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There have been 4 comment(s) made on this document:
  • Patrick Sullivan commented on 2009-11-04 17:19:09.053:
    Proposal #1: The Telecommunications Industry Association (TIA) urges the Commission to establish an expected duration or “speed of service” for Permit But Ask (PBA) review by the FCC. Explanation: Such a “speed of service” benchmark will assist manufacturers in planning and scheduling submissions. Proposal #2: TIA urges the Commission to create a “fast track” process which expedites the PBA approval whenever the request is based on a previously approved procedure and the associated KDB Inquiry Tracking Number is included. Explanation: Such a process will reduce testing redundancy and speed innovative products to market. TIA appreciates the Commission’s thoughtful consideration of these matters.
  • John Forrester commented on 2009-11-04 10:17:41.756:
    1. Some TCB’s reference Section 3 and request that a pre-submission KDB be filed for every HSPA device. This does not seem to be the FCC’s intent. Recommendation: To avoid numerous repeat pre-filing KDBs, consider adding a line that specifically states FCC KDB’s can be used as that guidance if available. As an example, the KDB 914225 can be referenced for HSPA+ devices. The TCB PBA is still required. 2. “Ev-DO” should be “CDMA2000 1xEVDO”, or “EVDO”. You can leave Ev-Dv to be safe, but the EVDV standard is not implemented.
  • Steve Liu commented on 2009-11-03 17:35:47.056:
    Page 3 - 2)d)i - clarify that the non-TCB just needs to state the "pertinent" rule parts. sometimes the lab may not know finally what rule parts are applicable entirely. 2)d)ii. - equipment classes. Same as above, incorporating language that makes it clear to just state the pertinent equipment class relevant for guidance sought. 3)d)i)(1) - clarification to say the "related TC#" under the sought guidance. i.e. so not listing TC's where the PBA does not apply.
  • Mike Kuo commented on 2009-10-16 16:01:47.476:

    Dear FCC:

     

    By reviewing this draft KDB 388624, I found there is no change in the PBA procedures for non-TCB and TCB.  The only difference is to remove some of devices/technologies from PBA list.  PBA procedure has been implemented for one year, below are my observation and suggestions:

     

    1. When test lab or manufacturer submitting non-TCB PBA to FCC, during this procedure, FCC engineer sometime asked for the SAR test report.  However, non-TCB PBA is designed to help the test lab and manufacturer to determine the test configuration and test requirements.  When CCS is submitting non-TCB PBA, we are typically not submitting SAR test report and awaiting FCC reply to confirm the test configuration that we proposed.  After one week or so, we received FCC reply and asking for SAR test report.  It is true that CCS will perform SAR tests before receiving FCC reply during non-TCB process, if SAR test report is required during non-TCB PBA process, CCS will submit SAR test report at the initial PBA submittal but not wait for one week and then submit the SAR test report.  I would like to request FCC to clear define the required information during non-TCB PBA process in order to speed up the process.

     

    2. As previously required during TCBC/FCC monthly conference call, all Class II permissive change filing requires separate non-TCB and TCB PBA process.  Since the non-PBA tracking number and TCB PBA tracking number are confidential information that only available to those who submitted the PBA.  I am requesting FCC to consider not to require non-TCB and TCB PBA process for future Class II permissive change filings.  PBA tracking number should be able to re-use for those parties submitted the PBA.

     

    3. The questions asked by FCC review engineer on the same device often time will vary.  Sometime I am wondering the information submitted in the PBA has been actually reviewed by FCC review engineer.  Some of questions that we received during PBA process are copy and paste from other applications and may not necessary applicable to the device in question. 

     

    4. If the test lab is also a TCB, I am requesting FCC to consider to waive non-TCB PBA requirements for the test lab.
     
    Best Regards
     
    Mike Kuo / CCS

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