead), you can touch it's flat side against the card reader on the driver's side door pillar (like the key card). Instructions for changing the battery are provided below. Note: Walk-Away Door Lock operates only when using an authenticated phone. When you walk away from your vehicle carrying your key fob, your vehicle does not automatically unlock/lock, even if this feature is turned on (see Walk-Away Door Lock on page 13). Note: You can use the same key fob with multiple vehicles provided you authenticate it (see Managing Keys on page 10). However, key fob works with only one vehicle at a time. Therefore, to use a key fob for a different vehicle, touch its flat side against the card reader on the driver's side door pillar. Note: A vehicle supports up to four different key fobs. Caution: Protect the key from impact, high temperatures, and damage from liquids. Avoid contact with solvents, waxes and abrasive cleaners. Replacing the Key Fob Battery Under normal use, the key fob battery lasts for approximately five years. When the battery is low, a message displays on the touchscreen. To replace the key fob battery:
1. With the key fob placed button side down on a soft surface, release the bottom cover. 2. Remove the battery by lifting it away from the retaining clips. 3. While avoiding touching the battery's flat surfaces, insert the new battery (type CR2330) with the + side facing up. Note: CR2330 batteries can be purchased through online retailers, local supermarkets, and drug stores. 4. Holding the bottom cover at an angle, align the tabs on the cover with the corresponding slots on the key fob, then press the cover firmly onto the key fob until it snaps into place. ALL REGIONS - FCC and IC Certification Security Controller Fascia Endpoint Key fob TPMS Radar Tesla Tesla Tesla Tesla Component Manufacturer Model Operating Frequency (MHz) FCC ID IC ID B Pillar Endpoint Tesla 1614291 13.56 2400-2483.5 6500-8000 2AEIM-1614291 20098-1614291 1614280 2400-2483.5 2AEIM-1089774 20098-1089774 1613851 1614283 2400-2483.5 6500-8000 2400-2483.5 6500-8000 2AEIM-1613851 20098-1613851 2AEIM-1614283 20098-1614283 1472547 2400-2483.5 2AEIM-1472547 20098-1472547 Continental ARS 4-B 76000-77000 OAYARS4B In Cabin Radar Tesla 1616631 60000-64000 2AEIM_1616631 20098-1616631 Homelink Gentex ADHL5C 286-440MHz CarPC Tesla 1960000 Wireless Charger Tesla WC4 127.72KHz 13.56 2400-2483.5 NZLADHL5C XMR2020AG525RG L YZP-
ATC5CPC001 2AEIM-WC4 20098-WC4 The devices listed above comply with Part 15 of the FCC rules and Industry Canada's license-exempt RSS Standard(s) and EU Directive 2014/53/EU. Operation is subject to the following two conditions:
1. This device may not cause harmful interference; and 2. This device must accept any interference received, including interference that may cause undesired operation. Changes or modifications not expressly approved by Tesla could void your authority to operate the equipment. The In Cabin Radar restricted to factory installation. 362 OWNER'S MANUAL ALL REGIONS - Radio Frequency Information This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, try to correct the interference by one or more of the following measures:
Reorient or relocate the receiving antenna. Increase the separation between the equipment and receiver. Connect the equipment into an outlet on a circuit different from that to which the receiver is connected. Consult the dealer or an experienced radio/TV technician to help. The users manual or instruction manual for an intentional or unintentional radiator shall caution the user that changes or modifications not expressly approved by the party responsible for compliance could void the user's authority to operate the equipment. In cases where the manual is provided only in a form other than paper, such as on a computer disk or over the Internet, the information required by this section may be included in the manual in that alternative form, provided the user can reasonably be expected to have the capability to access information in that form. Battery related warning:
Do not ingest battery, Chemical Burn Hazard The keyfob contains a coin cell battery. If the coin cell battery is swallowed, it can cause severe internal burns in just 2 hours and can lead to death. Keep new and used batteries away from children. If the battery compartment does not close securely, stop using the product and keep it away from children. If you think batteries might have been swallowed or placed inside any part of the body, seek immediate medical attention. Consumer Information 363 CAUTION: This equipment and its antennas must not be co-located or operated with another antenna or transmitter. ALL REGIONS - RF Modules The devices described below have been evaluated against the essential requirements of the 2014/53/EU and 2011/65/EU Directive. Description Frequency Band Power Level Antenna Location Security Controller 2.4 GHz 3mW output PCB Antenna, in center console Security Controller 11.56 MHz n/a (magnetic field) PCB Antenna, in center console Rear Fascia Endpoint 2.4 GHz 3mW output PCB Antenna, behind rear fascia Pillar Endpoint 2.4 GHz 3mW output PCB Antenna, behind the B-pillar glass Pillar Endpoint 13.56 MHz n/a (magnetic field) PCB Antenna, behind the B-pillar glass TPMS Sensor 2042-2480 MHz 2.5 mW Each wheel n/a (receive only) Rear Window n/a (receive only) Rear Window 10 mW Above front bumper beam 2402-2480 MHz 2.5 mW max. B-header Left hand side 2 W 1 W Transmit and receive - B-header Right hand side, also used for eCall Receive - B-header Left hand side B-header (MIMO) Wireless Connectivity WCDMA (Band 8) 250 mW WCDMA (Band 1/3) 250 mW 76-108 MHz 174-241 MHz 433.9 MHz 885-915 930-960 MHz 1710-1785 1805-1880 MHz 909-915 954-960 MHz 1920-1980 2110-2170 MHz 200 mW 200 mW 200 mW 100 mW 2500-2570, 909-915 MHz 2620-2690, 954-960 MHz 832-862,703-748 MHz 791-821, 758-803 MHz 1940-1965, 1735-1765 MHz 2130-2155, 1830-1860 MHz 2400-2483.5 MHz 5470-5725 MHz, 5725-5850 MHz FM DAB Homelink Bluetooth GSM 900 GSM 1800 LTE (band 7/8) LTE (band 20/28) LTE (band 1/3) Wi-Fi 364 B-header Left hand side B-
header Right hand side, Wireless Connectivity OWNER'S MANUAL GNSS 1563-1587 MHz, 1593-1610 MHz n/a (receive only) Between windshield and rear view mirror Charge port antenna RKE 433.9 MHz n/a (receive only) Charge port Consumer Information 365 NORTH AMERICA ONLY - Canada CAN ICES-003 (B)/NMB-003(B) Le prsent appareil est conforme aux CNR d'Industrie Canada applicables aux appareils radioexempts de licence. L'exploitation est autorise aux deux conditions suivantes : (1) l'appareilne doit pas produire de brouillage, et (2) l'utilisateur de l'appareil doit accepter tout brouillage radiolectrique subi, mme si le brouillage est susceptible d'en compromettre lefonctionnement. Cet quipement est conforme aux limites dexposition aux rayonnements IC tablies pour unenvironnement non contrl. Dclarationd'expositionauxradiations:
Leproduitestconformel'expositionRFICpourletransfertdepuissancesansfildeconsommateursdefaible puissance.Lalimited'expositionRFfixepourunenvironnementnoncontrlestsansdangerpourle fonctionnementprvutelquedcritdanscemanuel.L'expositionRFsupplmentairequelaconformitat dmontre20cmetplusdesparationducorpsdel'utilisateuroudemettrel'appareillapuissancedesortie infrieuresiunetellefonctionestdisponible. MEXICO ONLY - Mexico IFT-008-SCFI-2015 / NOM-208-SCFI-2016 La operacin de este equipo est sujeta a las siguientes dos condiciones:
1. Es posible que este equipo o dispositivo no cause interferencia perjudicial. 2. Este equipo debe aceptar cualquier interferencia, incluyendo la que pueda causar su operacin no deseada. Singapore ONLY Singapore Complies with IMDA Standards DB107406 Note: The IMDA label size need to be 17mm by 9mm 366 OWNER'S MANUAL The Ministry of Land, Infrastructure, and Transport (MOLIT) ensures that new vehicles conform to recommended Vehicle Interior Air Quality (VIAQ) standards. Tesla performs tests on the interior air quality of your Your vehicle to ensure that the quality conforms to VIAQ standards. When you purchase your new Your vehicle, Tesla recommends that you ventilate the cabin before you drive. For details on ventilating the cabin, refer to the Owner's Manual. Vehicle Interior Air Quality CHINA ONLY - China CMIIT IDs:
HomeLink: 2016DJ6564 Key Fob: XXXXXXXXXX UAE ONLY - UAE Key Fob:
TRA REGISTERER No: ERXXXXXXXX DEALER No: ER62616/18 Key Fob:
TPMS:
TAIWAN ONLY - Device Approval - Taiwan For 2.4G and 5G Devices Consumer Information 367 Wireless Phone Charger
: WC4
:DC 5 V 15 W x 2
: DC 13.5 V , 4 A 6 11 6
: -40 ~55 AUS/NZ ONLY - Device Approval - Australia, New Zealand 368 OWNER'S MANUAL Bulgarian Croatian Czech Danish Dutch ALL REGIONS EXCEPT NORTH AMERICA AN CHINA - EU The devices described previously have been evaluated against the essential requirements of the 2014/53/EU and 2011/65/EU Directive. Tesla Inc. , CarPC and PASSIVE ENTRY SYSTEM I 2014/53/EC. Ovime Tesla Inc. , izjavljuje da je ovaj KEY FOB and PASSIVE ENTRY SYSTEM je u skladu s osnovnim zahtjevima i drugim relevantnim odredbama Direktive 2014/53/EU. Tesla Inc. tmto prohlauje, e tento CarPC and PASSIVE ENTRY SYSTEM je ve shod se zkladnmi poadavky a dalmi pslunmi ustanovenmi smrnice 2014/53/EU. Undertegnede Tesla Inc. erklrer herved, at flgende udstyr CarPC and PASSIVE ENTRY SYSTEM overholder de vsentlige krav og vrige relevante krav i direktiv 2014/53/EU.. Hierbij verklaart Tesla Inc. dat het toestel CarPC and PASSIVE ENTRY SYSTEM in overeenstemming is met de essentile eisen en de andere relevante bepalingen van richtlijn 2014/53/EU. Finnish French Italian Latvian English Hereby, Tesla Inc., declares that this CarPC and PASSIVE ENTRY SYSTEM is in compliance with the essential requirements and other relevant provisions of Directive 2014/53/EU. Estonian Kesolevaga kinnitab Tesla Inc. seadme CarPC and PASSIVE ENTRY SYSTEM vastavust direktiivi 2014/53/EL phinuetele ja nimetatud direktiivist tulenevatele teistele asjakohastele stetele. German Hiermit erklrt Tesla Inc., dass sich das Gert CarPC and PASSIVE ENTRY SYSTEM in bereinstimmung mit den grundlegenden Anforderungen und den brigen einschlgigen Bestimmungen der Richtlinie 2014/53/EU befindet. Greek Tesla Inc. CarPC and PASSIVE ENTRY SYSTEM 2014/53/EU. Hungarian Alulrott, Tesla Inc. nyilatkozom, hogy a CarPC and PASSIVE ENTRY SYSTEM megfelel a vonatkoz alapvet kvetelmnyeknek s az 2014/53/EU irnyelv egyb elrsainak. Tesla Inc. vakuuttaa tten ett CarPC and PASSIVE ENTRY SYSTEM tyyppinen laite on direktiivin 2014/53/EU oleellisten vaatimusten ja sit koskevien direktiivin muiden ehtojen mukainen. Par la prsente Tesla Inc. dclare que l'appareil CarPC and PASSIVE ENTRY SYSTEM est conforme aux exigences essentielles et aux autres dispositions pertinentes de la directive 2014/53/UE.. Icelandic Hr me lsir Tesla Inc. yfir v a CarPC and PASSIVE ENTRY SYSTEM er samrmi vi grunnkrfur og arar krfur, sem gerar eru tilskipun 2014/53/ ESB. Con la presente Tesla Inc. dichiara che questo CarPC and PASSIVE ENTRY SYSTEM conforme ai requisiti essenziali ed alle altre disposizioni pertinenti stabilite dalla direttiva 2014/53/UE. Ar o Tesla Inc. deklar, ka CarPC and PASSIVE ENTRY SYSTEM atbilst Direktvas 2014/53/ES btiskajm prasbm un citiem ar to saisttajiem noteikumiem. Lithuanian iuo Tesla Inc. deklaruoja, kad is CarPC and PASSIVE ENTRY SYSTEM atitinka esminius reikalavimus ir kitas 2014/53/ES Direktyvos nuostatas. Maltese Hawnhekk, Name of Manufacturer, jiddikjara li dan CarPC and PASSIVE ENTRY SYSTEM jikkonforma mal-
tiijiet essenzjali u ma provvedimenti orajn relevanti li hemm fid-Dirrettiva 2014/53/UE. Norwegian Tesla Inc. erklrer herved at utstyret CarPC and PASSIVE ENTRY SYSTEM er i samsvar med de grunnleggende krav og vrige relevante krav i direktiv 2014/53/EU. Polish Niniejszym Tesla Inc. owiadcza, e CarPC and PASSIVE ENTRY SYSTEM jest zgodny z zasadniczymi wymogami oraz pozostaymi stosownymi postanowieniami Dyrektywy 2014/53/UE. Portuguese Tesla Inc. declara que este CarPC and PASSIVE ENTRY SYSTEM est conforme com os requisitos essenciais e outras disposies da Directiva 2014/53/UE. Slovak Tesla Inc. tmto vyhlasuje, e CarPC and PASSIVE ENTRY SYSTEM spa zkladn poiadavky a vetky prslun ustanovenia Smernice 2014/53/E. Slovenian Tesla Inc. izjavlja, da je ta CarPC and PASSIVE ENTRY SYSTEM v skladu z bistvenimi zahtevami in ostalimi relevantnimi doloili direktive 2014/53/EU. Consumer Information 369 Spanish Por medio de la presente Tesla Inc. declara que CarPC and PASSIVE ENTRY SYSTEM cumple con los requisitos esenciales y cualesquiera otras disposiciones aplicables o exigibles de la Directiva 2014/53/UE. Sweden Hrmed intygar Tesla Inc. att denna CarPC and PASSIVE ENTRY SYSTEM str I verensstmmelse med de vsentliga egenskapskrav och vriga relevanta bestmmelser som framgr av direktiv 2014/53/EU. 370 OWNER'S MANUAL
| 1 2 3 | ID Label/Location Info | 71.83 KiB | May 27 2021 / June 03 2021 |
ce AE | 211-XXXXXX
| XXXXXXXXXXXXX [G -Tsa-1616631 TESLA INC NOM ey Model Number: 1616631 "*
FCC ID: 2AEIM-1616631 IC: 20098-1616631 CAN ICES-3 (B)/NMB-3(B) CMIIT ID: XXXXXXXXXX TRA REGISTERER No: ERXXXXXXXX DEALER No: DA68835/17 LABEL LOCATION
| 1 2 3 | Agency Authorization Letter | Cover Letter(s) | 88.80 KiB | August 12 2022 / August 30 2022 |
WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6055474.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Federal Communications Commission Office of Engineering & Technology Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Via Electronic Filing Date: April 28, 2021 Re: Authorized Personnel for Grantee Code 2AEIM To Whom It May Concern:
I currently serve as Tesla, Incs (Tesla) grantee contact (Grantee Code 2AEIM) for Federal Communications Commission (FCC) equipment authorizations. As prescribed in KDB 852134 Authorized Policy Form 731, I authorize the following personnel to act on Teslas behalf with regard to all matters that relate to FCC equipment authorization (i.e., signing Form 731, attestation letters, and confidentiality request letters). These individuals also are authorized to assign additional persons to act on Teslas behalf as authorized agents. Authorized Personnel:
Peng Zhang Cindy Li This authorization is valid until further written notice from any of Teslas authorized grantee contacts. Sincerely Yours, Sean Lui Sr. Staff Charging Compliance Engineer 3500 Deer Creek Road, Palo Alto, California US 94304 Phone: (650)681-5109 slui@teslamotors.com Tesla, Inc. 3500 Deer Creek Road, Palo Alto, CA 94304 p +650 681 5100 f +650 681 5101
| 1 2 3 | C2PC Letter | Cover Letter(s) | 373.14 KiB | August 12 2022 / August 30 2022 |
WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6055475.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Tesla, Inc. 3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Class II Change Letter Date: 2022/7/26 Federal Communications Commission 7435 Oakland Mills Road Columbia MD 21046 To Whom It May Concern:
Request for Class II Permissive Change FCC ID: 2AEIM-1616631 / Grant Date: 06/03/2021 Pursuant to CFR 2.1043, Tesla, Inc. hereby requests a Class II Permissive Change. Modification:
1. Adding Ferrite Bead on Input power trace VBAT_12V 2. Moving Test point TP53 on Bottom layer for QR code space 3. Increasing PMIC trace width same as pad width 4. Changing L2 clearance to 8mil 5. Removing some tiny GND pouring traces 6. Depopulating shield fence 7. Updating stack up layer thickness 8. Adding special etching tolerance region illustration for RF signals 9. Replacing the top layer layout with the top layer layout to solve the TX antenna pattern notch issue.TX antenna is moved towards left by 0.2mm 10. Changing firmware version to V-INRA_AWR-TES-0203 Note:
1. There is no any software that can be modified by end-user. Respectfully, Applicants company name
: Tesla, Inc. Applicants company address Signature
3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Name and Job Title
: Peng Zhang / Sr Certification Engineer E-Mail Tel
: pengzhang@tesla.com
: 510 213 1367
| 1 2 3 | Confidentiality Request | Cover Letter(s) | 406.33 KiB | August 12 2022 / August 30 2022 |
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Long Term Confidentiality Pursuant to Sections 0.457 and 0.459 of the Commissions Rules, we hereby respectfully request confidential treatment of information accompanying this application as outlined below:
Schematics The above materials contain trade secrets and proprietary information not customarily released to the public. The public disclosure of these matters might be harmful to the Applicant and provide unjustified benefits to its competitors. We understand that pursuant to Rule 0.457, disclosure of this Application and all accompanying documentation will not be made before the date of the Grant for this application. Respectfully, Applicants company name
: Tesla, Inc. Applicants company address Signature
3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Name and Job Title
: Peng Zhang / Sr Certification Engineer E-Mail Tel
: pengzhang@tesla.com
: 510 213 1367
| 1 2 3 | Power of Attorney Letter | Cover Letter(s) | 372.82 KiB | August 12 2022 / August 30 2022 |
WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6055482.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Tesla, Inc. 3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Power of Attorney Date: 2022/7/26 Dear Sir, I hereby have entrusted the following person to be a proxy regarding application for Type Certification. Sporton International Inc. Hsinchu Laboratory Address
: No.8, Lane 724, Bo-ai St., Jhubei City, HsinChu County 302, Taiwan, R.O.C. Name
Leo Huang Job Title
: Manager e-mail
Leohuang@sporton.com.tw I am therefore responsible for the contents of the application. FCC ID: 2AEIM-1616631 Respectfully, Applicants company name
: Tesla, Inc. Applicants company address Signature
3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Name and Job Title
: Peng Zhang / Sr Certification Engineer E-Mail Tel
: pengzhang@tesla.com
: 510 213 1367
| 1 2 3 | Pro Installation Declaration | Cover Letter(s) | 384.32 KiB | August 12 2022 / August 30 2022 |
WARNING:pdfminer.pdfpage:The PDF <_io.BufferedReader name='/Volumes/Scratch/Incoming/eg-scratch/6055483.pdf'> contains a metadata field indicating that it should not allow text extraction. Ignoring this field and proceeding. Use the check_extractable if you want to raise an error in this case Tesla, Inc. 3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Professional Installation Declaration Date: 2022/7/26 FCC ID2AEIM-1616631 To Whom It May Concern:
Please be advised that due to the unique Market and function targeted by this product, this product will need special trained professional in configuring and installing the product. We hereby declare that the product will be distributed through controlled distribution channel which has special trained professional to install this product and will not be sold directly to the general public through retail store. Respectfully, Applicants company name
: Tesla, Inc. Applicants company address Signature
3500 Deer Creek Road Palo Alto, California US 94304 United States Of America Name and Job Title
: Peng Zhang / Sr Certification Engineer E-Mail Tel
: pengzhang@tesla.com
: 510 213 1367
| 1 2 3 | Authorized Signature | Cover Letter(s) | 155.17 KiB | May 27 2021 / June 03 2021 |
Federal Communications Commission Office of Engineering & Technology Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Via Electronic Filing Date: Oct 3, 2019 Re: Authorized Personnel for Grantee Code 2AEIM To Whom It May Concern:
I currently serve as Tesla, Incs (Tesla) grantee contact (Grantee Code 2AEIM) for Federal Communications Commission (FCC) equipment authorizations. As prescribed in KDB 852134 Authorized Policy Form 731, I authorize the following personnel to act on Teslas behalf with regard to all matters that relate to FCC equipment authorization (i.e., signing Form 731, attestation letters, and confidentiality request letters). This (these) individual(s) also is (are) authorized to assign additional persons to act on Teslas behalf as authorized agents. Authorized Personnel:
Peng Zhang Sincerely Yours, This authorization is valid until further written notice from any of Teslas authorized grantee contact(s). Sean Lui Sr. Staff Charging Compliance Engineer 3500 Deer Creek Road, Palo Alto, California US 94304 Phone: (650)681-5109 slui@teslamotors.com Tesla, Inc. 3500 Deer Creek Road, Palo Alto, CA 94304 p +650 681 5100 f +650 681 5101
| 1 2 3 | Confidentiality Letter | Cover Letter(s) | 96.75 KiB | May 27 2021 / June 03 2021 |
FCC Confidential Authorization 2021-01-07 FEDERAL COMMUNICATIONS COMMISSIONS Authorization and Evaluation Division 7435 Oakland Mills Road Columbia, MD 21046 Subject: Confidentiality Request regarding application for certification of FCC ID: 2AEIM-1616631 In accordance with Sections 0.457 and 0.459 of the Commissions Rules, Tesla Motors, Inc hereby requests long-term confidential treatment of information accompanying this application as outlined below:
As well as short-term (180 days) confidential treatment of information accompanying this application as outlined below:
Block Diagram Schematics Operation Description Internal Photos Users Manual External Photos Test Set-up Photos The above materials contain proprietary and confidential information not customarily released to the public. The public disclosure of these materials provides unjustified benefits to its competitors in the market. Sincerely, Simon Ma RF Supervisor 1274 Anvilwood Ave., Sunnyvale, CA 94089, USA QA-FR-172-A
| 1 2 3 | Power of Attorney Letter | Cover Letter(s) | 19.70 KiB | May 27 2021 / June 03 2021 |
Agent Power of Attorney 2021-01-07 Subject: Agent Authorization To whom it may concern:
We Tesla, Inc , the undersigned, Hereby authorizes Bay Area Compliance Laboratory Corporation to act on its behalf in all matters relating to application for Equipment authorization, including the signing of all documents relating to these matters. All acts carried out by Bay Area Compliance Laboratory Corporation on our behalf shall have the same effect as our own action. This authorization apply to below six products only:
Product name Vehicle Millimeter-wave Radar Sensor Model Name 1616631 This authorization is valid until further written notice from the applicant. Sincerely Yours, Peng Zhang Certification Engineer Tesla Motors, Inc 3500 Deer Creek Road, Palo Alto, CA 94304, USA QA-FR-206-A 6/21/2016
| 1 2 3 | Setup Photos | Test Setup Photos | 828.03 KiB | May 27 2021 / November 30 2021 | delayed release |
| 1 2 3 | Waiver DA 21-407 | Cover Letter(s) | 181.00 KiB | May 27 2021 / June 03 2021 |
Federal Communications Commission DA 21-407 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Vayyar Imaging Ltd. Request for Waiver of Section 15.255(c)(3) of the Commissions Rules for Radars used for Interactive Motion Sensing in the frequency band 57-64 GHz Valeo North America Inc. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for In-Vehicle Radar Operation in the frequency band 57-64 GHz Infineon Technologies Americas Corp. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for Short-Range Interactive Motion Sensors for In-Vehicle Radar Operation in the frequency band 57-64 GHz Tesla Inc. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for Short-Range Interactive Motion Sensors for Vehicle Radar Operation in the frequency band 60-64 GHz IEE Sensing Inc. Request for Waiver of Sections 15.255(c)(2) and (c)(3) of the Commissions Rules for Vehicle Radar Operation in the frequency band 60-64 GHz Brose North America Inc. Request for Waiver of Section 15.255(c)(3) of the Commissions Rules for Vehicle Radar Operation in the frequency band 57-64 GHz
) ET Docket No. 20-15 ET Docket No. 20-121 ET Docket No. 20-263 ET Docket No. 20-264 ET Docket No. 20-435 ET Docket No. 20-434 ORDER Adopted: April 14, 2021 Released: April 14, 2021 By the Acting Chief, Office of Engineering and Technology:
I. INTRODUCTION 1. By this action, we are waiving the requirements of sections 15.255(a)(2) and 15.255(c)(3) of our rules,1 subject to certain conditions, to allow Vayyar Imaging Ltd. (Vayyar), Valeo North America Inc. (Valeo), Infineon Technologies Americas Corp. (Infineon), Tesla Inc. (Tesla), IEE Sensing Inc. (IEE 1 47 CFR 15.255(a)(2) & (c)(3). Federal Communications Commission DA 21-407 Sensing), and Brose North America Inc. (Brose) to operate radars in the 57-64 GHz frequency band in passenger motor vehicles2 to perform detection of children inadvertently left in hot weather and other related passenger safety functions at higher power levels than specified in the rule.3 We find that grant of these waivers, along with specific conditions that take into account our coordination with the National Telecommunications and Information Administration Office of Spectrum Management on behalf of the federal agencies through the Interdepartment Radio Advisory Committee, will bring immediate relief to the industry and the public in this area. Specifically, our action will bring forth substantial public benefits by improving vehicular safety for children and providing opportunities for additional vehicular automation and theft prevention applications without increasing the potential for harmful interference to authorized users in the band. II. BACKGROUND 2. The Commission received the six waiver requests described herein,4 all of which propose radar operation in either the 57-64 GHz band or a subset of this band (i.e., the 60-64 GHz band), on an unlicensed basis under Part 15 of the rules.5 With certain differences, all requests have one common purpose: to provide vehicular passenger safety and theft prevention applications when the radar is installed inside passenger motor vehicle cabins with the primary function to prevent risks of children inadvertently left unattended in a rear seat in hot weather. The requesters claim that these applications require higher power levels than our rules permit. Along with the child-left-unattended application, an in-
cabin radar can support additional vehicle-related functions. 3. The Part 15 rules are designed to permit low-power devices to operate without an individual license where such use is not anticipated to cause harmful interference to authorized users of the radio spectrum.6 Section 15.255 of the rules stipulates operational policies and technical parameters for the 57-71 GHz band.7 Unlicensed devices in this band generally include indoor communication 2 By passenger motor vehicle we mean a passenger car (a motor vehicle with motive power, except a low-speed vehicle, multipurpose passenger vehicle, motorcycle, or trailer, designed for carrying 10 persons or less) or a multipurpose passenger vehicle (a motor vehicle with motive power, except a low-speed vehicle or trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation) that has more than one row of seats, as those terms are used by the National Highway Traffic Safety Administration at 49 CFR 571.3. 3 See Vayyar Imaging Ltd. Waiver Request, filed Nov. 13, 2019; Valeo North America, Inc. Waiver Request, filed Mar. 31, 2020; Infineon Technologies Americas Corp. Waiver Request, filed July 23, 2020; Tesla, Inc. Waiver Request, filed July 31, 2020; IEE Sensing Inc. Waiver Request, filed Nov. 16, 2020; and Brose North America, Inc. Waiver Request, filed Nov. 25, 2020. 4 The Commission has received additional waiver requests that relate to unlicensed use of the 57-65 GHz band (or a subset thereof). See, e.g., Husqvarna AB Request for Waiver of 47 CFR 15.255(c)(3) for Collision Avoidance Radars (filed Dec. 8, 2020); Acconeer AB Request for Waiver of 47 CFR 15.255(c)(3) (filed Dec. 23, 2020);
Faurecia Clarion Electronics North America Petition for Declaratory Ruling and Request for Waiver of 47 CFR 15.255(c)(3) (filed Jan. 20, 2021). We intend to consider these requests separately and do not address them further here. 5 47 CFR 15.1 et seq. 6 The fundamental operating conditions under Part 15 are that the operator of a Part 15 device must accept whatever interference is received and must correct whatever harmful interference it causes. Should harmful interference occur, the operator is required to immediately correct the interference problem, even if correction of the problem requires ceasing operation of the Part 15 equipment causing interference. See 47 CFR 15.5. 7 47 CFR 15.255. See Revision of Part 15 of the Commissions Rules Regarding Operation in the 57-64 GHz Band, ET Docket No. 07-113, FCC 13-112, Report and Order, 28 FCC Rcd 12517 (2013). The rules were further amended in 2016 to specifically permit certain types of field disturbance sensors. See Use of Spectrum Bands Above
(continued.) 2 Federal Communications Commission DA 21-407 networking devices such as WiGig,8 outdoor fixed point-to-point communication links,9 and field disturbance sensors (FDS) (e.g., radars)10 that are either in fixed installations, or used as short-range devices for interactive motion sensing (SRIMS). A fixed FDS operating under the provisions of section 15.255(c)(2) is permitted to operate with average output power levels up to +40 dBm and peak output power levels up to +43 dBm but its occupied bandwidth must be fully contained within the 61.0-
61.5 GHz band. For all other fixed FDS and SRIMS devices, section 15.255(c)(3) specifies that the peak transmitter conducted output power shall not exceed -10 dBm and the peak EIRP level shall not exceed
+10 dBm.11 4. In adopting the section 15.255 rules, the Commissions original intent was to foster the potential of the 60 GHz band for allowing the development of short-range wireless radio systems with communications capabilities approaching those achievable only with coaxial' and optical fiber cable.12 It is for this reason that section 15.255 has historically prohibited general mobile radar operation. In 2016, upon permitting short-range interactive motion sensing (SRIMS) despite the section 15.255 general prohibition on mobile radar operation, the Commission noted that it did not have sufficient information to allow for general operation of all mobile radars in the 60 GHz spectrum, but was nonetheless prepared to allow the narrow application of mobile radars for short-range interactive motion sensing but at reduced power levels to prevent harmful interference to authorized users.13 The Commission did not adopt a definition for SRIMS but intended it as a narrow application of the rules that would support technology such as that being developed by Google LLC (Google) under the Soli tradename which would allow the user of a smartphone or similar hand-held devices to control web pages opening and closing, or answering a call with hand gestures when the user is located at a short distance from the phone.14 5. Subsequently, in 2018, Google requested a waiver of the emission limits imposed on Soli by the 2016 rulemaking.15 It proposed to allow the radar to operate at a higher output power level than what had been authorized in the rulemaking.16 In granting that waiver, which was limited to use of the Soli sensor as described in Googles request, we permitted Google to deploy its Soli sensor technology to
(Continued from previous page) 24 GHz For Mobile Radio Services, GN Docket No. 14-117, FCC 16-89, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 8014 (2016). 8 See Wi-Fi Alliance, Wi-Fi Certified WiGig, http://www.wi-fi.org/discover-wi-fi/wigig-certified. 9 See e.g., http://www.airlinx.com; https://www.ignitenet.com/technology/metrolinq/. 10 The Commission has a long history of considering radar devices in Part 15 of the rules as a subset of FDS. See e.g., 47 CFR 15.503 & 15.515. The devices in the Instant Order will be referred to as a radar or sensor. 11 47 CFR 15.255(c)(3). 12 Amendment of Parts 2, 15 and 97 of the Commissions Rules to Permit Use of Radio Frequencies Above 40 GHz for New Radio Applications, ET Docket No. 94-124, First Report and Order and Second Notice of Proposed Rule Making, 11 FCC Rcd. 4481, 4488 (1995) at para. 14. 13 Use of Spectrum Bands Above 24 GHz For Mobile Radio Services, GN Docket No. 14-177, Report and Order and Further Notice of Proposed Rulemaking, FCC 16-89, 31 FCC Rcd 8014, 8133-8134, at para. 337 (2016). 14 Google developed the Soli sensor to capture motion in a three-dimensional space using a radar beam, which enables persons to use gestures and motions to control a smartphones functions or features. See https://atap.google.com/soli. 15 Google LLC Request for Waiver of Section 15.255(c)(3) of the Commission's Rules Applicable to Radars used for Short Range Interactive Motion Sensing in the 57-64 GHz Frequency Band, Order, DA 18-1308, 33 FCC Rcd 12542
(2018). 16 Id. Google stated that the higher power levels were necessary for the Soli device to provide sufficient resolution. 3 Federal Communications Commission DA 21-407 enable touchless control of device functions or features (such as its Pixel phone) at +10 dBm peak transmitter conducted output power, +13 dBm peak EIRP level, and +13 dBm/MHz peak power spectral density, with a 10% duty cycle in any 33 milliseconds (ms) interval. Because the Google Soli is integrated within a Google mobile phone, which can be carried by air travelers, Google also received a waiver of section 15.255(b)(2) to operate the device on-board aircraft without being part of the aircraft internal communication network.17 6. In granting the waiver to Google for operation of its Soli device at higher power levels than specified in the rules, we considered the particular use environment in which Googles devices would be operated. We noted that Googles submission of supportive studies regarding Solis co-
existence with other users in the 57-64 GHz band inspired confidence that all users of the 57-64 GHz band will be able to operate without experiencing harmful interference.18 While the 57-64 GHz band is allocated on a co-primary basis to the Federal Mobile, Fixed, Inter-Satellite and Radiolocation services and to non-Federal Fixed, Mobile and Radiolocation services, Passive Earth-Exploration-Satellite Service
(EESS) users in particular expressed concern about the Google Solis operation on-board aircraft.19 All of the pending waiver requests, as discussed below, are asking to operate radars specifically for automotive in-cabin applications at the same higher power levels that were granted to Google in 2018.20 III. WAIVER REQUESTS 7. As indicated above, all pending waiver requests share a common element: operation on passenger motor vehicles to provide passenger safety functions, especially the ability to detect a child inadvertently left unattended on the rear seat of a hot car. Parties most prominently describe the risks associated with forgotten children in unattended vehicles and cite an automobile industry commitment to provide a widely deployed rear seat reminder no later than the 2025 model year.21 The parties further envision that their proposed devices would provide other automated vehicular functions, such as passenger presence detection, seatbelt alarm/airbag deployment, driver inattention detection, and vehicle intrusion detection. Each of the parties request to operate their respective radars at the same power levels and duty cycle we granted to Google in the 2018 waiver (i.e., +13 dBm EIRP, +13 dBm/MHz power spectral density and 10% duty cycle). We describe each of the waiver requests and the comments received in their respective dockets below. Vayyar Imaging Ltd. (Vayyar) Waiver Request A. 8. On November 13, 2019, Vayyar asked for waiver of section 15.255(c)(3) of the Commissions rules to obtain a grant of equipment authorization for its V60G radar module to permit operation in the 57-64 GHz frequency band.22 At that time, Vayyar asked for a waiver so that its radar 17 47 CFR 15.255(b)(2). See also supra para. 3. 18 Google LLC Request for Waiver of Section 15.255(c)(3) of the Commission's Rules Applicable to Radars used for Short Range Interactive Motion Sensing in the 57-64 GHz Frequency Band, Order, DA 18-1308, 33 FCC Rcd 12542, 12547 (2018), at para. 11. 19 47 CFR. 2.106. EESS operates in the 57-59.3 GHz sub-band for satellite-based remote sensing instruments to make important atmospheric, oceanic and land measurements of the Earth. 47 CFR. 2.106, Note 5.138. Industrial, scientific and medical (ISM) equipment may also operate in the band at 61.00-61.50 GHz, pursuant to 47 CFR 18.301. 20 The Google Soli device integrated in a smartphone could operate on-board aircraft, thus Google also received a waiver of 47 CFR. 15.255(a)(2). Because the devices subject to the instant waiver will all operate at ground level inside a vehicle, they do not require waiver of this section. 21 See https://www.nhtsa.gov/campaign/heatstroke; https://www.consumerreports.org/car-safety/auto-industry-
agrees-to-put-rear-seat-reminder-systems-in-most-new-cars-by-2025/. 4 Federal Communications Commission DA 21-407 could be used broadly in a variety of interactive products, including use on-board aircraft. It subsequently filed a Modified Waiver Request to narrow the scope of radar applications to only include: 1) in-home and medical imaging sensors and 2) in-vehicle safety applications.23 We are only addressing Vayyars requested vehicular use here and make no decision regarding Vayyars device for use in home and medical settings. Accordingly, that portion of Vayyars Modified Request remains pending. 9. Vayyar claims that the V60G is an interactive motion sensing device designed to operate under the same technical parameters (power and duty cycle limits) as the Google Soli sensor for which the Commission has previously granted a waiver. In support of its request, Vayyar asserts that the V60G will generate an identical spectrum footprint as the Google Soli sensor and will coexist with other spectrum users in the 57-64 GHz band in the same manner as does the Soli sensor. It asks the Commission to evaluate the V60G based on a general interference simulation study that Google submitted in its waiver request.24 Vayyar states that the V60G is intended to be installed inside vehicle cabins to provide various passenger safety applications, including detecting a child left unattended in a hot car.25 10. Vayyar describes the V60G devices as MIMO26 radars with an array consisting of 20 transmit and 20 receive antennas, configured to provide azimuth and elevation resolution, resulting in 400 possible signal paths, which provides greater signal spatial resolution than the Google Soli.27 Vayyar states that the wideband signals provide distance resolution for 3D imaging capability, while Doppler28 processing identifies object motion and small displacements.29 Vayyar claims that the V60G technology has the ability to detect respiration via chest movement which permits it to discriminate between people and inanimate objects, to limit system response to people only conditions, to provide accurate discrimination of seat occupancy (e.g., child vs. groceries) and to improve the efficiency of seatbelt reminder systems.30 11. The Office of Engineering and Technology (OET) issued a Public Notice soliciting comments on the Vayyar Request on Jan. 14, 2020.31 Two parties filed individual comments32 and an
(Continued from previous page) 22 Vayyar Imaging Ltd. Request for Waiver of Section 15.255(c)(3) of the Commissions Rules for Radars used for Interactive Motion Sensing in the frequency band 57-64 GHz (filed Nov. 13, 2019) (Vayyar Request). 23 Vayyar Imaging Ltd. Modification of Request for Limited Waiver, filed May 5, 2020 (Vayyar Modified Request). 24 Vayyar Request at 2. The Google studies and simulations were filed March 8, 2018 and Oct. 12, 2018 in ET Docket No. 18-70. See https://ecfsapi.fcc.gov/file/10307158658894/2018-03-
07%20Soli%20Request%20for%20Waiver%20%2B%20Simulation%20Study.pdf, and https://ecfsapi.fcc.gov/file/101213308029/2018-10-
12%20Google%20Letter%20re%20Project%20Soli%20%2B%20Studies%20(ET%2018-70).pdf. 25 Vayyar Modified Request at 4-6. 26 MIMO (multiple-input and multiple-output) is a method for enhancing the capacity of a radio link using multiple transmission and receiving antennas. 28 The Doppler effect is the change in frequency of a wave as the wave source and an observer move towards or away from each other. 27 Vayyar Request at 5. 29 Vayyar Request at 2. 30 Vayyar Request at 6-7. 31 See OET Seeks Comment on Vayyar Imaging Ltd. Request for Waiver of Sections 15.255(b)(2) and (c)(3) of the Commission Rules for Radars used for Interactive Motion Sensing in the 57-64 GHz band, ET Docket No. 20-15, Public Notice, DA 20-68, 35 FCC Rcd 500 (2020). 32 Joe Gytrock and IEE Sensing filed individual comments. 5 Federal Communications Commission DA 21-407 additional comment (Joint Comment) was filed by a group of seven parties.33 Vayyar filed reply comments. 12. Comments. IEE Sensing states that the FCC should consider more broadly any necessary changes to its rules for both the 57-64 GHz and the 77-81 GHz bands that would allow life-saving devices to operate, rather than simply proceeding on an individual case-by-case waiver approach.34 The Joint Comment encourages the Commission to commence a comprehensive rulemaking proceeding to: (i) promote future applications, services, and devices in the 60 GHz band, and (ii) address the range of technical and policy issues necessary to preserve reasonable coexistence between radars/FDS, with higher power levels than currently permitted, and other users of the 60 GHz band.35 One commenting party, Joe Gytrock, opposes the waiver by disputing Vayyars technical claim that the V60G provides an identical interference footprint to the Google Soli.36 Gytrocks arguments and Vayyars responses are discussed, infra.37 All other parties support the request. Valeo North America Inc. (Valeo) Waiver Request B. 13. On March 31, 2020, Valeo filed a request for waiver of section 15.255(c)(3) of the Commissions rules to allow Valeo to obtain equipment certification for radar sensing devices operating in the 57-64 GHz band at a higher power than specified in the rule.38 Valeo requests to operate its radar at the same technical conditions as specified in the waiver we granted to Google in 2018.39 Valeo states that its sensors will be installed in a vehicles interior roof, behind the headliner40 and will issue an alert whenever a child is left behind. Valeo states that its sensors also could be used for other passenger safety functionalities such as seat belt reminders and decision criteria for airbag deployments based on seating position and occupant size (e.g. child versus adult).41 14. Valeo describes that its radars modulation consists of consecutive frames, including an acquisition sequence comprised by a repetition of frequency chirps or stepped chirps. The acquisition sequence is followed by idle time where antennas are not transmitting. The frequency chirps will span over the 57-64 GHz band. For each acquisition sequence, the number of chirps and chirp duration can be 33 Seven parties (Facebook Inc., Google LLC, Infineon Technologies, Intel Corporation, Qualcomm Incorporated, Samsung Electronics America, Socionext America) filed a joint comment (filed Feb. 3, 2020) (Joint Comment). These parties were joined by Continental Automotive Gmbh, Texas Instruments Inc., and Vayyar Imaging Ltd, in a 10-party ex parte filing (filed Jul.1, 2020) with essentially the same content. 34 Comments of IEE Sensing at 3. 35 Joint Comment at 2. 36 See filings by Joe Gytrock filed Mar. 10, Jun. 2, and Aug. 3, 2020; and responses of Vayyar filed Mar. 19 and Jun. 17, 2020 in ET Docket No. 20-15. See also, Vayyars Apr. 28, 2020 ex parte filing, titled Comparison of V60G and Soli Interference Footprints. 37 See discussion infra at paras. 43-44. 38 Valeo North America Inc. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for In-Vehicle Radar Operation in the frequency band 57-64 GHz (filed Mar. 31, 2020) (Valeo Request). Valeo did not originally ask for waiver of 47 CFR 15.255(a)(2) because it considered its device a SRIMS. It later decided to request waiver of this section should the Commission decide the device is not a SRIMS but a general mobile radar, which would be prohibited under this section. Valeo ex parte (filed Oct. 29, 2020). 40 The headliner is the material that is adhered to the vehicle cabins inside roof. 39 Valeo Request at 3. 41 Valeo Request at 3. 6 Federal Communications Commission DA 21-407 adjusted depending on the speed of the objects to be detected so that the total duty cycle that will be no greater than 10%.42 15. OET issued a Public Notice soliciting comments on the Valeo Request on May 7, 2020.43 The Commission also sought comment on whether Valeos sensors, under the described application, could be operated as a SRIMS under section 15.255(a)(2) of the rules. Although Valeo did not ask for a waiver of this rule, the Commission raised the issue because its application differs from Googles in that detecting a child left in a vehicle is not the same as detecting hand gestures and movements associated with interactions between a user and a personal device such as a smartphone. Valeo subsequently requested waiver of section 15.255(a)(2) to the extent its device would not comply with the SRIMS requirement. 44 16. Comments. Nine comments were submitted45 and Valeo filed reply comments. All parties support of Valeos waiver request. With respect to qualification as a SRIMS, Brose, Infineon and Texas Instruments (TI) state their belief that Valeos application for in-car sensing qualifies as SRIMS.46 Vayyar Imaging Ltd. (Vayyar) argues that applications such as those described by Valeos do not require a waiver to qualify as SRIMS.47 Wiley Rein LLP (Wiley) states that the Commission should clarify that interactive motion sensing includes the use of a field disturbance sensor to: (1) permit a person to control a device; (2) enable the control of a device by the device interacting with its environment; or (3) allow a device to monitor a person by the person interacting with the device.48 C. 17. Infineon Technologies Americas Corp. (Infineon) Waiver Request On July 23, 2020, Infineon filed a request for waiver of section 15.255(c)(3) of the Commissions rules to allow Infineon to market its BGT60 family of radar system-on-chip (SoC) modules.49 Infineon indicates that its devices would be used for in-vehicle child safety systems and other in-cabin safety-related monitoring such as seatbelt reminders, airbag optimization, and drivers health and attention alerting.50 In particular, Infineon describes the risks of inadvertently leaving children in hot vehicles.51 Like other parties, Infineon requests to operate its devices at higher power than specified in 42 Valeo Request at 5. In its original request, Valeo asked to operate its radar with a duty cycle identical to the Google Soli, i.e., no more than 3.3 ms transmission time in each 33 ms time period; however, in its reply comments, Valeo modified this request to ask for a 16 ms transmission time in each 160 ms time period, to cover multi-sensor situations. Valeo Reply at 5. Subsequently, Valeo agreed that as long as the duty cycle is imposed on a per-radar-
basis, its device can comply with the 3.3 ms duty cycle. Valeo ex parte (filed Dec. 7, 2020). 43 OET Seeks Comment on Valeo North America Inc. Request for Waiver of Section 15.255(c)(3) of the Commissions Rules for In-Vehicle Radar Operation in the 57-64 GHz band, ET Docket No. 20-121, Public Notice, DA 20-486, 35 FCC Rcd 4582 (2020). 44 Valeo ex parte (filed Oct. 29, 2020). 45 Acconeer AB, Alps Alpine Co. Ltd., Brose North America Inc., IEE Sensing, Infineon Technologies AG, Texas Instruments, Inc. (TI), Vayyar Imaging Ltd., and Wiley Rein LLP (Wiley) filed individual comments. Ten parties
(Facebook Inc., Google LLC, Infineon Technologies, Intel Corporation, Qualcomm Incorporated, Samsung Electronics America, Socionext America, Continental Automotive Gmbh, Texas Instruments Inc., and Vayyar Imaging Ltd.) filed a joint comment. 46 Comments of Brose at 1; comments of Infineon at 5; comments of TI at 1. 47 Comments of Vayyar at 3. 48 Comments of Wiley at 5. 50 Infineon Request at 5. 49 Infineon Technologies Americas Corp. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for Short-Range Interactive Motion Sensors for In-Vehicle Radar Operation in the frequency band 57-64 GHz (filed July 23, 2020) (Infineon Request). 7 Federal Communications Commission DA 21-407 our rules, under the same technical parameters as those we granted to Google in 2018.52 Infineon explains that it needs to operate the radar at higher power levels, because, depending on the installation within the vehicle cabin (e.g., the radar cross section of the target, random material, distance to the target, field-of-
view of the radar system), there could be several dB of losses in the link budget53 that have to be compensated with higher output power.54 18. Infineon asserts that the life-saving technology associated with Infineons BGT60 family of radars justifies granting its request in the near term rather than waiting for a lengthy rulemaking process to modify our rules, as has been suggested by commenters in similar waiver requests pending before the Commission.55 Infineon further requests that the waiver, if granted, clearly apply to BGT60 radars that will be certified under the rules as modular transmitters, or that are otherwise incorporated, without change, as components by Infineon or Infineons customers into other vehicular in-cabin devices or systems.56 19. OET issued a Public Notice soliciting comments on the Infineon Request on Aug. 20, 2020.57 Six parties filed comments58 and Infineon filed reply comments. All parties support the request. 20. Comments. ADC Automotive Distance Control Systems GmbH (ADC), Ficosa International (Ficosa), and Magna International (Magna) state that the 57-64 GHz band is the most suitable band for in-cabin safety technologies and that there is broad industry support for use of this band for in-cabin safety applications.59 Valeo and Ficosa believe that Infineons in-cabin applications qualify as SRIMS and does not need a waiver of 15.255(a)(2).60 Magna and MEAA fully support vehicle radar use in the 57-64 GHz frequency band.61 Tesla states that in-vehicle sensing devices have the potential to provide a number of significant safety and security benefits, including detecting children left unattended in hot cars, detecting seat occupancy for advanced airbag deployment and seatbelt reminders, monitoring driver health and engagement, enhancing theft prevention systems, and allowing for gesture recognition to control, for example, dashboard functions.62
(Continued from previous page) 51 Infineon Request at 6. 52 Id. at 3-4. We note that Infineon only seeks a waiver of 47 CFR 15.255(c)(3). Google also received a waiver of 47 CFR 15.255(b)(2), which restricts airborne operation; Infineons proposed applications are limited to in-cabin automotive passenger vehicles. Id. at 5. 53 A link budget is a design aid to determine all of the power gains and losses that a communication signal experiences in a telecommunication system; from a transmitter, through a medium (free space, cable, waveguide, fiber, etc.) to the receiver, to ensure that the information is received intelligibly. 54 Infineon Request at 7. 55 Infineon Request at 15-16. 56 Infineon Request at 6, n.19. 57 OET Seeks Comment on Infineon Technologies Americas Corp. Request for Waiver of Section 15.255(c)(3) of the Commission Rules for Short-Range Interactive Motion Sensors for In-Vehicle Radar Operation in the 57-64 GHz band, ET Docket No. 20-263, Public Notice, DA 20-897, 35 FCC Rcd 8815 (2020). 58 ADC Automotive Distance Control Systems GmbH (ADC), Ficosa International (Ficosa), Magna International
(Magna), Mitsubishi Electric Automotive America (MEAA), Tesla Inc., and Valeo North America, Inc. 59 Comments of ADC at 3; comments of Ficosa 1; comments of Magna at 1. 60 Comments of Valeo at 2; comments of Ficosa at 1. 61 Comments of Magna and MEAA at 1. 62 Comments of Tesla at 2. 8 Federal Communications Commission DA 21-407 Tesla Inc. (Tesla) Waiver Request D. 21. On July 31, 2020, Tesla filed a request for waiver of section 15.255(c)(3) of the Commissions rules to allow Tesla to obtain equipment certification for a radar operating in the 60-
-64 GHz band at a higher power than specified in the rule.63 Tesla indicates that its device would be focused on the vehicle interior for applications such as child presence detection and seatbelt reminders;
however, Tesla states that the device may be able to scan up to 2 meters (approximately 6 feet) outside of the vehicle, to provide vehicle security benefits such as detecting a broken window or a vehicle intrusion.64 Like other parties, Tesla seeks a waiver to operate under the same technical parameters as those we granted to Google in 2018.65 22. Tesla describes that its device will use 4 transmit and 3 receive antennas driven by a highly configurable radar front-end unit and in-vehicle radar modulation will consist of consecutive frames, including an acquisition sequence comprised by a repetition of frequency chirps or stepped chirps, a listening period, then a period for signal processing.66 23. OET issued a Public Notice soliciting comments on the Tesla Request on Aug. 20, 2020.67 As in the Public Notice for Valeo, supra, the Commission also sought comment on whether Teslas sensors, under the application as described could be operated as SRIMS under section 15.255(a)(2) of the rules. Six parties filed comments68 and Tesla and Infineon filed reply comments. All but one party support the request. 24. Comments. The Advocates for Highway and Auto Safety (Safety Advocates) state that the ability of a vehicle to detect and classify all occupants will likely be critical as autonomous vehicles
(AVs) are deployed onto our roads in the future becauseAVs will need to know the number of occupants and whether they are properly restrained before beginning to move.69 Valeo, Acconeer and TI agree that Teslas described applications qualify as SRIMS.70 Duncan Armour, the sole party opposing the petition, characterizes Teslas request as a trivial or edge-case use of radiofrequency (RF) energy 63 Tesla Inc. Request for Waiver of Sections 15.255(a)(2) and (c)(3) of the Commissions Rules for Short-Range Interactive Motion Sensors for Vehicle Radar Operation in the frequency band 60-64 GHz (filed July 31, 2020)
(Tesla Request). Tesla did not originally ask for waiver of 47 CFR 15.255(a)(2) because it considered its device to be a SRIMS. It later decided to request a waiver of this section should the Commission decide the device is not a SRIMS but a general mobile radar, which would be prohibited under this section. Tesla Reply Comments at 4-5. 64 Id. at 2-4. 65 Id. at 13. We note that Tesla only seeks a waiver of 47 CFR 15.255(c)(3). As discussed above, Googles receipt of a waiver of 47 CFR 15.255(b)(2) pertains to airborne operation, which is not relevant to Teslas use model. Id. at 3-4. 66 Tesla further states that the acquisition sequence is followed by idle time where antennas are not transmitting. The frequency chirps will span over the 60-64 GHz band and for each acquisition sequence, the number of chirps and chirp duration can be adjusted depending on system requirements so that the duty cycle will not exceed 10%. Tesla Request at 2-3. 67 See OET Seeks Comment on Tesla, Inc. Request for Waiver of Section 15.255(c)(3) of the Commission Rules for Short-Range Interactive Motion Sensors for Vehicle Radar Operation in the 60-64 GHz band, ET Docket No. 20-264, Public Notice, DA 20-898, 35 FCC Rcd 8818 (2020). 68 Acconeer AB, Alliance for Automotive Innovation (Auto Innovators), Texas Instruments (TI), Valeo North America, Inc., Duncan Armour, and Advocates for Highway and Auto Safety (Safety Advocates). Duncan Armours comment was filed in the Valeo docket, ET Docket No. 20-121, but is titled Comment on: Tesla Application and exclusively discusses Teslas waiver request. For this reason, we address it here. 69 Comments of Safety Advocates at 2. 70 Comments of Valeo at 2; comments of Acconeer at 1; comments of TI at 1. 9 Federal Communications Commission DA 21-407 that does not warrant approval, and speculates that [t]he request is likely to be for other surveillance purposes than the protection of cute vulnerable babies posited by Tesla.71 25. In reply comments, Tesla states that although it did not request waiver of Section 15.255(a)(2) for mobile radar operation in its request, it seeks a waiver of this section to the extent its device would not comply with the SRIMS requirement.72 Subsequently, in an ex parte letter, Tesla provided further explanations for the use cases requested for waiver. Tesla identifies some potential use caseschild detection, cabin intrusion, and exterior detectionfor which sensing would occur only while the vehicle is stationary; and other use casesoccupant detection and classificationfor which the device would sense both while the vehicle is stationary and while in motion; and one use casedrivers vital signs monitoringfor which the device would sense only while the vehicle is in motion. In addition, Tesla clarifies that the vast majority of sensing would be confined to the vehicle interior; the only exception being for exterior detection, but with the radar still installed inside the vehicle.73 E. IEE Sensing Inc. (IEE Sensing) Waiver Request 26. On November 16, 2020, IEE Sensing, Inc. (IEE Sensing) filed a request for waiver of sections 15.255(c)(2) and/or 15.255(c)(3) of the Commissions rules to allow IEE Sensing to obtain a grant of equipment authorization for its VitaSense sensor, a radar operating in the 60-64 GHz band, at a higher power than specified in the rule, limited to operation within automotive vehicle cabins.74 According to IEE Sensing, the VitaSense is designed to detect the breathing and movements of children inadvertently left in an automobile to alert the vehicles alarm system. IEE Sensing states that the VitaSense is intended to be integrated into the vehicle by the vehicle manufacturers and not as an after-
market product.75 27. IEE Sensing indicates that its device would detect unattended children while the vehicle is completely stopped, thus it considers the VitaSense to be a fixed radar under the provisions of section 15.255(c)(2).76 IEE Sensing states that the VitaSense needs a bandwidth of four gigahertz to eliminate errors in detection, thus it requests a waiver of the 500-megahertz bandwidth requirement in section 15.255(c)(2). This rule requires fixed field disturbance sensors/radars to comply with a 500-megahertz bandwidth contained within the 61.0-61.5 GHz band, and limits emission levels outside of this band (but within the 57-71 GHz band) to +10 dBm average EIRP and +13 dBm peak EIRP. IEE Sensing affirms that the VitaSense complies with the EIRP limits of this rule section across its proposed 60-64 GHz operating frequency band. 28. In the alternative, IEE Sensing requests to operate its VitaSense as a fixed radar at higher power limits than specified in section 15.255(c)(3). IEE requests to operate at +13 dBm peak EIRP, +4 dBm conducted output power and 1% duty cycle.77 71 Comments of Duncan Armour at 1. 72 Reply comments of Tesla at 4-5. 73 Tesla ex parte letter (filed Dec. 9, 2020). 74 IEE Sensing Inc. Request for Waiver of Sections 15.255(c)(2) and (c)(3) of the Commissions Rules for Vehicle Radar Operation in the frequency band 60-64 GHz (filed Nov. 16, 2020) (IEE Sensing Request). IEE Sensing supplemented its request on December 1, 2020 to provide additional detail and to ask to operate in the same manner as the Google Soli with the same technical conditions granted to Google. IEE Sensing, Inc., Clarification to the IEE Sensing Petition for Waiver (filed Dec. 1, 2020) (IEE Sensing Supplement). 75 IEE Sensing Request at 2. 76 47 CFR 15.255(c)(2). IEE Sensing Request at 1. 77 IEE Sensing Request at 4. 10 Federal Communications Commission DA 21-407 29. As an alternative, if waiver of the requested bandwidth and power limits for fixed FDS are not possible, IEE Sensing requests waiver of section 15.255(c)(3) to allow the VitaSense to operate with the same technical parameters as those we granted to Google.78 30. OET issued a Public Notice soliciting comments on the IEE Sensing Request on Dec. 31, 2020.79 A single commenter, Advocates for Auto and Highway Safety (Advocates), filed in support. IEE Sensing filed reply comments. Brose North America Inc. (Brose) Waiver Request F. 31. On November 25, 2020, Brose North America, Inc. (Brose) filed a request for waiver of section 15.255(c)(3) of the Commissions rules to allow Brose to obtain a grant of equipment authorization for a radar operating in the 57-64 GHz band at a higher power than specified in the rule, limited to operation within automotive vehicle cabins.80 According to Brose, the main focus of its device is to detect humans (including infants and children) inadvertently left in an automobile and their associated body sizes and/or movements.81 Brose states that the Brose device is intended to be mounted behind a non-conductive headliner or a covering in the vehicles roof area.82 Like other petitioners, Brose also requests to operate its devices under the same technical parameters as those we granted to Google in the 2018 waiver order.83 32. OET issued a Public Notice soliciting comments on the Brose Request on Dec. 31, 2020.84 A single commenter, Valeo, filed in support.85 No parties filed reply comments. IV. DISCUSSION 33. We are authorized to grant a waiver under section 1.3 of the Commissions rules if the petitioner demonstrates good cause for such action.86 Good cause, in turn, may be found and a waiver granted where particular facts would make strict compliance inconsistent with the public interest.87 To 78 IEE Sensing Supplement at 2 (citing Google LLC Request for Waiver of Section 15.255(c)(3) of the Commission's Rules Applicable to Radars used for Short-Range Interactive Motion Sensing in the 57-64 GHz Frequency Band, ET Docket No. 18-70, Order, 33 FCC Rcd 12542 (2018) (Google Waiver)). Because IEE Sensing only seeks a waiver for in-vehicle use, it does not seek nor require a waiver of 47 CFR 15.255(b)(2) (restricting airborne operation) that we also granted to Google. 79 See OET Seeks Comment on IEE Sensing Inc. Request for Waiver of Sections 15.255(c)(2) and/or (c)(3) of the Commission Rules for in-Vehicle Radar Operation in the 60-64 GHz band, ET Docket No. 20-435, Public Notice, DA 20-1515, 35 FCC Rcd 14676 (2021). 80 Brose North America Inc. Request for Waiver of Section 15.255(c)(3) of the Commissions Rules for Vehicle Radar Operation in the frequency band 57-64 GHz (filed Nov. 25, 2020) (Brose Request). 81 Brose Request at 2. 82 Brose Request at 2. 83 Brose Request at 4. 84 See OET Seeks Comment on Brose North America Inc. Request for Waiver of Sections 15.255(c)(3) of the Commission Rules for In-Vehicle Radar Operation in the 57-64 GHz band, ET Docket No. 20-434, Public Notice, DA 20-1514, 35 FCC Rcd 14673 (2021). 85 Comments of Valeo at 1-3. 86 47 CFR 1.3; see also ICO Global Communications (Holdings) Limited v. FCC, 428 F.3d 264 (D.C. Cir. 2005);
Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164 (D.C. Cir. 1990); WAIT Radio v. FCC, 418 F.2d 1153
(D.C. Cir. 1969). 87 Northeast Cellular, 897 F.2d at 1166; see also ICO Global Communications, 428 F.3d at 269 (quoting Northeast Cellular); WAIT Radio, 418 F.2d at 1157-59. 11 Federal Communications Commission DA 21-407 satisfy this public interest requirement, the waiver cannot undermine the purposes of the rule, and there must be a stronger public interest benefit in granting the waiver than in applying the rule.88 34. As with the Google waiver, these applications seek to use unlicensed radars for a particular use case. The exigency of the child-vehicular-heatstroke risks and the overwhelming passenger safety benefits provided by the use of radar technology in passenger motor vehicles in the 57-64 GHz band give us good cause to consider granting these waivers.89 Parties assert that 57-64 GHz radars are uniquely well suited for these applications, and discuss why they considered but rejected alternate ways to perform these tasks.90 Parties also describe why, like Google, they need a waiver of our technical rules to ensure their devices operate reliably.91 35. As an initial matter, devices operating pursuant to Part 15 of the Commissions rules are not afforded any right of interference protection and these provisions are applicable to all unlicensed users.92 Parties wishing to operate safety-related applications under Part 15 unlicensed provisions must be cognizant of the limitations of such operation. We will require instructions to be provided to users and installers of the radars operating under the provisions of this waiver to inform that these radars may only be operated on a non-interference basis to other authorized services in the 57-64 GHz frequency band, and that operators of these devices will be required to mitigate any instances of harmful interference that may occur. 36. We find it is appropriate for us to waive the operating restrictions in section 15.255(a)(2) to permit in-vehicle radar operation. We sought input on whether use of 60 GHz radar sensing in vehicular applications could be considered short-range interactive motion sensing (i.e. satisfy the SRIMS meaning) in the same way as the Google Soli technology meets the intent of the rule.93 We noted that the Google Soli radar when installed in a smartphone (e.g., the Google Pixel phone) allows the user of the phone to control web pages opening and closing or answering a call with hand gestures when the user is located at a short distance from the phone. We indicated that vehicle radar applications (e.g., sensing a childs breathing pattern, etc.) are different from Googles in that the users will not be engaging in touchless control of device functions in the same way that a Google phone user uses gestures and hand movements to interact with his or her personal device. In response to our question, some commenters 88 See, e.g., WAIT Radio, 418 F.2d at 1157 (stating that even though the overall objectives of a general rule have been adjudged to be in the public interest, it is possible that application of the rule to a specific case may not serve the public interest if an applicants proposal does not undermine the public interest policy served by the rule);
Northeast Cellular, 897 F.2d at 1166 (stating that in granting a waiver, an agency must explain why deviation from the general rule better serves the public interest than would strict adherence to the rule). 89 See e.g., https://www.nhtsa.gov/child-safety/help-prevent-hot-car-deaths. 90 See, e.g., Tesla Request at 4 (stating that, unlike cameras, radar devices operating in the requested frequency range provide depth perception and can see through soft materials, such as a blanket covering a child in a child restraint;
and, unlike in-seat sensors, such radar devices can differentiate between a child and an object left on the seat, reducing the likelihood of false alarms). 91 See, e.g., Infineon Request at 7 (Stating that it needs to operate the radar at higher power levels than permitted by the rule, because, depending on the installation within the vehicle cabin (e.g. the radar cross section of the target, random material, distance to the target, field-of-view of the radar system), there could be several dB of losses in the link budget that have to be compensated with higher output power). 92 The operator of a Part 15 device must accept interference and may not cause harmful interference. Should harmful interference occur, the operator must immediately resolve the interference up to and including ceasing operation of the device. See 47 CFR 15.5. 93 See, e.g., OET Seeks Comment on Valeo North America Inc. Request for Waiver of Section 15.255(c)(3) of the Commission Rules for In-Vehicle Radar Operation in the 57-64 GHz band, ET Docket No. 20-121, Public Notice, DA 20-486, 35 FCC Rcd 4582 (2020). 12 Federal Communications Commission DA 21-407 assert that a device should not be considered to operate as a SRIMS device unless movements originate from the owner/user of the device; under this theory, applications such as vehicle theft intrusion would not represent SRIMS.94 On the other hand, other commenters suggest including broad applications in the SRIMS designation such as any interaction with the devices environment, which could comprise a non-
users action such as a thief, or non-moving obstructions in the devices path, when they are part of the devices environment.95 37. The record on the SRIMS designation does not provide a clear bright line for determining the practical scope of SRIMS operation.96 Moreover, we recognize that an overly broad interpretation risks blurring the distinction between SRIMS devices and more general mobile radar use in the 57-
64 GHz band that the Commission clearly rejected when adopting the rule. We find that the appropriate course is to refrain from making the determination that the SRIMS designation applies to the instant case and to instead include section 15.255(a)(2) in our waiver analysis, where we are able to provide relief that is limited and narrowly tailored. We thus leave further consideration of the scope and definition of SRIMS for a later time. 38. As discussed below, we find that the waiver standard has been met and will permit the use of radar equipment mounted in a passenger motor vehiclei.e., a passenger car or a multipurpose passenger vehicle that has more than one row of seats, as those terms are defined at 49 CFR 571.397 for child detection and other safety-related vehicular-monitoring purposes. 39. In evaluating the instant waiver requests, we first consider whether a waiver would undermine the purpose of our rules. As discussed above, the operational policies and technical parameters associated with sections 15.255(a)(2) and (c)(3) are both designed to ensure that users of devices operating under section 15.255 do not cause harmful interference. When the Commission expanded the base of uses to include SRIMS, it recognized that there were types of mobile radar applications that could operate without causing harmful interference to authorized users. 40. In general, we find that radar operation in the 57-64 GHz band in passenger motor vehicles where a child may be inadvertently left unattended on a rear seat will not cause harmful interference to other authorized users in the band. First, these radars will operate at comparatively much lower power levels than the levels already permitted to communication devices (indoors and outdoors) in the same band. The communication devices such as WiGig 60 GHz networking devices are allowed to operate at +40 dBm EIRP, as compared to the +13 dBm EIRP that we are allowing here. Although the proposed +10 dBm limit on transmitter conducted power is 20 dB higher than in the existing rule, the requested peak +13 dBm EIRP is only 3dB above the existing limit. While our existing rule in section 15.255(c)(3) does not currently place a restriction on power spectral density, the +13 dBm/MHz emission limit as an additional waiver condition provides supplemental protection from potential high peak emissions in a given bandwidth. Second, with the radar installed inside a vehicle, the vehicles metallic chassis and the glass windows will block or attenuate the radar signals.98 When combined with the extensive radio frequency propagation loss in the 57-64 GHz band, the radar signals will be further 94 See, e.g., comments of Vayyar at 3 (stating that intrusion detection involves the sensing of actions by a non-user of the device and thus, would not come within the scope or ordinary meaning of the SRIMS term.) 95 See, e.g., comments of Wiley at 5. 97 See supra note 2. 96 For example, those commenters that state that all the requested use cases should be considered as SRIMS generally provide little or no substantive analysis to support their assertion. 98 Some researchers indicate that at 60 GHz, regular glass provides 11 dB/centimeter attenuation and mesh glass, 32 dB/centimeter. See e.g., C. Anderson and T. Rappaport, In-building Wideband Partition Loss Measurements at 2.5 and 60 GHz, IEEE Trans. Wireless Communications, vol. 3, no. 3, pp. 922928 (2004.) 13 Federal Communications Commission DA 21-407 attenuated outside the vehicle.99 We note that the EIRP, power density and transmitter conducted output power limits here are identical to those we placed on Google in its 2018 waiver. 41. Furthermore, restricting the radars transmit duty cycle to 10% in every 33 ms can provide additional assurance that the potential for harmful interference is minimal.100 This restriction is identical to what we required in the Google waiver and was based on Googles extensive interference studies and its final agreement with stakeholders from the WiGig communications industry whose technology shares the 57-64 GHz spectrum.101 Because all parties agree that they can comply with the same duty cycle timing restriction as the Google Soli so long as that requirement applies per radar device, we are including this restriction as a waiver condition.102 42. Because our decision addresses multiple distinct waiver requests, we next consider a number of application-specific matters that have been raised within the individual dockets. We find that none of these matters alter our overall finding that granting the waivers will not undermine the purpose of the rulesi.e., that operation under the waivers will not cause harmful interference to other authorized users in the band. 43. Vayyars V60G Spectral Footprint. In its request to operate its V60G device at the same power levels granted to Google in the 2018 waiver, Vayyar affirms that the V60G provides the same spectral footprint as the Google Soli.103 In comments, Joe Gytrock (Gytrock) argues that the V60G integrates 40 transceivers, each capable of transmitting in the proposed frequency band, whereas the Google Soli integrates only two transmit channels, which is an increase by a factor of 20.104 Gytrock asserts that the power accumulation in a phased-array beam would have some portion of the antennas adding up coherently in certain directions, resulting in a larger aggregate transmit power than the Google Soli.105 Gytrock suggests Vayyar submit a test report to prove equivalency with the Soli and compliance with the rules.106 Gytrock further requests that the Commission specify the pulsing scheme, including pulse timing as part of the waiver conditions to maintain equivalency to the Soli waiver.107 Vayyar asserts in response that, irrespective of the phase combinations used, the aggregate power of the V60G remains exactly the same as the Soli sensors, with 20 elements transmitting only 1/20th of the overall power, whereas the Google Solis 2 transmitting antennas would each transmit of the overall power.108 Vayyar 99 Free space path loss (FSPL) for a 60 GHz signal is 77.56 dB at 3 meters from the transmitter (i.e., FSPL (in dB)=
20 log F + 20 log d 147.55, where F is the signal frequency in Hertz and d is the distance from the transmitter in meters). 100 Duty cycle is defined as the fraction of one period in which transmission is active. A period is the time it takes for a signal to complete an on-and-off cycle. Duty cycle is commonly expressed as a percentage or a ratio. The existing rules do not place a restriction on duty cycle. 101 See Letter from Megan Anne Stull, Google LLC, and Pankaj Venugopal, Facebook, Inc., to Marlene Dortch, FCC, ET Docket No. 18-70 (filed Sept. 7, 2018) (Google-Facebook Joint ex parte Filing). Google agreed to the 3.3 ms duty cycle restriction after extensive consultation with Facebook and other stakeholders, as outlined in the above filing. 102 Both Valeo and Brose indicate that although they requested a longer duty cycle to cover multi-sensor situations in larger vehicles, each of their individual radar devices can comply with the 3.3 ms duty cycle per 33 ms time period. Valeo ex parte (filed Dec. 7, 2020) at 2; Brose Request at 4-5. 103 Vayyar Request at 2. 104 Gytrock Mar. 10, 2020 ex parte filing in ET Docket No. 20-15 at 1. 105 Id. 106 Id. 107 Id. 108 Vayyar Apr. 28, 2020 ex parte filing in ET Docket No. 20-15. 14 Federal Communications Commission DA 21-407 also asserts that it can configure the V60G operation to match that of the Google Soli.109 Vayyar also submitted a detailed Technical Comparison of the V60G and Soli Interference Footprints, in which it affirms that the higher EIRP during some of the slots is offset by having lower EIRP in other slots.110 Further, Vayyar argues that, in the rare case that the energy momentarily combines coherently in just one slot, the other slots are interference-free, bringing the interference-free time from 90% to 99.5%... [and because] WiGig systems themselves utilize beamforming [they can] avoid interference arriving from a given direction for most of the time.111 44. We find that the V60G can be configured to comply with the same technical conditions imposed on the Google Soli, based on Vayyars technical description and comparison, and that our existing equipment authorization procedures are sufficient to ensure that this happens.112 As an example, Vayyar has a pre-production V60G radar device, with an even higher number of antennas (up to 24 transmit and 24 receive), that has been tested and certified to comply with the power limits in the existing rules, which are even lower than the levels Vayyar requests here.113 As part of the Certification process, the V60G will be subject to rigorous compliance testing to ensure that it meets the technical requirements under our rules and waiver conditions, including the emission limits at the worst-case antenna configuration to produce the worst-case transmitted power. The device may not be sold or installed until this process has been completed. Furthermore, the +13 dBm EIRP limit will restrict what can be gained via the antenna array. For these reasons, we find that the EIRP limit and final compliance testing prior to a grant of certification are sufficient to address Gytrocks concerns, and we deny Gytrocks request to impose specific technical conditions such as pulsing scheme and pulse timing on the V60G, as unnecessary.114 45. Similarly, because our equipment authorization process will ensure that Teslas devices will operate within the radiofrequency emission standards set forth in our rules, we find Duncan Armours comments regarding RF energy unpersuasive.115 We note that low-power unlicensed devices operating under section 15.255,116 including the devices we are considering here, are already subject to the standards in sections 1.1307(b), 1.1310, 2.1091, and 2.1093 of the rules,117 and we have no reason to deviate from them in the context of Teslas waiver request.118 109 Vayyars Jun. 17, 2020 Response at 3. Vayyar states that the V60G would transmit 20 chirps (one chirp per transmitter) each 150 s long and, when tested, the Soli transmitted 30 chirps each 108.6 s. By adjusting the timing of the chirp, Vayyar claims it can comply with the same specified power levels as the Google Soli. 110 Vayyar Apr. 28, 2020 ex parte filing in ET Docket No. 20-15 at 3-7. 111 Id. at 7. 112 Id. at 5-7. 113 This Vayyar pre-production unit has received FCCID 2AHIS-V60G-HOME. 114 Gytrock Aug. 3, 2018 ex parte filing in ET Docket No. 20-15 at 1. 115 Comments of Duncan Armour in ET Docket No. 20-121 at 1. 116 See 47 CFR 15.255(g). 117 47 CFR 1.1307(b), 1.1310, 2.1091, and 2.1093. 118 These rules are designed to ensure safe levels of RF exposure for workers and for members of the public from RF devices. See Targeted Changes to the Commissions Rules Regarding Human Exposure to Radiofrequency Electromagnetic Fields, ET Docket No. 19-226, Resolution of Notice of Inquiry, Second Report and Order, Notice of Proposed Rulemaking and Memorandum Opinion and Order, 34 FCC Rcd 11687, 11688, para. 2 (2019) (Despite requests from some to increase and others to decrease the existing limits, we believe they reflect the best available information concerning safe levels of RF exposure for workers and members of the general public, including inputs from our sister federal agencies charged with regulating safety and health and from well-established international standards.) 15 Federal Communications Commission DA 21-407 46. Radar Intentional Emissions Outside of the Vehicle. Tesla specifically requests to operate radar intentional emissions outside of the vehicle while the vehicle is stationary (e.g., in park or stop mode). Tesla requests to extend the intentional emissions of its radar device outward, up to 2 meters from the vehicles body, for exterior monitoring, with the radar still installed inside the vehicles cabin.119 Tesla explains that the vast majority of sensing would be confined to the vehicles interior, except for the exterior detection use case which is accomplished while the vehicle is stationary.120 We find that intentional emissions from Teslas radar, which is installed inside the vehicle, that extend a short distance outward from the vehicles body will not cause harmful interference because the signals will be significantly attenuated by vehicles metallic chassis and the glass windows.121 Furthermore, free space path loss122 and oxygen absorption and atmospheric conditions at 60 GHz will severely limit 60 GHz outdoor signal travelling distance.123 We therefore decline to impose specific restrictions on intentional emissions outside of the vehicle, as long as the radar itself is installed within the vehicles cabin and operating under the technical limits required by our rules and associated waiver conditions. 47. Passenger Motor Vehicle Operational Environment. Our intent here is to provide limited relief within the scope of a waiver without promoting widespread radar deployments that operate at higher power than permitted in our rules, leaving any larger-scale review of the rules to whatever future actions the Commission may choose to undertake. We will therefore restrict the installation and operation of radars under this waiver to the following. The radar device shall be factory-installed on a new passenger motor vehicle. It must be installed within the passenger cabin (versus attached to the outside of the vehicle) and have the primary purpose of supporting in-cabin passenger monitoring functions (e.g., detecting children inadvertently left unattended on a rear seat). The grantee of the radar device shall provide clear instructions specifying these limitations to ensure that radars certified under the terms of this waiver shall not be marketed in after-market add-on automotive products. These restrictions will provide immediate relief to the industry and the public for this narrow type of use without undermining our general rule that limits radar operations in the band to fixed and SRIMS applications. Furthermore, any radar operating under this waiver, even if certified as a stand-alone product (if not installed behind the headliner of the vehicle) and not as a modular transmitter for installation inside host vehicles, must be marketed only for factory installation on a new passenger motor vehicle, in accordance with specific equipment grant conditions. 48. Fixed vs. Mobile Radars Installed on Vehicles. IEE Sensing initially framed its waiver request by distinguishing whether the vehicle on which the radar is installed is stationary (which IEE Sensing considers a fixed operation) or moving.124 It is not necessary for us to address fixed versus 119 Tesla Request at 2-4. 120 Tesla ex parte letter (filed Dec. 9, 2020.) at 1. 121 Researchers indicate that at 60 GHz, regular glass provides 11 dB/centimeter attenuation and mesh glass, 32 dB/centimeter. See e.g., C. Anderson and T. Rappaport, In-building Wideband Partition Loss Measurements at 2.5 and 60 GHz, IEEE Trans. Wireless Communications, vol. 3, no. 3, pp. 922928 (2004.) 122 Free space path loss (FSPL) for a 60 GHz signal is 77.56 dB at 3 meters from the transmitter (i.e., FSPL (in dB)=
20 log F + 20 log d 147.55, where F is the signal frequency in Hertz and d is the distance from the transmitter in meter). 123 See Attenuation by Atmospheric Gases, International Telecommunications Union, Reports of the CCIR, 1990, Vol. V, Report 719-3, at p. 189. See also OET Bulletin 70, Millimeter Wave Propagation: Spectrum Management Implications, July 1997, at http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet70/oet70.pdf. 124 IEE Sensing Request at 1-3. IEE Sensing claims that its radar should be treated as a fixed radar because the radar operates when the vehicle is parked. It therefore asks for waiver of the bandwidth requirement in section 15.255(c)(2) for fixed radar operation, as one of its alternative requests. 47 CFR 15.255(c)(2). IEE Sensing Request at 1. 16 Federal Communications Commission DA 21-407 mobile operation to grant IEE Sensing its desired relief. This is because our waiver of section 15.255(a)(2) already allows radars to be used in passenger motor vehicles regardless of whether the vehicles are stationary or in motion.125 Because the Commission did not specifically address whether section 15.255 permits something that is inherently mobile (such as an automobile) to be treated as fixed in certain circumstances, we decline to address the matter here and instead choose to grant IEE Sensings alternative request to operate under the same technical parameters as Google and deny the other aspects of its request.126 In doing so, we leave the determination of what constitutes fixed and mobile operation under section 15.255 for separate consideration, such as by the Commission in the context of a rulemaking proceeding. 49. Decision. We find that allowing radar operation limited to passenger motor vehicles at the same power levels and duty cycle granted to the Google Soli radar will not materially affect the 60 GHz operating environment. Because it will not increase the potential for harmful interference to authorized users in the band, a waiver of section 15.255(c)(3) will not undermine the purpose of the rule. Moreover, allowing use that is neither fixed nor SRIMS will not undermine the purpose of section 15.255(a)(2). In modifying the rule to permit SRIMS operations, the Commission found that limited non-
fixed radar use could be permitted in narrow circumstances where harmful interference was unlikely to occur. Such is the case here. Notably, both the Google Soli radar and the in-cabin radars under consideration here have been evaluated to operate without causing harmful interference when they are used in specific environments that are characterized by a short distance between the radar and what it is sensing. And, unlike the Google device, which can be carried by a person and used anywhere, the radars subject to this waiver will be deployed exclusively within vehicular cabins. 50. We also find that the second element of the waiver standard has been met. It is clear from the record that granting the pending waivers will provide substantial public benefit in improving passenger safetymost notably the prevention of vehicular pediatric heatstroke deathswhile at the same time enhancing opportunities for additional vehicular automation and theft prevention applications. We thus disagree with Duncan Armour that heatstroke deaths caused by children inadvertently left in hot vehicles could be considered trivial.127 To the extent that some commenters suggest that a rulemaking proceeding would be a better approach, we believe that a waiver is an appropriate way to address the specific in-cabin automotive radar application under consideration here.128 The narrow relief we provide will permit innovative radar systems to begin saving lives without posing interference threats to authorized users in the band while not precluding the Commissions future consideration of expanded unlicensed radar use under section 15.255 through the rulemaking process. 51. Modular Transmitter Approval. Vayyar and Infineon express the desire to certify their radars under the modular transmitter approval provisions of section 15.212.129 The modular transmitter approval provision allows a grantee to certify a transmitter module to market it to any third-party host equipment integrator. Given that the instant waivers rely on an analysis of a specific use case and radar placement, we are not willing to allow an unidentifiable number of third parties to incorporate radars 125 As a practical matter, the potential for harmful interference caused by the in-vehicle radars we consider here is minimal whether or not they are in motion. Harmful interference, if any, may be discovered when the vehicle is parked, and is otherwise generally transient, when the vehicle is in motion; thus, the effect of the radar on other users of the band is integral to the vehicle, whether it is moving or parked. 126 Specifically, we will not further consider its requests to waive either the bandwidth or related power level requirements in sections 15.255(c)(2) and (c)(3) to operate its radar under the fixed radar provision. 127 Comments of Duncan Armour in ET Docket No. 20-121 at 1. 128 See, e.g., comments of ADC Automotive Distance Control Systems GmbH in ET Docket No. 20-263 at 4-5;
comments of Acconeer AB in ET Docket No. 20-264 at 1. 129 Infineon Request at 6 & n.19. Vayyar Modified Request at 2. See 47 CFR 15.212. 17 Federal Communications Commission DA 21-407 without any effective control on the circumstances and purposes for which they are installed. Instead, we will permit limited modular transmitter approval to any party who so desires under the provisions of this waiver, restricted to the requirement that the module may only be factory installed and only in new passenger motor vehicles under the following conditions: (a) the operator's manual shall provide clear and complete installation instructions that explain the applicable restrictions and a copy of these instructions shall be submitted along with the application for equipment authorization; (b) the certification grant conditions shall clearly state that the module is limited to this type of installation; and (c) the grantee shall provide an attestation letter adhering to the limited conditions under which the module will be marketed and sold to ensure that it is installed according to the grant conditions. 52. Future Rulemaking Proceedings. The record indicates considerable interest in unlicensed use of the 60 GHz band that reaches far beyond the specific automotive-based radar use that we approve under this waiver. For example, a consortium of ten companies including Facebook and Google state that a long-term solution is needed to allow for technological innovation while ensuring reasonable coexistence of all technologies operating pursuant to the Commissions 60 GHz unlicensed rules, and encourage the Commission to commence a comprehensive rulemaking proceeding to (i) promote future applications, services, and devices in the 60 GHz unlicensed band, and (ii) address the range of technical and policy issues necessary to preserve reasonable coexistence between radars and field disturbance sensors, which require higher power levels than currently permitted, and other users of the 60 GHz unlicensed band.130 Moreover, our waiver only addresses the petition of Vayyar Imaging in part and does not attempt to resolve matters related to the definition of short-range interactive motion sensing or fixed operations under the rules in their current form. Such matters remain ripe for further consideration, including as part of a comprehensive review by the Commission through the rulemaking process that would include coordination with NTIA as the 57-71 GHz band contains co-primary Federal allocations.131 We note that operations pursuant to the waivers we grant today are expressly conditioned on compliance with the Commissions rules except as waived, and where rules are modified as a result of any future Commission rulemaking these operations will be subject to those modified rules. 53. Waiver Conditions. To ensure that harmful interference to authorized operations and other spectrum users will not occur, we impose explicit conditions on the installation, operation, and certification of the device(s) under this waiver, as follows:
The radar shall be certified for compliance with all the technical specifications applicable to operation under 47 CFR Part 15, with the exception of the following provisions in 47 CFR 15.255(a)(2) and (c)(3), which are waived to allow the device to operate as a radar on new passenger motor vehicles in the 57-64 GHz band at a maximum +13 dBm EIRP, +10 dBm transmitter conducted output power, and +13 dBm/MHz power spectral density.132 Each individual radar device shall not exceed a maximum transmit duty cycle of 10% in any 33 milliseconds (ms) interval (i.e., the device will not transmit longer than a total of 3.3 ms in any 33 ms time period). The radar shall be restricted to factory installation in the interior cabin of new passenger motor vehicles for the primary purpose of in-cabin monitoring functions and shall not be marketed in after-market add-on products. The grantee shall include clear and complete installation instructions that explain this restriction and a copy of these instructions shall be submitted along with the application for equipment authorization. If the radar is installed 130 Letter from Alan Norman, Facebook, Inc., et. al. to Marlene Dortch, Secretary, FCC, ET Docket No. 20-121 et al, at 2 (filed July 1, 2020). 131 Federal allocations in the 57-71 GHz band include Earth-Exploration-Satellite Service (EESS), Fixed, Inter-
Satellite, Mobile, Mobile-Satellite, Radiolocation, Radionavigation, Radionavigation-Satellite, and Space Research. 132 A copy of this Order shall be provided with the application for certification of the device. 18 Federal Communications Commission DA 21-407 such that it is not visible (e.g., behind the headliner), then the required equipment labeling in accordance with the provisions of 47 CFR 2.925 and 15.19 shall be provided in the vehicles Owners Manual. The certification grant shall specify these restrictions. Operations under this waiver may not be used to transmit data. Limited modular transmitter approval under 47 CFR 15.212 shall also comply with the following conditions: (a) the operators manual shall provide clear and complete installation instructions that explain the applicable restrictions and a copy of these instructions shall be submitted along with the application for equipment authorization; (b) the certification grant conditions shall clearly state that the module is limited to factory installation in new passenger motor vehicles; and (c) the grantee shall provide an attestation letter adhering to the limited conditions under which the module will be marketed and sold to ensure that host integrators install the device according to the specified grant conditions. Users of these radars must be made aware through a disclosure in the vehicle Owners Manual or an equivalent means that that operation is subject to the conditions that no harmful interference is caused and that any interference must be accepted. This waiver and its conditions shall apply only to radars intended for installation in passenger motor vehicles as described herein and are not to be considered to apply generally to any other radars or field disturbance sensors that will operate in different environments where further analysis would be necessary to assess the potential for impact to other authorized users. The waiver conditions granted herein are not transferable to any third party via 2.933 or any other means of technology transfer. V. ORDERING CLAUSES 54. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by Vayyar Imaging Ltd. IS GRANTED IN PART, consistent with the terms of this Order. This action is effective upon release of this Order. 55. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by Valeo North America Inc. IS GRANTED, consistent with the terms of this Order. This action is effective upon release of this Order. 56. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by Infineon Technologies Americas Corp. IS GRANTED, consistent with the terms of this Order. This action is effective upon release of this Order. 57. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by Tesla Inc. IS GRANTED, consistent with the terms of this Order. This action is effective upon release of this Order. 58. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by IEE Sensing Inc. IS GRANTED in part and DENIED in part, consistent with the terms of this Order. This action is effective upon release of this Order. 19 Federal Communications Commission DA 21-407 59. Accordingly, pursuant to authority in Sections 0.31, 0.241, and 1.3 of the Commissions rules, 47 CFR 0.21, 0.241, and 1.3, and Sections 4(i), 302, 303(e), and 303(r) of the Communications Act of 1934, as amended, 47 U.S.C. 154(i), 302, 303(e), and 303(r), IT IS ORDERED that the Request for Waiver filed by Brose North America Inc. IS GRANTED, consistent with the terms of this Order. This action is effective upon release of this Order. 60. IT IS FURTHER ORDERED that, if no petitions for reconsideration or applications for review are timely filed in ET Docket Nos. 20-121, 20-264, 20-265, 20-434, or 20-435, the docket(s) for which no such petitions or applications were filed SHALL BE TERMINATED, and the docket(s) CLOSED. FEDERAL COMMUNICATIONS COMMISSION Ronald T. Repasi Acting Chief, Office of Engineering and Technology 20
| frequency | equipment class | purpose | ||
|---|---|---|---|---|
| 1 | 2022-08-30 | 60000 ~ 64000 | DXX - Part 15 Low Power Communication Device Transmitter | Class II Permissive Change |
| 2 | 2021-06-03 | 60000 ~ 64000 | DXX - Part 15 Low Power Communication Device Transmitter | Original Equipment |
| 3 | 2021-01-13 | 60000 ~ 64000 | DXX - Part 15 Low Power Communication Device Transmitter |
| app s | Applicant Information | |||||
|---|---|---|---|---|---|---|
| 1 2 3 | Effective |
2022-08-30
|
||||
| 1 2 3 |
2021-06-03
|
|||||
| 1 2 3 |
2021-01-13
|
|||||
| 1 2 3 | Applicant's complete, legal business name |
Tesla, Inc
|
||||
| 1 2 3 |
Tesla Motors, Inc
|
|||||
| 1 2 3 | FCC Registration Number (FRN) |
0024474967
|
||||
| 1 2 3 | Physical Address |
3500 Deer Creek Road
|
||||
| 1 2 3 |
Palo Alto, CA
|
|||||
| 1 2 3 |
United States
|
|||||
| app s | TCB Information | |||||
| 1 2 3 | TCB Application Email Address |
t******@timcoengr.com
|
||||
| 1 2 3 |
b******@baclcorp.com
|
|||||
| 1 2 3 | TCB Scope |
A2: Low Power Transmitters (except Spread Spectrum) and radar detectors operating above 1 GHz
|
||||
| app s | FCC ID | |||||
| 1 2 3 | Grantee Code |
2AEIM
|
||||
| 1 2 3 | Equipment Product Code |
1616631
|
||||
| app s | Person at the applicant's address to receive grant or for contact | |||||
| 1 2 3 | Name |
S******** L****
|
||||
| 1 2 3 | Title |
International Compliance Engineer, Charging
|
||||
| 1 2 3 | Telephone Number |
650-6********
|
||||
| 1 2 3 | Fax Number |
650-6********
|
||||
| 1 2 3 |
s******@tesla.com
|
|||||
| app s | Technical Contact | |||||
| n/a | ||||||
| app s | Non Technical Contact | |||||
| n/a | ||||||
| app s | Confidentiality (long or short term) | |||||
| 1 2 3 | Does this application include a request for confidentiality for any portion(s) of the data contained in this application pursuant to 47 CFR § 0.459 of the Commission Rules?: | Yes | ||||
| 1 2 3 | Long-Term Confidentiality Does this application include a request for confidentiality for any portion(s) of the data contained in this application pursuant to 47 CFR § 0.459 of the Commission Rules?: | No | ||||
| 1 2 3 | Yes | |||||
| 1 2 3 | If so, specify the short-term confidentiality release date (MM/DD/YYYY format) | 11/30/2021 | ||||
| 1 2 3 | 07/11/2021 | |||||
| if no date is supplied, the release date will be set to 45 calendar days past the date of grant. | ||||||
| app s | Cognitive Radio & Software Defined Radio, Class, etc | |||||
| 1 2 3 | Is this application for software defined/cognitive radio authorization? | No | ||||
| 1 2 3 | Equipment Class | DXX - Part 15 Low Power Communication Device Transmitter | ||||
| 1 2 3 | Description of product as it is marketed: (NOTE: This text will appear below the equipment class on the grant) | Vehicle Millimeter-wave Radar Sensor | ||||
| 1 2 3 | Related OET KnowledgeDataBase Inquiry: Is there a KDB inquiry associated with this application? | Yes | ||||
| 1 2 3 | No | |||||
| 1 2 3 | Modular Equipment Type | Does not apply | ||||
| 1 2 3 | Purpose / Application is for | Class II Permissive Change | ||||
| 1 2 3 | Original Equipment | |||||
| 1 2 3 | Composite Equipment: Is the equipment in this application a composite device subject to an additional equipment authorization? | No | ||||
| 1 2 3 | Related Equipment: Is the equipment in this application part of a system that operates with, or is marketed with, another device that requires an equipment authorization? | No | ||||
| 1 2 3 | Grant Comments | Output power listed is conducted. This device is authorized in accordance with the Waiver granted in DA 21-407 on April 14, 2021, as shown in the filing. This device will be factory-installed in Tesla vehicles and will not offer for sell to other automotive manufacturers. This transmitter must be installed and operated so as to provide a separation distance of at least 20 cm from all persons and must not be co-located or operating in conjunction with any other antenna or transmitter, except in accordance with FCC multi-transmitter product procedures. Class II Permissive Change: Trace layout changes as described in this filing. | ||||
| 1 2 3 | Output power listed is conducted. This device is authorized in accordance with the Waiver granted in DA 21-407 on April 14, 2021, as shown in the filing. This device will be factory-installed in Tesla vehicles and will not offer for sell to other automotive manufacturers. | |||||
| 1 2 3 | Output power listed is EIRP. | |||||
| 1 2 3 | Is there an equipment authorization waiver associated with this application? | No | ||||
| 1 2 3 | Yes | |||||
| 1 2 3 | If there is an equipment authorization waiver associated with this application, has the associated waiver been approved and all information uploaded? | No | ||||
| 1 2 3 | Yes | |||||
| app s | Test Firm Name and Contact Information | |||||
| 1 2 3 | Firm Name |
Sporton International Inc. Hsinchu Laboratory
|
||||
| 1 2 3 |
Bay Area Compliance Laboratories Corporation
|
|||||
| 1 2 3 | Name |
A**** C****
|
||||
| 1 2 3 |
L****** T****
|
|||||
| 1 2 3 | Telephone Number |
+886-********
|
||||
| 1 2 3 |
408-7******** Extension:
|
|||||
| 1 2 3 | Fax Number |
+886-********
|
||||
| 1 2 3 |
408 7********
|
|||||
| 1 2 3 |
a******@sporton.com.tw
|
|||||
| 1 2 3 |
l******@baclcorp.com
|
|||||
| Equipment Specifications | |||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Line | Rule Parts | Grant Notes | Lower Frequency | Upper Frequency | Power Output | Tolerance | Emission Designator | Microprocessor Number | |||||||||||||||||||||||||||||||||
| 1 | 1 | 15C | 60000.00000000 | 64000.00000000 | 0.0023000 | ||||||||||||||||||||||||||||||||||||
| Line | Rule Parts | Grant Notes | Lower Frequency | Upper Frequency | Power Output | Tolerance | Emission Designator | Microprocessor Number | |||||||||||||||||||||||||||||||||
| 2 | 1 | 15C | 60000.00000000 | 64000.00000000 | 0.0023000 | ||||||||||||||||||||||||||||||||||||
| Line | Rule Parts | Grant Notes | Lower Frequency | Upper Frequency | Power Output | Tolerance | Emission Designator | Microprocessor Number | |||||||||||||||||||||||||||||||||
| 3 | 1 | 15C | 60000.00000000 | 64000.00000000 | 0.0007000 | ||||||||||||||||||||||||||||||||||||
some individual PII (Personally Identifiable Information) available on the public forms may be redacted, original source may include additional details
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