P25 Vendors Resist 700 MHz Device CAP Certification before FCC Type Approval (1/6/15)
Tuesday, January 06, 2015 | Comments

The association representing Project 25 (P25) manufacturers and suppliers asked the FCC to revise its newly released 700 MHz narrowband rules to not encourage P25 Compliance Assessment Program (CAP) certification before receiving FCC device type approval.

In rules adopted last year for 700 MHz narrowband spectrum, the FCC encouraged manufacturers of 700 MHz public-safety radios to obtain P25 CAP certification for new equipment to demonstrate that the equipment meets P25 interoperability standards as required by Section 90.548 of the commission’s rules. CAP certification will presumptively establish compliance with Section 90.528; manufacturers that elect not to obtain CAP certification must disclose their basis for asserting compliance, the rules said.

In a petition for reconsideration, the Telecommunications Industry Association (TIA) said that at the time a manufacturer submits a device to the FCC for type approval, it may not yet be feasible or possible to have completed all the requirements for P25 CAP certification.

TIA said it strongly supports the CAP compliance program to give licensees information regarding vendor assertions that equipment is interoperable and complies with P25 standards. However, the filing said CAP faces several challenges.

“Perhaps most significantly, CAP remains subject to vagaries associated with funding support from the Department of Homeland Security (DHS),” the petition said. “Additionally, the CAP governing board, which is appointed by DHS, has not met in over a year. CAP is not currently recognizing new laboratories, although the status of previously approved labs continues.”

CAP involves three categories of tests: performance, conformance and interoperability. TIA said interoperability tests, in particular, in advance of submission for FCC type approval present particular challenges. TIA said the actual P25 CAP compliant functionality for a new device may not happen until many months after FCC type approval could be completed.

The association suggested that, instead, the manufacturer could identify which P25 CAP tests the design intends to pass. TIA said the FCC should “amend the commission’s rules to more fully reflect the product development process in which devices are mature enough for submission for FCC type acceptance before CAP certification testing is feasible.”

The full petition for reconsideration is here.

Your comments are welcome, click here.


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