WPCn 2?BJ%<Courier 3|j/#Xj\  P6G;XP#Times New RomanTimes New Roman Bold P6G;PZX@Times New RomanTimes New Roman BoldTimes New Roman ItalicXP#2,qK ZCourierTimes New Roman"i~'^09CSS999S]+9+/SSSSSSSSSS//]]]Ixnnxg]xx9?xgxx]xn]gxxxxg9/9MS9ISISI9SS//S/SSSS9?/SSxSSIP!PZ9+ZM999+99999999S/xIxIxIxIxIlnIgIgIgIgI9/9/9/9/xSxSxSxSxSxSxSxSxSxSxIxSxRxSxSxS]SxIxIxInInInZnIxigIgIgIgIxSxSxSxZxSxZxS9/9S999Su]ZZxSg/gCg9g9g/xSbxSxSxSxSxn9n9n9]?]?]?]ZgFg/gMxSxSxSxSxSxSxxZgIgIgIxSg9xS]?g9xSi+SS88WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuddddddddddddddddddddddddddddddddddddddddN a8AgendaAgenda Items q?@ BibliogrphyBibliography!ABxxx Tech InitInitialize Technical Style"CD 1 .1 .1 .1 .1 .1 .1 .1 2Y(#!$"%e'&p'Doc InitInitialize Document Style#EF    I. 1. A. a.(1)(a) i) a)ҲPleadingHeader for Numbered Pleading Paper$lGH   L, 1. a. i.(1)(a)(i) 1) a)#Xj\  PG;XP# X  y*dddyy*dddy H\1 H\2 H\3 H\4 H\5 H\6 H\7 H\8 H\9 H10 H11 H12 H13 H14 H15 H16 H17 H18 H19 H20 H21 H22 H23 H24 H25 H26 H27 H28   LHeading 2Underlined Heading Flush Left%IJ Heading 1Centered Heading&K L7 Ã  2D*'s((p()qn)*e)Bullet ListIndented Bullet List'MN` ` ` 4Document Style(OP` ` ` 5Document Style)Q R . 6Document Style* ST 2p,+ev*,*-pn+.+7Document Style+ UV 8Document Style,*WX   9Document Style-YZ` ` ` 10Right-Aligned Paragraph Numbers.8[\@   2#//,0=-1-2v.11Right-Aligned Paragraph Numbers/A]^@` `  ` ` ` 12Document Style00_ `    13Right-Aligned Paragraph Numbers1Jab@  ` `  14Right-Aligned Paragraph Numbers2Scd@  2c23U/4 0506115Right-Aligned Paragraph Numbers3\ef@hh# hhh 16Right-Aligned Paragraph Numbers4egh@( hh# 17Right-Aligned Paragraph Numbers5nij@- ( 18Right-Aligned Paragraph Numbers6wkl@pp2 -ppp 24728O393:Y419Document Style7Fmn 7  ׃  20Technical Document Style8&op  . 21Technical Document Style9&qr  . 22Technical Document Style:*st    27;'5<5=P6>723Technical Document Style;'uv   24Technical Document Style<&wx   25Technical Document Style=4y$z     26Technical Document Style>&{|  . 2;?7@o<8A8BhQ927Technical Document Style?&}~  . Footnote@..footnote texA''#FxX  PCXP##FxX  PCXP#headerB   #FxX  PCXP#  #FxX  PCXP#2CC;D<Eh2?F]AreferenceC;'#FxX  PCXP##FxX  PCXP#itemizeD*  XF r#FxX  PCXP# FF r#FxX  PCXP#header2E `    #FxX  PCXP# `   #FxX  PCXP#heading 3F #FxX  PCXP# #FxX  P CXP#2IGN)DHwFIWHJRIfooterG!#X\  P!G;P#!#X\  P"G;P#CitatorFormat Secretary's Citator Output FileH#d6X@#7@# XX  FX 3#d6X@$7@# XX  1. a. i.(1)(a)(i) 1) a)#d6X@%7@# XX *  3Format DownlFormat Downloaded DocumentI XX #P&X#  #X\  P'G;P# X\ #d6X@(7@#HeadingChapter HeadingJ3  7  ׃  2=MK!JLJMdKKNKRight ParRight-Aligned Paragraph NumbersK<@    SubheadingSubheadingL.   HIGHLIGHT 1Italics and BoldM DRAFT ONHeader A Text = DRAFT and DateN6 X 8 1. a. i.(1)(a)(i) 1) a)#Xj\  P)G;XP#`$ (#DDRAFTă `0(#B 3 1, 4   2ROoMPcMQcTORcPDRAFT OFFTurn Draft Style offO*  LETTER LANDLetter Landscape - 11 x 8.5P  '3 II   LEGAL LANDLegal Landscape - 14 x 8.5Q  'A II   LETTER PORTLetter Portrait - 8.5 x 11R  3' II   2UScLRTnSUTVdTLEGAL PORTLegal Portrait - 8.5 x 14S  A' II   TITLETitle of a DocumentT* ăBLOCK QUOTESmall, single-spaced, indentedU HIGHLIGHT 2Large and BoldV 2ZWj4UXUYI1XZzYHIGHLIGHT 3Large, Italicized and UnderscoredW LETTERHEADLetterhead - date/marginsX!  X  3' II   * 3' II Ѓ    X INVOICE FEEFee Amount for Math InvoiceY \, $0  MEMORANDUMMemo Page FormatZ  D/ M E M O R A N D U M ă y<dddy 2f`[<Z\<[]5]^[ `INVOICE EXPExpense Subtotals for Math Invoice[ ,p, $0INVOICE TOTTotals Invoice for Math Macro\ p,p, $0INVOICE HEADHeading Portion of Math Invoice]=3   p,X 9 XX  *)  ӧ   XX  XX  *)SMALLSmall Typestyle^2b_[``[`a[Nab[aFINEFine Typestyle_LARGELarge Typestyle`EXTRA LARGEExtra Large TypestyleaVERY LARGEVery Large Typestyleb2+sc6bdcedf GeENVELOPEStandard Business Envelope with Headercm V, II  X  , 8'   ' `   Style 14Swiss 8 Pt Without Marginsd''#Co> P*QP##)a [ P+QXP#Style 12Dutch Italics 11.5e''#)^ `> Xi,QXX##)a [ P-QXP#Style 11Initial Codes for Advanced IIf #)a [ P.QXP# dn  #  [ b, oT9 !#A\  P/P# ## b, oT9 !#A\  P0P# ## b, oT9 !#)^ `> Xi1QXX#`e%%Advanced Legal WordPerfect II Learning Guide   #A\  P2P# ## b, oT9 !#A\  P3P# ## b, oT9 !#)^ `> Xi4QXX#Advanced Legal WordPerfect II Learning Guide   v#A\  P5P# ## b, oT9 !#A\  P6P# ## b, oT9 !#)^ `> Xi7QXX#   Copyright  Portola Systems, Inc. 1987, 1988`e%APage  v#A\  P8P# ## b, oT9 ! 1. a. i.(1)(a)(i) 1) a)#)a [ P9QXP# ## b, oT9 !#)^ `> Xi:QXX#   Page `1e%&Copyright  Portola Systems, Inc. 1987, 1988 2}vgs]shtioujuStyle 3Dutch Roman 11.5 with Margins/Tabsg#)a [ P;QXP# n  ## b, oT9 !Style 4Swiss 8 Point with MarginshG#Co> P<QP# dd  #  Style 1Dutch Roman 11.5 Fonti7#)a [ P=QXP# dn Style 2Dutch Italic 11.5j'#)^ `> Xi>QXX#2kvlUwmwnr xStyle 5Dutch Bold 18 Pointk''#T~> p?Qp##)a [ P@QXP#Style 7Swiss 11.5l''#)ao> PAQXP##)a [ PBQXP#Style 6Dutch Roman 14 Pointm''#w [ PCQP##)a [ PDQXP#Style 10Initial Codes for Advancedn #)a [ PEQXP# dn   #  [ b, oT9 !#A\  PFP# ## b, oT9 !#A\  PGP# ## b, oT9 !#)^ `> XiHQXX#`Me%'Advanced Legal WordPerfect Learning Guide   #A\  PIP# ## b, oT9 !#A\  PJP# ## b, oT9 !#)^ `> XiKQXX#Advanced Legal WordPerfect Learning Guide   v#A\  PLP# ## b, oT9 !#A\  PMP# ## b, oT9 !#)^ `> XiNQXX#   Copyright  Portola Systems, Inc. 1987, 1988`e%APage  v#A\  POP# ## b, oT9 !#A\  PPP# ## b, oT9 !#)^ `> XiQQXX#   Page `1e%&Copyright  Portola Systems, Inc. 1987, 1988 2or Epp q'rrStyle 8Initial Codes for Beginningo #)a [ PRQXP# dn  ## b, oT9  [ #A\  PSP# ## b, oT9 #A\  PTP# ## b, oT9 #)^ `> XiUQXX#`)e%&Beginning Legal WordPerfect Learning Guide   #A\  PVP# ## b, oT9 #A\  PWP# ## b, oT9 #)^ `> XiXQXX#Beginning Legal WordPerfect Learning Guide   #A\  PYP# ## b, oT9 #A\  PZP# ## b, oT9 #)^ `> Xi[QXX#   Copyright  Portola Systems, Inc. 1987, 1988`e%APage  #A\  P\P# ## b, oT9 #A\  P]P# ## b, oT9 #)^ `> Xi^QXX#   Page `1e%&Copyright  Portola Systems, Inc. 1987, 1988 Style 9Initial Codes for Intermediatep #)a [ P_QXP# dn  ## b, oT9 Њ [ #A\  P`P# ## b, oT9 #A\  PaP# ## b, oT9 #)^ `> XibQXX#`ee%%Intermediate Legal WordPerfect Learning Guide   #A\  PcP# ## b, oT9 #A\  PdP# ## b, oT9 #)^ `> XieQXX#Intermediate Legal WordPerfect Learning Guide   #A\  PfP# ## b, oT9 #A\  PgP# ## b, oT9 #)^ `> XihQXX#   Copyright  Portola Systems, Inc.`e%APage  #A\  PiP# ## b, oT9 #A\  PjP# ## b, oT9 #)^ `> XikQXX#   Page `1e%&Copyright  Portola Systems, Inc. 1987, 1988 UpdateInitial Codes for Update Moduleq-#)a [ PlQXP# dn  ##  [ b, oT9 ! 1. a. i.(1)(a)(i) 1) a)#Xj\  PmG;XP##)a [ PnQXP# ## b, oT9 !#A\  PoP# ## b, oT9 !#)^ `> XipQXX#`e%"Legal WordPerfect 5.0 Update Class Learning Guide    1. a. i.(1)(a)(i) 1) a)#Xj\  PqG;XP##)a [ PrQXP# ## b, oT9 !#A\  PsP# ## b, oT9 !#)^ `> XitQXX#Legal WordPerfect 5.0 Update Class Learning Guide   v 1. a. i.(1)(a)(i) 1) a)#Xj\  PuG;XP##)a [ PvQXP# ## b, oT9 !#A\  PwP# ## b, oT9 !#)^ `> XixQXX#   Copyright  Portola Systems, Inc. 1987, 1988`e%APage  v 1. a. i.(1)(a)(i) 1) a)#Xj\  PyG;XP##)a [ PzQXP# ## b, oT9 !#A\  P{P# ## b, oT9 !#)^ `> Xi|QXX#   Page `1e%&Copyright  Portola Systems, Inc. 1987, 1988 Agenda[8]r 2srPtr²ur4vrAgenda[7]s Agenda[6]t Agenda[5]u Agenda[4]v 20Jw˲xeyX\  PG;P5\  `&Times New RomanXj\  PG;XP5\  `&Times New RomanXXj\  PG;XP5\  `&Times New RomanXXj\  PG;XP5\  `&Times New RomanXXj\  PG;XP5\  `&Times New RomanXXj\  PG;XP5\  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LL2L"",,2d""K@"i~'^09FSS999Sq+9+/SSSSSSSSSS99qqqSggnxggxx9In]nxgxgS]xgg]]?/?FS9SSISI/SS//I/xSSSS??/SInII?C/CZ9+ZF999+999999S9S/gSgSgSgSgSnnIgIgIgIgI9/9/9/9/nSxSxSxSxSxSxSxSxS]IgSxSxSxS]IxSgSgSgSgSnInInZnIxdgIgIgIgIxSxSxSxZxSxZxS9/9S999SSZZnI]/]<]9]5]/nSanSnSxSxSng?g?g?S?S?S?ZZ]<]/]FxSxSxSxSxSxSn]Z]?]?]?xS]9nSS?]9]Sd+SS8%8WuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuuddddddddddddddddddddddddddddddddddddddddN  {O'ԍSee ACIL comments at 67, Intertek comments at 7, and TIA comments at 7. We will not  xpermit TCBs to authorize transfers of control of Part 2 grants of certification, however, because  xMthe Commission's rule on these transfers requires that we make a determination on a casebycase  X4 xbasis as to whether new equipment authorization applications are required.S?~ {O'ԍSee 47 C.F.R.  2.929(d).S We will continue  xto perform that function to ensure that the rule is applied in a consistent manner. We determine,  x<however, that TCBs may authorize transfers of Part 68 certifications. Commission approval of  X4 xcsuch transfers is not required, although the Commission requires notification of such transfers.T@ {O| 'ԍSee 47 C.F.R.  68.214(b).T  xWe intend to develop an electronic filing system to accommodate Part 68. We expect that the  xelectronic filing system will permit TCBs to notify the Commission of transfers of control. In"@0*%%ZZq"  x=the interim, we will accept Part 68 transfers of control by utilizing the same means of  X4communication we employ during the TCB program implementation period.A  yOl' " ԍWe will accept FCC form 730 for transfer of control purposes until we have developed and implemented  xU an electronic filing system for Part 68. We may utilize interim filing procedures as necessary during the development  xZ and implementation of the electronic filing system. We will provide public notice of any changes in our filing procedures.  X4 "#36. Written grant of certification.  Several parties would like the Commission to ensure  xVthat grants issued by TCBs are exactly equivalent to grants issued by the FCC. ACIL, Intertek  x/and TIA suggest that TCBissued grants indicate that the TCB is FCC designated, and that the  X4 xFCC publish the list of TCBs under its letterhead.B {O 'ԍSee ACIL comments at 4, Intertek comments at 5, and TIA comments at 56. Motorola and PCTEST recommend that the  X4 xFCC standardize the format of TCB grants.rCB {O'ԍSee Motorola comments at 5, and PCTEST reply comments at 6.r We find that the first two suggestions have merit.  xWe believe the success of the TCB program will depend in part on our ensuring that TCB  xcertifications are truly equivalent to those issued by the Commission. Accordingly, we will  xrequire a TCB grant to indicate that the TCB is designated to grant the certification, citing the  Xt 4 x<source of authority (e.g., the rules that we are adopting in this Report and Order). We will not  xrequire a specific format for TCB grants, but the certification must include the same information  xas contained in one issued by the Commission. We will make samples of the Commission's format available to TCBs that wish to follow it.  X64 "$37. Consistent with the Commission's rules,PD6 {O'ԍSee 47 C.F.R.  1.108.P a TCB may set aside a grant on its own  xmotion within 30 days of the effective date of the grant in the event of administrative errors, e.g.,  x/the application was not complete. The TCB will be required to provide notice of such action to  x}the applicant and to the Commission. After the 30 day period, only the Commission may revoke  xNa grant if, for example, we discover misrepresentations in the application or failure of the  X4equipment to conform to the applicable technical standards.SEf  {O 'ԍSee 47 C.F.R.  2.939(a).S  X4 "'%38. Unmodified sample for type testing. CurtisStrauss requests clarification on what  X4 xconstitutes an "unmodified" sample for testing.ZF  {Oz#'ԍSee CurtisStrauss comments at 12.Z CurtisStrauss points out that manufacturers  x_often apply for certification during product development, and product modifications are often" F0*%%ZZ"  X4 xneeded for compliance.@G {Oy'ԍId.@ In proposing this requirement, we intended that TCBs use the same  xystandards that we currently use in certifying equipment (i.e., the sample of the equipment for  x"which certification is being obtained must be representative of what will actually be marketed).  X4 xIn the event modifications to a sample are required during compliance testingmHZ yO'ԍ"Compliance testing" and "type testing" mean the same thing.m to make a product  x"comply with the standards, those modifications must be incorporated into the finished marketed  X4product.I {OZ 'ԍSee 47 C.F.R.  2.907(b) (equipment marketed by a grantee must be identical to the sample tested).  X4 "l&39. Test data. Some commenters express concern that TCBs will not accept test data from  xmanufacturers or independent labs, preferring instead to conduct compliance testing themselves.  x}SEA is concerned that TCBs will have an incentive to conduct compliance testing themselves in  x/order to demonstrate their impartiality and, as a result, manufacturers' costs and time to market  Xt 4 xwill increase.OJt | {O'ԍSee SEA comments at 56.O TIA asks that we clarify whether "subcontractor" includes an applicant's own test  Xg 4 xlab.MKg  {O&'ԍSee TIA comments at 6.M Although it recognizes that a TCB will want a manufacturer to demonstrate a basis for  xgconfidence in the manufacturer's test procedures and results, Motorola suggests that TCBs provide  x/public notice of the criteria they will use to determine whether they will accept test data from a  X@4 xmanufacturer.RL@ {O'ԍSee Motorola comments at 9.R ACIL recommends that ISO Guide 25 accreditation serve as the basis for  X34accepting test data.NM32  {O'ԍSee ACIL comments at 2.N  X4 "'40. Under the Commission's current certification process, manufacturers and independent  xlaboratories may test products and submit applications to the Commission for certification. Under  xthe TCB system we are adopting, manufacturers and independent labs may continue to test  x products as they do now, except applications can be submitted to a TCB rather than the  X4 x"Commission.N  {OZ"'ԍA TCB is required to make its services available to all applicants. See clause 4.1.2 of Guide 65. Thus, a manufacturer or a test lab does not have to be a subcontractor in order  xto test products and submit applications to a TCB. We agree with Motorola that a TCB will want  x}a manufacturer to demonstrate a basis for confidence in the manufacturer's test procedures and"V N0*%%ZZ("  xresults. Consistent with our decision regarding subcontractor's competence, a TCB can establish  xconfidence in a manufacturer's or independent lab's test results by any reasonable means, but we  xwill not require accreditation of the test lab under Guide 25. We expect that a TCB will examine  x8a test report for completeness of data and documentation; notify applicants in writing of any  xcdeficiencies in the test report; request additional information to address the deficiencies; and not  xretest or duplicate testing for minor equipment changes that do not affect compliance with  xtechnical requirements. Our oversight of TCBs should identify any abusive practices concerning the acceptance of test data.  X4 "(41. Common Database of Certified Equipment. ACIL, CCL, Intertek and TIA request  xthat the Commission establish a standard format for the information submitted for inclusion in  Xt 4 xthe database to be maintained by the Commission.Ot  {O 'ԍSee ACIL comments at 5, CCL comments at 8, Intertek comments at 10, and TIA comments at 6. ACIL provides a list of the information it  Xg 4 x}believes is necessary to include in the database.Pg Z {Or' " ԍSee ACIL comments at 56. ACIL recommended that the information submitted include the application form, photographs of the equipment, and a copy of the test results. TIA requests that the Commission work with  XZ 4industry to develop the common database.MQZ  {O'ԍSee TIA comments at 6.M  X@4 ")42. We conclude that it is necessary to maintain a common database of certified  xpequipment by having all TCBs send an electronic copy of each granted application, including the  xcertification the TCB issued, to the Commission using the electronic filing system for Part 2  X4 xapplications. As we explained in the Notice, a common database will allow the Commission to  xverify whether a piece of equipment was approved without having to locate the TCB that  xapproved it and obtaining their records; to monitor the activities of TCBs to determine how many  xapprovals are issued and for what types of equipment; and to provide one location which all  x'parties can use to verify approvals and obtain copies of applications. However, requiring  xsubmission of a copy of the complete application to the database, including all the photographs,  x/user manuals and test reports would be an unnecessary burden on TCBs. We will only require  xIsubmission of the application Form 731 and an electronic copy of the TCB's grant of equipment  xauthorization. In the event we need additional information about a particular piece of equipment,  x/we can obtain it from the TCB. We are amending our rules to require TCBs to provide a copy  xJof the application file within 30 days of a request by the Commission, or to provide an  xexplanation as to why the file can not be provided. Where appropriate, the TCB will provide a  xRcopy of any request for confidentiality for any material in the application file that qualifies as"FQ0*%%ZZ"  X4 xtrade secrets, to ensure appropriate handling.R yOy' " ԍUnder clause 4.10 of Guide 65, TCBs are to safeguard the confidentiality of information obtained in the course of their certification activities, but they may disclose the information as required by law. OET will notify TCBs of the specific information it will need about a TCB grant and in what electronic format it should be provided.  X4 "*43. We recognize that we have not yet developed an electronic filing system to  xaccommodate Part 68, but intend to do so in the future. We will utilize conventional means for  X4 xcollecting information in the interim.S  yO 'ԍWe will accept FCC form 730 during the development and implementation of the electronic filing system. We will authorize submission of Part 68 certification  xVinformation into a common database, and describe the information that must be filed for Part 68 purposes, after we have developed an electronic filing system to accommodate that information.  X4 "+44. Surveillance Activities. ISO/IEC Guide 65 requires TCBs to perform surveillance on  X 4 xproducts they have approved.OT  {O'ԍSee Guide 65, clause 13.O It does not specify the number or percentage of products that  x_need to be examined. We received a number of comments on this issue. Acme and Curtis Xg 4 xStrauss would like the Commission to clarify exactly what TCBs are required to do.pUg B {OZ'ԍSee Acme comments at 1, and CurtisStrauss comments at 2.p However,  xmany parties object to requiring TCBs to perform surveillance. Cisco, ITI, Itron, Motorola, SEA  xand PCTEST believe that surveillance should be done only by the government, primarily because  xthey view audits as closely aligned with enforcement responsibility which they argue should be  X34 x&retained by the Commission.V3 {O' " ԍSee Cisco comments at 9, ITI comments at 6, Itron comments at 2, Motorola comments at 910, SEA comments at 89, and PCTEST reply comments at 4. Cisco, ITI, Itron and PCTEST are concerned about a possible lack  X&4 xof impartiality or conflict of interest.W&.  {O' " ԍSee Cisco comments at 910, ITI comments at 6, Itron comments at 23, and PCTEST reply comments at 4. Cisco also is concerned that a TCB may determine that  xca product is no longer in compliance with a certification it issued, when in fact the manufacturer  X 4 xcused another TCB to certify the product modification.RX   {OE 'ԍSee Cisco comments at 910.R SEA is concerned that TCBs will have  X4to charge additional fees to cover the cost of equipment audits.OY {O"'ԍSee SEA comments at 89.O "Y0*%%ZZj"Ԍ X4 "0,45. The Commission will continue to perform its own surveillance of products on the  xmarket, by periodically conducting random product testing as well as by investigating allegations  xof noncompliance. However, we find that surveillance is an appropriate activity for TCBs to  xsupplement the Commission's efforts. Under clause 13 of Guide 65, a TCB is obligated to ensure  xcthat products that it has certified continue to comply with Commission requirements, particularly  X4 xafter a manufacturer notifies a TCB that the product has been modified.QZ {O8'ԍSee Guide 65, clause 13.2.Q We will not specify  xa specific number or percentage of products that a TCB should test to satisfy this guideline, since  x/our experience has shown that different levels of scrutiny are required for different products to  X4 x'ensure compliance.[XZ yO ' "y ԍFor example, lowpower, unlicensed transmitters such as cordless telephones and baby monitors have  x frequently been a source of compliance problems because of pressures in the marketplace to build them as cheaply as possible, or to increase their operating range by increasing their transmitter power above the legal limit. We will rely on TCBs to use their judgment in complying with this  xguideline. In addition, we may periodically require a TCB to test for continued compliance  xcertain types of products that the TCB certified and which are already being marketed (post xmarket surveillance). We do not view postmarket surveillance by TCBs as an abdication of our  xenforcement responsibilities, since the TCB will report apparent violations to the Commission and  xnot take action on its own against the manufacturer. To ensure that TCBs conduct audits  x~impartially, the Commission will devise procedures that TCBs will use for postmarket  xhsurveillance, and we delegate authority to the Chief, OET and the Chief, CCB to develop  x"procedures that TCBs will use for conducting postmarket surveillance. These procedures will  xaddress, for example, conducting field audits or acquiring samples for testing. The TCB will test  xthe products under the Commission guidelines and report the results to us. TCBs will be able  xto check the Commission's common database, described above, to avoid reporting as non xcompliant products that actually were subsequently recertified by another TCB. By using the  xTCBs to conduct audits, the Commission will be able to secure information quickly from a  xvariety of sources about ongoing compliance, while focusing its own resources on investigating  xspecific problem cases. Based on the TCBs' reports, the Commission may conduct further  xinvestigations and take appropriate enforcement action against companies found to be marketing  xnoncompliant products. As stated above, the Commission will also continue to perform post x&market surveillance in cases where we deem it warranted, and to audit the performance of TCBs.  xVThese actions will help ensure that TCBs act in a fair, impartial manner. We expect that TCBs  xwill take the cost of postmarket surveillance into account when setting their fees. As previously  xstated, we are not regulating the fees that TCBs charge, but we expect that competitive pressures in the market will prevent a TCB from charging excessive fees.  X`4 "-46. Consultative Activities. Several parties suggest that the Commission develop a joint  xpublicprivate sector working group to address implementation issues as they arise. Commenters"Vz[0*%%ZZx"  xrecommend that this working group include all interested parties, such as TCBs, test labs and  X4 xmanufacturers.\ {Ol' " ԍSee ACIL comments at 7, CCL comments at 45, ICS comments at 3, Intertek comments at 78, Retlif comments at 4, and TIA comments at 78. We refrain from establishing a new formal organization at this time, and choose  x}to rely instead on existing voluntary industry consensus groups. For example, for Part 68 issues,  xwe intend to continue our cooperative association with TIA's TR.41 committees. Moreover, we  xuintend to work with all interested parties to implement the TCB program and to ensure its success.  X4Continued Certification by the Commission  X4 ".47. The Notice solicited comments on whether the Commission should eventually stop  X 4 xVcertifying equipment once TCBs are designated.N] " {OT'ԍSee Notice at para. 20.N We received mixed comments on this issue.  xACIL, CCL, Compliance, DLS, ICS, Intertek and TIA state that the Commission should cease  Xg 4 x certifying equipment after TCBs are designated.^g  {O' "N ԍSee ACIL comments at 8, CCL comments at 5, Compliance comments at 2, DLS comments at 4, ICS comments at 3, Intertek comments at 8, and TIA comments at 8. However, Cisco, CurtisStrauss, ITI, Motorola  XZ 4 xand SEA state that the Commission should continue to certify equipment._Z  {O' " ԍSee Cisco comments at 10, CurtisStrauss comments at 2, ITI comments at 45, Motorola comments at 5, and SEA comments at 910. Cisco states that the  xCommission is better able to interpret the rules, and authorization by the Commission will set a  X@4 xbenchmark for quality and prices.S`@h  {OY'ԍSee Cisco comments at 1011.S ITI believes that having the Commission continue to issue  X34 xVauthorizations will help limit fees charged by TCBs.Ma3  {O'ԍSee ITI comments at 4.M Motorola believes continued Commission  X&4certification is necessary to satisfy foreign governments that may require an FCC approval.Rb&  {Oc'ԍSee Motorola comments at 5.R  X 4 "/48. Our goal in this proceeding is to discontinue granting routine, noncontroversial  xapplications under Parts 2 and 68 of our rules when TCBs are available to perform the work, but  xwe do not at this time set a date when the Commission will cease to issue authorizations. We  xconclude that the Commission should continue approving equipment, including processing routine  xapplications, during the implementation of the TCB program. This will help smooth the  xtransition to the new system and ensure that at least one organization is available to certify all"b0*%%ZZ"  xtypes of equipment. After we have some experience with the new system, we will assess the  xeffectiveness of the TCB program and determine when the Commission should discontinue  x<approving products. After the TCB program is initiated, however, the Commission will continue  xto be the authorizing body if no TCB is available to authorize a given type of equipment and to process applications raising novel issues regarding application of our rules.  X4 "9049. We conclude that it is unnecessary for the Commission to continue approving  xcertification applications for personal computers and peripherals, since that equipment can be  X4 xauthorized through the DoC procedure.c  yO ' " ԍPersonal computers and peripherals can be authorized through the DoC procedure, but manufacturers also  xD have the option of obtaining certification from the Commission. In the quarter that ended in September 1998, the  x Commission received 342 applications for this equipment, which was approximately onethird of all applications received during that time period. We find that processing these voluntarily filed  x"applications is not an efficient use of the Commission's resources. Accordingly, once domestic  xTCBs are available to process applications for personal computer equipment for those applicants  xwho choose to use the certification process rather than DoC, the Commission will stop accepting  x}these applications a reasonable time thereafter. The Commission will announce by public notice  xwhen it will cease to accept these applications. We amend Section 15.101 of the rules to reflect this change.  X04Implementation Dates and Transition Periods  X#4  X4 "150. In the Notice, we proposed that a transition period of 24 months elapse before any  X 4 xTCBs would be allowed to certify equipment.Nd  {Om'ԍSee Notice at para. 19.N This time period was proposed because it is  xsimilar to the provision of the US/EC MRA, which specifies a 24 month transition period after  xthe MRA effective date, so that countries have time to modify requirements and procedures to  x}meet the MRA's obligations. Some commenters suggest that a transition period be no more than  X4 x24 months, and perhaps less.xeB {O'ԍSee ACIL comments at 7, ITS comments at 8, and TIA comments at 8.x Upon further consideration, we do not find it necessary to delay  xthe introduction of the TCB system for a 24 month period, and we would rather implement the  xTCB system as soon as practicable. Nonetheless, we cannot implement the TCB system  ximmediately because of a number of tasks which need to be completed first. For example, we  xneed to specify the documentation necessary to meet the qualification criteria for TCBs, as  x3discussed above, and we need to develop with NIST the accreditation and designation procedures.  xAlthough we will immediately begin taking the necessary steps to implement the TCB system,  xqwe recognize that it is difficult to specify a fixed date when TCBs will begin to certify"}e0*%%ZZ"  xequipment. We also conclude that a fixed date would not serve the ongoing accreditation and  ximplementation processes. For example, TCBs may be identified readily for some equipment,  xbut not for others, accreditation compliance dates may vary, and TCBs can enter and exit the  xsystem at different times. Thus, we conclude that we will authorize the use of TCBs as they are designated by the Chief, OET and the Chief, CCB in a public notice.  X4Part 68 Issues  X4 "251. Terminology. In the Notice, we discussed the use of the terms "certification" and  X4 x""registration" as they apply to the Part 68 program.Qf {O 'ԍSee Notice at para. 2124.Q Commenters suggest that the two terms  xVare functional equivalents, and recommend that we expand our use of the term "certification" to  Xt 4 xinclude our Part 68 program.gt Z yO'ԍACIL comments at 8; CCL comments at 5; ICS comments at 4; ITC comments at 9; TIA comments at 10. Commenters point out that such usage would be consistent with  xvarious other parts of the Federal Register, the norms of international terminology, and  XZ 4 xIspecifically the language of the MRAs.khZ  yO'ԍACIL comments at 8; ITS comments at 9; TIA comments at 10.k We agree with commenters that the use of common  xterminology benefit clarity and consistency, and determine that the terms "registration" and  x"certification" are equivalent for the purposes of our Part 68 rules. To the extent practicable, we  xuwill implement this change in the course of future rule makings and administrative actions affecting Part 68.  X 4 "352. FCC Form 730. The Part 68 program currently utilizes FCC Form 730 to transmit  X4 xinformation from test labs and manufacturers to the Commission. In the Notice, we sought  xlcomment on whether we could utilize that form to transmit test data to the Commission from  X4 xTCB candidates during the transition period.Niz {O'ԍSee Notice at para. 24.N Although commenters support the use of a  xcommon format for recording and transmitting information among TCBs and the Commission,  X4 xthey do not support the use of FCC Form 730 for this purpose.zj  {O'ԍSee ACIL comments at 1112; CCL comments at 8; ITS comments at 10. z We agree that FCC Form 730  xlis not the optimal format for use among TCBs and the Commission, and intend to develop an  xelectronic filing system and common database to fulfill that purpose. In the mean time, however,  xcwe find that it would be a waste of resources to create an interim solution. Thus, we determine  xVthat we will utilize FCC Form 730 as the initial information transmission format for the purposes"j0*%%ZZ["  xof implementing the TCB program. We will, however, update this requirement pursuant to further TCB program implementation activities.  X' B. Mutual Recognition Agreements (MRAs)  X4United States / European Community MRA  X4 "`453. The Office of the United States Trade Representative and the Department of  x8Commerce have participated in negotiations over the past several years to develop a mutual  xrecognition agreement for product approvals with the European Community (EC). The  x Commission has also participated in these negotiations, as have industry representatives from both  xthe United States and Europe. These negotiations culminated on June 21, 1997 when the US/EC  xMRA was finalized by the United States Trade Representative and a representative of the  xIEuropean Community. The Agreement was signed on May 18, 1998, and entered into force on December 1, 1998.  X04 "554. The US/EC MRA addresses conformity assessment activities in six industrial sectors:  xtelecommunications equipment, electromagnetic compatibility, electrical safety, recreational craft,  xpharmaceutical good manufacturing practice, and medical devices. The Commission's regulations  xapply directly to two industry sectors, telecommunications equipment and electromagnetic  xcompatibility ("EMC"), among the six specifically addressed by the US/EC MRA. The  xtelecommunications sector addresses terminal equipment covered by Part 68 of the rules, and  x+transmitters covered by Part 2 and other parts of the Commission's rules. The EMC sector  X4applies to equipment addressed by Parts 15 and 18 of the Commission's rules.`k {ON'ԍSee 47 C.F.R.  2, 15, 18, and 68.`  X4 "655. Under the US/EC MRA, products can be tested and certified in the United States for  xconformance with EC member states' technical requirements. The certified products may be  xshipped directly to Europe without any further testing or certification. In return, the MRA  xIobligates the United States to permit parties in Europe to test and authorize equipment based on  xIthe United States technical requirements. The US/EC MRA thereby promotes bilateral market  xaccess and competition in the provision of telecommunications products and electronic equipment.  xThe US/EC MRA also will reduce industry burdens and delays caused by testing and approval requirements for products marketed in the United States and Europe.  XF 4 ",756. The US/EC MRA provides a 24 month transitional period that will be used to  ximplement the regulatory or legislative changes necessary for both parties to implement the  xUS/EC MRA. The period began on the effective date of the MRA, which is December 1, 1998. ","Zk0*%%ZZ!"  xAt the end of the transition period, the parties should be prepared for full mutual recognition of  x<product certifications and registrations. To ensure parity between U.S. and EC manufacturers,  xwe will not permit parties in an EC country to test and approve products to U.S. requirements until that country permits U.S. parties to test and approve products to its requirements.  X4AsiaPacific Economic Cooperation (APEC) MRA  X4 "857. The Office of the United States Trade Representative, at the request of the United  xStates telecommunication industry, has negotiated a Mutual Recognition Arrangement (MRA) for  xConformity Assessment for Telecommunication products in the AsiaPacific Economic  xCooperation (APEC), which is intended to facilitate trade in telecommunications and radio  xequipment among the APEC economies. APEC is a trade cooperative of twentyone economies  xSalong the Pacific Rim. Commission staff and representatives of the United States  x"telecommunications industry have been participating in a Task Force Group under the Telecom  xWorking Group of APEC, which was established in March, 1997 to facilitate the development of the APEC Telecom MRA.  X#4 "958. The text of the model APEC Telecom MRA was finalized on April 30, 1998 and was  xendorsed at the APEC Ministerial Meeting on June 5, 1998. Unlike the US/EC MRA, the APEC  x"Telecom MRA is a voluntary model agreement. To enact the agreement, each APEC member  xeconomy must adopt the agreement with each of its APEC trade partners, such as the United  xStates, through a bilateral exchange of letters. Participation in the APEC Telecom MRA is  xvoluntary; however, if a member economy chooses to participate, the model text becomes the  xgoverning document for conformity assessment between the participating member economies.  xThe MRA is expected to take effect on July 1, 1999, although individual parties may agree to  xapply it bilaterally before that date. The key elements of the APEC Telecom MRA text are  xcsubstantially similar to the key elements of the US/EC MRA text, with the following exceptions:  xthe APEC Telecom MRA has specific designation procedures for conformity assessment bodies  x(CABs); when parties agree to participate in activities with one another, the transition period will  xnormally be twelve months from the date of mutual agreement; and implementation occurs in two  x<phases the first for accepting test results and the second for accepting product approvals. As  xin the case of the US/EC MRA, we will not permit parties in an APEC member economy to test  xand approve products to U.S. requirements unless that member economy permits parties in the  x/U.S. to test and approve products to its requirements. We adopt the tentative conclusion in the  XF 4 xNotice that the rules proposed in this proceeding to implement the US/EC MRA are sufficient to  X63. The US/EC and APEC MRAs identify the Designating Authorities for the United  x<States as NIST and the Federal Communications Commission. NIST will designate conformity  XM 4 xassessment bodies, such as TCBs,_pM z yOx'ԍA TCB is a type of conformity assessment body._ in the United States for equipment that will be exported  xthrough its National Voluntary Conformity Assessment System Evaluation (NVCASE) program.  xNIST will oversee the United States conformity assessment bodies on an ongoing basis to ensure  X&4 xthat they are performing in a satisfactory manner. We stated in the Notice that it would be  xunnecessary for the Commission to play a direct role in designating or supervising TCBs with  x"respect to equipment being exported. However, the Commission would provide assistance and  x"guidance to NIST as may be necessary. For example, if questions arise as to the performance  xof a United Statesbased CAB, the Commission would make its expertise in testing and measurements available as needed to resolve such matters.  X4 "?64. We adopt the approach described in the Notice for designating conformity assessment  xbodies, such as TCBs, in the United States for equipment that will be exported to countries  xVpursuant to MRAs. TCBs designated to certify equipment for export to a specific country shall  xmeet the qualification criteria specified in the relevant MRA. We conclude that NIST has  x"sufficient resources and experience to assume responsibility for designating and overseeing the  xperformance of TCBs certifying equipment for export, in conformance with MRA obligations.  xThus, the Commission will not perform designation and oversight functions for TCBs certifying equipment for export, but will provide assistance and guidance to NIST as necessary."v p0*%%ZZ"Ԍ X4 "ԙ@65. We received several comments on the MRA provisions for equipment being exported  xfrom the United States. DLS and USCEL request that we clarify whether the US/EC MRA  xcovers Competent Bodies in Europe which evaluate Technical Construction Files for  xelectromagnetic compatibility (EMC) that are used in some cases in lieu of a supplier declaration,  x4and whether U.S. TCBs should be permitted to prepare Technical Construction Files for  X4 xIequipment going to Europe.q" {O8' " ԍSee DLS comments at 1, and USCEL comments at 2. In Europe, manufacturers may declare compliance  x7 with essential elements of the EMC Directive, relying on harmonized standards. If standards are not harmonized  xk or the standard cannot be used for another reason, the manufacturer develops a technical construction file (TCF) which a European Competent Body will evaluate to determine compliance. Intertek wants the Commission to clarify that U.S. TCBs do not  X4 x<need accreditation from Europe to approve products going to Europe.Tr {O 'ԍSee Intertek comments at 45.T SEA notes that TCBs  x8approving products for export would have to be able to approve products for many different  X4 xcountries, since standards still vary by country.QsD {O'ԍSee SEA comments at 1114.Q Cisco wants the Commission to ensure that  xRU.S. TCBs are capable of granting equipment authorizations for any country covered by the  xUS/EC MRA. Otherwise, manufacturers would have to approve equipment at multiple TCBs,  Xq 4 xtwhich is the same piecemeal approach manufacturers currently face.Utq  {O'ԍSee Cisco reply comments at 9.U PCTEST does not believe  xlthat Europeans will accept test results and certifications of products performed in the United  xhStates. It wants the Commission to take an active role in TCB certification of equipment  XJ 4 x@exported to Europe and other countries.VuJ h  {Oc'ԍSee PCTEST reply comments at 5.V SEA also expresses concern that regulatory authorities  X=4in some countries may require additional approvals despite the MRA.Nv=  {O'ԍSee SEA comments at 11.N  X#4 "hA66. Some of the concerns raised are already addressed by provisions of the MRAs. For  x}example, the EC requirements for telecommunications equipment are covered by three separate  xdirectives EMC, Low Voltage and Telephone Terminal Equipment (TTE) Directives. Each  xdirective has distinct conformity assessment requirements. Under the EMC Directive most  xequipment is subject to supplier's declaration, except that when standards are not harmonized  xwithin the EC or the equipment is too large for remote testing, the supplier must use what is  xccalled the Technical Construction File (TCF) route to market, requiring the use of a CAB called  xa Competent Body. NIST will be able to designate a U.S. entity to serve as a Competent Body,  xprovided the entity is accredited to Guide 25 and meets the appropriate technical requirements" v0*%%ZZ"  xVin the EMC Directive. Radio transmitters and telephone terminal equipment subject to the TTE  xDirective, which is the most frequently used route to market, must be approved by a CAB called  x4a Notified Body, which is accredited to Guide 65. In either case, NIST will accredit and  xdesignate the U.S. TCBs to the appropriate directives. Under the MRAs, parties are to accept test  xresults and product certifications prepared by CABs in other countries. The APEC MRA, for  xexample, clarifies that an importing party is to accept test reports on terms no less favorable than  xIthose it accords to those produced by its own CABs and that retesting or duplicate testing is to  X4 xbe avoided.Zw {O 'ԍSee APEC MRA, Appendix B section 5.Z Because technical standards vary by country, a U.S. CAB may be found qualified  xto certify equipment intended for export to some countries but not others. The US/EC MRA, for  xexample, does not require that CABs in this country be capable of approving equipment to all  xof the EC member states requirements, and we find no basis for imposing such a requirement.  x'We expect that CABs will be able to provide certification for multiple countries because manufacturers will expect this level of service from CABs.  XJ 4Administration of the MRAs  X04 "B67. The US/EC MRA provides for oversight of implementation by a Joint Committee and  X#4 xJoint Sectorial Committees ("JSC").x#Z yO.' "A ԍThe US/EC MRA states that it will be administered by a Joint Committee along with Joint Sectoral  x. Committees ("JSCs") in the various sectors (i.e. telecommunication and EMC). The Agreement also states that the  x Joint Committee and JSCs will consist of government representatives, with possible participation by private sector  x* experts in the JSCs. These groups will establish their own operating procedures. Each party will have one vote.  xH The Joint Committee and JSCs will provide a vehicle for the exchange of information, dispute resolution, and general management of the implementation of the US/EC MRA. The MRA provides that Commission representatives will  xparticipate in both committees for the United States with regard to telecommunications equipment  xand electromagnetic compatibility sectors. The APEC MRA has similar provisions for a Joint  x3Committee consisting of representatives of each party, with subcommittees including persons from  x}the business/private sector. We conclude that Commission participation in the Joint Committees  xyand JSCs will be important to ensure the successful administration and implementation of the  xUS/EC and APEC MRAs. For example, the Commission may serve as an independent authority  xVto evaluate claims of performance deficiencies by United States TCBs or the noncompliance of specific equipment with European technical requirements.  X4 "C68. With regard to ensuring the ongoing compliance of TCBs, the US/EC MRA provides  xthat if a particular TCB does not appear to be performing satisfactorily, the Commission may  x/request that the noncompliant TCB take corrective actions. The Commission may also present  xcappropriate evidence to the JSCs and/or Joint Committee and request removal of the TCB from"zx0*%%ZZ"  xthe list of designated Certification Bodies. The APEC MRA also has provisions for contesting  x"a TCB's technical competence, and provides a framework to limit or remove the recognition of  x TCBs when necessary. The Commission shall consult with the Office of the United States Trade  X4Representative (USTR), as necessary, concerning any disputes that arise under an MRA.y {OR' " ԍSee the Telecommunications Trade Act of 1988 (Section 13711382 of the Omnibus Trade and  x Competitiveness Act of 1988). Section 1377 requires the USTR to conduct a review to determine whether any act,  x policy, or practice of a foreign country that has entered into a telecommunicationsrelated agreement with the U.S.  x< (1) is not in compliance with the terms of the agreement; or (2) otherwise denies, within the context of the  x agreement, mutually advantageous market opportunities to telecommunications products and services of U.S. firms in that country.  X' C. Global Mobile Personal Communications by Satellite (GMPCS)  X4 "D69. The Notice proposed to adopt an interim equipment authorization procedure for  X4 x GMPCS terminals prior to full implementation of the GMPCS Arrangements.QzB {O'ԍSee Notice at para. 3745.Q The Commission  xwill be undertaking a separate proceeding to propose rules to implement fully the GMPCS  X 4 xArrangements. Because one GMPCS operator was providing service prior to the Notice and  xanother system was scheduled to commence service before final rules implementing the  xcArrangements could be adopted, we proposed a set of interim standards under which applicants  x}could request equipment certification. We believe that certification of GMPCS terminals will be  xa major benefit to the global satellite industry. A Commission equipment authorization, and the  xsubsequent placement of the "GMPCSMoU ITU Registry" mark on the terminals, would  xpotentially be recognized by many foreign countries as sufficient to allow the equipment to transit  xyborders more easily and without additional type approvals, equipment testing, or imposition of fees or delay for the user.  X4 "E70. The Notice proposed a voluntary equipment authorization procedure that would apply  xto GMPCS terminals as defined by the 1996 World Telecommunications Policy Forum held under  X4 x the auspices of the ITU.H{ {Op'ԍSee supra note 2.H The terminals would be certified in accordance with the requirements  X4 xin Parts 1, 2 and 25 of the rules.|f  {O ' " ԍSee 47 C.F.R., Parts 1, 2 and 25. Part 25 contains the technical requirements for satellite communications. Part 1 contains the requirements for RF safety, and Part 2 contains the equipment authorization requirements. In addition, we proposed that terminals operating in the  x16101626.5 MHz band would also have to meet the outofband emission limits recommended" |0*%%ZZ"  xfor implementation by the year 2000 by the National Telecommunications and Information  X4Administration (NTIA) in their September 1997 petition for rule making.B} {Ol'ԍSee RM9165B  X4 ",F71. A number of parties expressed concern about the outofband emission limits  X4 x proposed in the Notice. LSC, Raytheon and the GPS Council state that the proposed NTIA limits  X4 x are not stringent enough to protect GPS and GLONASS.~Z {O'ԍSee LSC comments at 1, Raytheon comments at 1, and the GPS Council comments at 6. However, AMSC and CCI state that  X4 xthe NTIA limits are too stringent.e {OR 'ԍSee AMSC comments at 3, and CCI comments at 3.e CCI objects to the fact that they have not been adopted  X4 xthrough a rule making.M~ {O 'ԍSee CCI comments at 3.M Moreover, MCHI believes that the Commission should wait to approve  x'equipment until final standards are adopted, since there may be difficulties in recalling or  xyretrofitting noncompliant equipment if the final standards adopted are more stringent than the  X 4 x<interim ones.P  {OB'ԍSee MCHI comments at 67.P TIA in their comments, and Globalstar/Airtouch, Iridium, MCHI, Motorola and  xORBCOMM in their reply comments, all state that the issue of outofband limits should be  Xg 4addressed in a separate rule making proceeding.g  {O' "y ԍSee TIA comments at 15, Globalstar/Airtouch reply comments at 5, Iridium reply comments at 5, MCHI reply comments at 2, Motorola reply comments at 8, and ORBCOMM reply comments at 3.  XM 4 "WG72. In addition to uniform support expressed for the Commission's intention to rapidly  ximplement the GMPCSMoU Arrangements, we also received comments concerning other issues  xrelated to the interim GMPCS equipment certification. Primary among these was an indication  xby several parties that the Commission was limiting the interim authorization procedure to "Big  X4 xLeos"  yO' " ԍ"Big Leo" systems provide voice and data MobileSatellite Service via a constellation of one or more nongeostationary orbit satellites operating in the band of 16101626.5 MHz. in the Notice. Final Analysis, ICO, Lockheed, ORBCOMM and Iridium all state that  X4the interim authorization procedure should apply to other mobile satellite terminals.T  {O!' " ԍSee Final Analysis comments at 3, ICO comments at 2, Lockheed comments at 2, ORBCOMM comments at 7, and Iridium reply comments at 3.  X4 "H73. In the Notice, we specifically proposed to apply an interim procedure for certifying  xZall GMPCSrelated terminal equipment where we have authorized service and which demonstrates" 0*%%ZZT"  x8compliance with the Commission's relevant Part 1 and Part 25 standards, including emission  X4 xlimits for "Little Leos" yOl' "t ԍ"Little Leo" systems provide dataonly MobileSatellite Service via a constellation of nongeostationary orbit satellites operating below 1 GHz. contained in 25.202(f).N  {O'ԍSee Notice at para. 45.N In light of the comments, we adopt the voluntary interim procedures for all GMPCS terminal equipment.  X4 "I74. For terminals operating in the 16101626.5 MHz band, we proposed to add a  xrequirement that the outofband emission limit of 70 dBW/MHz averaged over any 20  xmillisecond period for wide band emissions occurring between 15591605 MHz and 80 dBW/700  xHz for narrow band emissions occurring between 15591605 MHz would also need to be met.  x"We find that, for the following reasons, use of the proposed outofband emission standards for  x}terminals operating in the 16101626.5 MHz band will facilitate the authorization process for this  xequipment. First, the International Telecommunication Union's Radio Sector (ITUR) Study  x&Group WP 8D has adopted the proposed wideband standard as a recommendation for suppression  Xd 4 xof spurious emissions for MSS systems with mobile earth terminals.Vd  {O'ԍSee Recommendation ITUR M.1343V Similarly, the European  xCommission/CEPT adopted a European Testing and Standards Institute (ETSI) standard late last  xZyear for both CDMA and TDMAtype Mobile Satellite Service (MSS) systems based on this ITU X=4 x/R recommendation.=D {O2' " ԍSee ETSI standards TBR041 and TBR042 for Mobile Earth Terminals in the 1.6/2.4 GHz and 2.0 GHz range, respectively. Second, NTIA proposed both the wide and narrowband standards cited  xin its recent petition for rule making concerning outofband emissions standards for protection  xcof radionavigation devices. By using the most stringent requirement currently under review, we  xwill ensure that MCHI's concern over the recall or retrofit of noncompliant equipment in the  xfuture is minimized. Since the Commission will consider the NTIA petition for rule making in  x"conjunction with full implementation of the GMPCS Arrangements, any further concerns about  xuthe proposed NTIA outofband emission limits are best addressed in the future, separate proceeding.  X4 "J75. In adopting this standard for voluntary interim certification, we are not prejudging  xlthe standards that we will ultimately adopt in our future GMPCS proceeding. Rather, we are  xestablishing here a voluntary certification process designed to facilitate the circulation of GMPCS  xpterminals across borders, aiding system operators, manufacturers and users of GMPCS service.  xIf the standards we adopt in the GMPCS proceeding are more stringent than the ones used for  xinterim certification, we will require the terminals to meet the stricter standards, in accordance"!0*%%ZZ"  xwith any associated implementation provisions adopted in that proceeding. In order to be used,  x}the terminals must be operated with a satellite system or service provider authorized to provide  xEmobile satellite service in the United States. Subsequent to receiving a blanket authorization under Part 25 of the rules, terminals may be authorized under Part 2 of the rules.  X4 "qK76. Accordingly, we amend Part 25 of the rules to allow for the voluntary equipment  X4 xauthorization of all GMPCS terminals meeting the requirements set forth in our Notice.  xcAuthorizations granted under this interim provision will be conditioned on the equipment meeting all final standards eventually adopted for GMPCSrelated equipment.  Xt 4/ ORDERING CLAUSES ă  XZ 4 "L77. Accordingly, IT IS ORDERED that Parts 0, 2, 15, 25 and 68 of the Commission's  xRules and Regulations ARE AMENDED as specified in Appendix A effective 90 days after  xpublication in the Federal Register. This action is taken pursuant to Sections 4(i), 301, 302,  xV303(e), 303(f), 303(r), 304 and 307 of the Communications Act of 1934, as amended, 47 U.S.C. Sections 154(i), 301, 302, 303(e), 303(f), 303(r), 304 and 307.  X 4 "M78. IT IS FURTHER ORDERED that, pursuant to Section 5(c)(1) of the Communications  xAct of 1934, as amended, 47 U.S.C.  155(c)(1), authority is delegated to the Chief, Office of  xEngineering and Technology (OET) and the Chief, Common Carrier Bureau (CCB) to develop  xspecific methods that will be used by the National Institute for Standards and Technology (NIST)  xto accredit TCBs, consistent with the qualification criteria herein, to enter into a memorandum  xof understanding with NIST on the accreditation process for TCBs, to designate and withdraw  xRthe designation of TCBs, and to develop procedures that TCBs will use for performing postmarket surveillance.  X4 "N79. IT IS FURTHER ORDERED that the Commission's Office of Public Affairs,  xReference Operations Division, SHALL SEND a copy of this Report and Order, including the  xFinal Regulatory Flexibility Analysis in Appendix C, to the Chief Counsel for Advocacy of the Small Business Administration. "c"0*%%ZZM"  X4 "4O80. For further information regarding this Report and Order, contact Hugh L. Van Tuyl,  x<(202) 4187506, Office of Engineering and Technology. For Part 68 specific questions, contact  x/Vincent M. Paladini, (202) 4182332, Common Carrier Bureau. For Part 25 specific questions, contact Tracey Weisler at (202) 4180744. ` ` hhCFEDERAL COMMUNICATIONS COMMISSION ` ` hhCMagalie Roman Salas ` ` hhCSecretary "W #0*%%ZZ "  X' UAPPENDIX A ă  X4 1. a. i.(1)(a)(i) 1) a)P 1. a. i.(1)(a)(i) 1) a)IP FINAL RULES ă Part 0 of Title 47 of the Code of Federal Regulations is amended as follows:  X41. The authority citation for Part 0 continues to read as follows:  X' AUTHORITY: Sec. 5, 48 Stat. 1068, as amended; 47 U.S.C. 155, 225,  X'unless otherwise noted. Đ  Xq 42. A new paragraph 0.241(g) is added to read as follows:  XW 4Section 0.241 Authority delegated * * * * *  "(g) The Chief of the Office of Engineering and Technology is delegated authority to enter  xinto agreements with the National Institute of Standards and Technology to perform accreditation  xof Telecommunication Certification Bodies (TCBs) pursuant to  2.960 and 2.962 of this  xlchapter. In addition, the Chief is delegated authority to develop specific methods that will be  xused to accredit TCBs, to designate TCBs, to make determinations regarding the continued  xacceptability of individual TCBs, and to develop procedures that TCBs will use for performing postmarket surveillance.  X43. A new paragraph 0.291(i) is added to read as follows:  X4Section 0.291 Authority delegated * * * * *  "(i) The Chief, Common Carrier Bureau, is delegated authority to enter into agreements  xwith the National Institute of Standards and Technology to perform accreditation of  x3Telecommunication Certification Bodies (TCBs) pursuant to  68.160 and 68.162 of this chapter.  xIn addition, the Chief is delegated authority to develop specific methods that will be used to  xaccredit TCBs, to designate TCBs, to make determinations regarding the continued acceptability  xof individual TCBs and to develop procedures that TCBs will use for performing postmarket surveillance. "$$0*%%ZZ""ԌPart 2 of Title 47 of the Code of Federal Regulations is amended as follows:  X44. The authority citation for Part 2 continues to read as follows:  X' AUTHORITY: 47 U.S.C. 154, 302, 303, 307 and 336, unless otherwise noted.  X'SOURCE: 28 FR 12465, Nov. 22, 1963, unless otherwise noted. X` hp x (#%'0*,.8135@8:Implement Mutual Recognition Agreements and Begin Implementation of bthe Global Mobile Personal Communications by Satellite (GMPCS) HArrangements   a4\ I support adoption of this Report and Order. In my view, any reduction of unnecessary regulatory burdens is beneficial. To that extent, this item is good and I am all for it. This item should not, however, be mistaken for complete compliance with Section 11 of the Communications Act.   a4As I have explained previously, the FCC is not planning to "review all regulations issued under this Act . . . that apply to the operations or activities of any provider of telecommunications service," as required under Subsection 11(a)  a4in 1998 (emphasis added). See generally 1998 Biennial Regulatory Review  a4Review of Computer III and ONA Safeguards and Requirements, 13 FCC Rcd 6040 (released Jan. 30, 1998). Nor has the Commission issued general principles to guide our public interest analysis and decisionmaking process across the wide range of FCC regulations. In one important respect, however, the FCC's current efforts are more ambitious and difficult than I believe are required by the Communications Act. Subsection 11(a) "Biennial Review" requires only that the Commission  a 4"determine whether any such regulation is no longer necessary in the public interest" (emphasis added). It is pursuant to Subsection 11(b) "Effect of Determination" that regulations determined to be no longer in the public interest must be repealed or modified. Thus, the repeal or modification of our"#80*%%ZZ1#" rules, which requires notice and comment rule making proceedings, need not be accomplished during the year of the biennial review. Yet the Commission plans to complete roughly thirty such proceedings this year. I encourage parties to participate in these thirty rule making proceedings. I also suggest that parties submit to the Commission either informally or as a formal filing specific suggestions of rules we might determine this year to be no longer necessary in the public interest as well as ideas for a thorough review of all our rules pursuant to Subsection 11(a).  a 4Yi* * * * * * *#Xj\  P6G;XP#