Tim Harrington commented on 2009-11-06 19:41:48.59:
A) For the Nov 5 2009 1:49PM John Welch comments:
We anticipate revising appropriately; please note also that KDB 447498 item 2) b) ii) (1) requires a single fixed probe position only, well within the capability of SAR systems, and as a part of the specific relative-level testing while device spacing is varied.
B) For the Nov 4 2009 10:15AM John Forrester comments:
1) To our recall this topic was considered during past periodic discussions with TCBs, for example leading to July 2008 version of KDB 447498. Regardless, we will review text to determine whether other changes may be appropriate.
2) As discussed during the October 2009 TCB workshop, the supplemental procedures to KDB 616217 apply for both laptop / notebook / netbook computer and tablet computer host platforms. Parties are encouraged to use the KDB 616217 supplemental procedures where applicable to reduce subsequent unnecessary test and permissive change requirements. However, while use of the generic procedures in KDB 447498 is not precluded for tablet computers, parties must not mix the original and the new supplemental procedures as these can cause administrative and other technical issues due to many of the previous host-specific permissive-change approvals.
3) We will review text to determine whether other changes may be appropriate.
4) As discussed during the October 2009 TCB workshop, such device configurations and exposure conditions may apply certain not-source-based low transmission duty factor considerations; however SAR testing is not applicable for device positioned at arbitrary separation distances.
5) As discussed during the October 2009 TCB workshop, for such device configurations and exposure conditions certain interim policies and recommendations are provided but uniform procedures for inclusion in KDB publications are not established.
C) For the Oct 28 2009 7:20PM Mike Kuo comments:
We confirm and anticipate revising accordingly.
D) For the Oct 16 2009 3:17PM Mike Kuo comments:
As discussed in the October 2009 TCB workshop, the supplemental laptop / notebook / netbook procedures to KDB 616217 should assuage many of the existing issues described in your attachment. It was suggested during the TCB workshop and we plan to include additional guidance on how to test for conservative SAR configurations. This could be included as an appendix to the supplemental document to KDB 616217.
E) For the Oct 16 2009 3:14PM David Case comments:
We will consider these suggestions in the next revisions of KDB 248227, and KDB 447498 where applicable. To our understanding 802.11n was finalized under the IEEE process as of Sep. 2009. As the official publication becomes available we will begin considering the issues and changes then work on revising the existing 802.11 and MiMo SAR testing guidance accordingly.
John Welch commented on 2009-11-05 13:49:38.186:
These comments submitted on behalf of Motorola, Inc.
Comments on Section 2 b) ii 1: Motorola recommends changing the fixed distance from one half the probe tip diameter to the distance equivalent of that used during the zoom scan measurement. The rationale for this recommendation is that specifying one half probe tip diameter distance could introduce higher measurement uncertainty due to boundary effects and physical damage to fragile high frequency probes whose tip diameter is 2.5 mm.
Mike Kuo commented on 2009-10-28 19:20:22.186:
Section 2)b)ii)2) :
(2) When the device position in item 2) b) ii) (1) with the highest point SAR is > 25% of that measured at the initial position, a complete 1-g SAR evaluation is required for this configuration.
Comment: With confirmation from FCC, the intended requirement should be " with the highest point SAR is > 125% (1.25) of that measured at the inital position, a complete 1-g SAR evaluation is required for this configuration."
Mike Kuo commented on 2009-10-16 15:17:21.373:
Dear FCC:
Attached please find SAR measurement procedure proposal to utilize KDB 447498 section 2)a)i) to reduce number of SAR evaluations and permissive change filings:
Best Regards
Mike Kuo / CCS
View attachment associated with this comment
David Case commented on 2009-10-16 15:14:59.61:
1) Under General requirements the document states that when applicable KDB # 248227 should be used for 802.11a/b/g for antenna diversity. Given the fact that 802.11n products have been approved and that it uses the same modulation OFDM as 802.11g / a (except for BW), should this document also not refer to using KDB 248227 for 802.11n testing. at least for initial reference. Note; In reviewing KDB 248227, one set of missing information that needs to be added includes the 802.11n channel sets for the 5470-5725 MHz, these are listed in the current version of the standard..
2) In addressing MiMo and beam forming antennas, it currently states one needs to discuss the testing with the FCC lab. In order to insure uniform testing across all product lines by all manufacturers and given that the current IEEE 1528 standards does not address the issue at this time, will the FCC be issuing further guidance on MiMo and beam forming testing in the near future?
David Case commented on 2009-10-16 08:51:00.54:
1) Under General requirements the document states that when applicable KDB # 248227 should be used for 802.11a/b/g for antenna diversity. Given the fact that 802.11n products have been approved and that it uses the same modulation OFDM as 802.11g / a (except for BW), should this document also not refer to using KDB 248227 for 802.11n testing. at least for initial reference. Note; In reviewing KDB 248227, one set of missing information that needs to be added includes the 802.11n channel sets for the 5470-5725 MHz, these are listed in the current version of the standard..
2) In addressing MiMo and beam forming antennas, it currently states one needs to discuss the testing with the FCC lab. In order to insure uniform testing across all product lines by all manufacturers and given that the current IEEE 1528 standards does not address the issue at this time, will the FCC be issuing further guidance on MiMo and beam forming testing in the near future?