• Randy Clark commented on 2009-10-22 19:55:30.546:
  With regard to RF exposure conditions, the document leads the reader to infer all conditions require commission review. I don't believe this was the original intent. I recommend clarifying the conditions under which additional guidance would be required. For example, an inductive charging system under part 18 which is used next to the body to charge an implanted device may require guidance from the comission. I suggest a possible clarification: RF charging devices would require comission review if the following conditions are met: 1) operating under part 18 and with fundamental field strength measurements above the appropriate spurious emissions limit (18.305(b)) 2) the equipment is used in portable operating conditions. Since most part 15 devices do not have RF exposure requirements, does this mean that a part 15.225 portable indicuctive charger would also require guidance, or would this equipment be exempt from RF Exposure review? I suggest a clarification: For individual part 15 only compliant devices, additional RF exposure evaluation is not required (except where otherwise required by part 15). Those combination part 15 and 18 devices where RF exposure may be a concern would already be directed to the comission due to the critieria listed above. Regarding the statement, "It is possible that the power charging function could also be approved under Part 15 rather than Part 18 if the device meets all of the requirements of the appropriate rule part." Why would this require commission review? If a charging device can be approved under part 15 and the device meets all applicable criteria, then there should not be any further clarifiction necessary. However, if the comission is concerned that a purely analog device with no digital circuitry and no data communication would be inappropriately certified under part 15, then this statement should be removed as a possible option. It is my opinion that the statement remain, and if the device meets part 15 requirements then further clarification should not be necessary.

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• Tim Johnson commented on 2009-10-17 02:00:52.9:
  Given the current draft - it appears the FCC is asking for consultation in all cases for a) which rules to apply (15 vs. 18) and b) for RF exposure considertaions. If this is the intent, FCC should consider adding to PBA procedures.

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