- Kwok Chan commented on 2009-11-05 17:38:34.893:
For the comments at the end:
The supplemental laptop/notebook/netbook procedures include simultaneous transmission. The applicable simultaneous transmssion configurations and conditions should be clearly described in the instructions the grantee provides to its OEM integrators. The qualified simultaneous transmission conditions are allowed and applicable grant comments should be applied. This document provides test related guidance. Grant comments will need to be addressed separately in other KDB publications. Until additional guidance is available for grant conditions, when it is unclear, the TCB should submit a KDB inquiry to determine applicable grant conditions.
- John Forrester commented on Nov 5 2009 3:31PM:
- John Forrester commented on Nov 5 2009 3:48PM:
KDB616217 supplicate note clearly indicates collocated transmitters are added through a Class I permissive change providing the technical requirements are satisfied. Based on this, will the non-collocated grant note be removed from module and host grants or replaced by a modified grant note addressing when collocation is allowed.
As an example, consider a Class II change adding a conservative notebook for a wireless module. A collocated report is not submitted with the Class II application as long as it is not required per the 616217 supplement note. The grant note could then read Collocated transmission is allowed providing the appropriate technical requirements for the combined transmitters are addressed in a Class I or II change.
- Kwok Chan commented on 2009-11-05 17:25:29.32:
For the comments at the end:
The formula (5+n/2) cm is explained and identified in the original KDB publication 616217, which has been in use for over 3 years to determine SAR test reduction for antennas installed on laptop computer display screens. The propsoed supplemental procedures are extensions to the original KDB 616217 that enable flexibility for recent generation notebook and netbook computers. The equation in 4)b)i) are based on the 5 cm peak SAR location separation described in KDB 648474 (handset SAR procedures). Since the dimensions of laptop computers are much larger than cellphones, the original equation needs to be modified to enable flexibility at both small than 5 cm and substantially larger than 5 cm separations, to further reduce unnecessary testing in laptop configurations. While various laptop/notebooh/netbook computers are on the market, current SAR measurement standards do not have specific procedures to streamline the test requirements for the complex cnfigurations and flexibility required by this type of products.
Draft IEC 62630 was developed as a Technical Report to provide IEC TC-106 sub-committees and workings with uniform concepts to develop RF exposure standards through releant projects. When these concepts are incorporated into the relevant SAR measurement standards and published, they will be reviewed and considered accordingly. The issues and difficulties described in this suplemental laptop/notebook/netbook document are not addressed in on-going SAR measurement standards, including IEC 62209-2. This document has little or no overlap with the procedures in existing and on-going SAR measurement standards.
John Welch commented on Nov 5 2009 1:37PM:
These comments submitted on behalf of Motorola, Inc.
Explanations or references to a relevant standard should be provided for the formula (5+n/2) cm and the formula in 4) b) i). Motorola recommends that FCC adopt without modification the procedures set forth in IEC 62209-2 and IEC Technical Report 62630 when they are published in early 2010. Such action would be beneficial for worldwide harmonization of guidance and regulations.
- John Forrester commented on 2009-11-05 15:48:08.6:
KDB616217 supplicate note clearly indicates collocated transmitters are added through a Class I permissive change providing the technical requirements are satisfied. Based on this, will the non-collocated grant note be removed from module and host grants or replaced by a modified grant note addressing when collocation is allowed.
As an example, consider a Class II change adding a conservative notebook for a wireless module. A collocated report is not submitted with the Class II application as long as it is not required per the 616217 supplement note. The grant note could then read Collocated transmission is allowed providing the appropriate technical requirements for the combined transmitters are addressed in a Class I or II change.
- John Forrester commented on 2009-11-05 15:31:50.903:
KDB616217 supplicate note clearly indicates collocated transmitters are added through a Class I permissive change providing the technical requirements are satisfied. Based on this, will the non-collocated grant note be removed from module and host grants or replaced by a modified grant note addressing when collocation is allowed.
As an example, consider a Class II change adding a conservative notebook for a wireless module. A collocated report is not submitted with the Class II application as long as it is not required per the 616217 supplement note. The grant note could then read Collocated transmission is allowed providing the appropriate technical requirements for the combined transmitters are addressed in a Class I or II change.
- John Welch commented on 2009-11-05 13:37:36.836:
These comments submitted on behalf of Motorola, Inc.
Explanations or references to a relevant standard should be provided for the formula (5+n/2) cm and the formula in 4) b) i). Motorola recommends that FCC adopt without modification the procedures set forth in IEC 62209-2 and IEC Technical Report 62630 when they are published in early 2010. Such action would be beneficial for worldwide harmonization of guidance and regulations.
- Kwok Chan commented on 2009-11-04 16:44:33.763:
For the comments at the end:
1. As discussed during the October 2009 TCB workshop, the supplemental procedures apply to both laptop/notebook/netbook and table computer host platforms.
2. As discussed during the October 2009 TCB workshop, you are encouraged to use the supplemental procedures to reduce subsequent unnecessary test and permissive change requirements. However, if you choose to use the original procedures in KDB 616217 for laptop display screen only, you must not mix the original and the new supplemental procedures as these can cause administrative and other technical issues due to many of the previus host specific permissive approvals.
3. Since you do have a choice to choose between the original KDB 616217 and the more flexible supplemental procedures, the assumption of [shall be used] as indicated in 2a i) - iii) of your comment would be incorrect.
4. Since you are given the choice to choose between the original and the new procedures and the new procedures are expected to provide the needed flexibility, it would be in everybody's interest to avoid many of the lingering filing, administrative and permissive change problems associaed with many of those previous filings; therefore, no mixing and you are encouraged to use the new procedures. As discussed during the TCB workshop, we plan to gradually phase out the original procedures.
5. Transmitter manufacturers and grantees do not need to test for the external connector and card slot configurations. They only need to fully inform and ensure their clients (typically OEM integrators) that a minimum separation of 5 cm is required between devices plug into these connectors/slots and the antennas they are incorporating in their host computers. If a product cannot maintain the required 5 cm separation, the supplemental notetop/notebook/netbook procedures do not apply; however, they may still seek approval for the specific host configurations with proper testing.
6. The grantee is the responsible party and is required to ensure its clients (OEM integrators etc.) fully understand how the specific transmitter must be incorporated into qualified host configurations to meet the grantee's equipment certification requirements. The OEM integrators must comply with the grantee's instructions to properly implement the transmitter/antenna into its computer hosts; includng simultaneous transmission conditions; therefore, minimizing any unnecessary tests and permissive changes for the OEM.
Mike Kuo commented on Nov 3 2009 5:01PM:
SAR Evaluation Considerations for Notebook/Netbook and Laptop Computers
Supplement to KDB 616217
1. This supplement applies to transmitters and antennas incorporated in notebook/Netbook and laptop computers for use in laptop or tablet modes, including those with display screens less than 12.1
a. Comments: Based upon above statement, supplement to KDB 616217 procedure can be used for tablet computer as well. Please help to confirm.
2. If antennas are incorporated in the display only and providing more than 5 cm separation from users, the procedures in KDB 616217 may continue to be applied.
a. Comments: Below is my understanding:
i. For screen size greater than 12 inches and antenna-to-antenna separation distance is > 5 cm, KDB 616217 shall be used to assess test configuration and simultaneous transmission requirements.
ii. For screen size greater than 12 inches and antenna-to-antenna separation distance is less than 5 cm, supplement to KDB 616217 shall be used to assess simultaneous transmission requirements.
iii. For screen size less than 12 inches and antenna-to-antenna separation distance is either > 5 cm or < 5 cm, supplement to KDB 616217 shall be used to assess simultaneous transmission requirements.
3. However, it is unacceptable to mix the simultaneous transmission procedures in this supplement with those in KDB 616217.
a. Comments: Do not understand the concerns here. It will be very helpful if FCC can provide an example and RF exposure concerns for above statement. If there are no significant RF exposure concerns, it is suggested to harmonize simultaneous transmission consideration for KDB 616217 and supplemental KDB 616217 with same requirements. Section 4)a) and section 4)b) calculation are easy to understand and suggest to use the calculation provided in supplemental KDB 616217 for all notebook/Netbook/laptop/tablet computers regardless screen size and antenna-to-antenna distance.
4. Transmitters/antennas operating from external card slots and or connectors of the hosts must be more than 5 cm from any simultaneous transmitting antennas to ensure possible combined exposures due to user installed transmitters, such as Card Bus and USB devices, are insignificant.
a. Comments: Since Card Bus and USB devices are after the market devices purchased by the end user. It is not possible for module or host integrator manufacturers to assess RF exposure consideration for these devices. For CardBus and USB devices manufacturers, it is difficult for them to anticipate the host configurations that these devices will be used with. In case of tablet computer with PCMCIA slots or USB connectors, there is great possibilities the user installed Cardbus and USB device will be within 5 cm to the installed transmitting antenna(s). Additional guideline may be needed to determine the responsible party to address RF exposure compliance issues.
Mike Kuo/ CCS
- Kwok Chan commented on 2009-11-04 16:05:59.543:
In general, FCC rules use the term routine (SAR) evaluation, which may include measurement, computational modeling and other forms of analysis, as appropriate for demonstrating compliance. In most cases, the type of evaluation necessary are self explanatory within the context of the procedures. When appropriate, we will consider using more specific terms; especially when measurements are unnecesary and analysis is required to qualify for SAR test exclusion.
John Forrester commented on Nov 4 2009 10:13AM:
There are numerous references to SAR evaluation. It sometimes unclear what is meant by evaluation as it has different meaning for the certifications is evaluation is a SAR measurement vs. paper summation analysis. Recommendation: When evaluation is a measurement, clarify that SAR evaluation is an actual measurement. As an example, section 7 and 8 would change to SAR measurements or other wording. This would avoid any confusion with TCBs and manufactures between completing an actual measurement vs. doing a paper analysis of existing data.
- Kwok Chan commented on 2009-11-04 15:51:14.03:
For the comments included at the end:
1. Laptop/Notebook/Netbook and Tablet computers are considered separate host platforms.
2. Near-field exposure is typically dominated by the RF current distribution on the device (chassis), antenna(s), cables etc. and also the energy coupling conditions dictated by the relative locations of the device/transmitter/antenna and the user. Under these circumstances, replacing an antenna with lower gain does not always ensure there would be no noticeable changes to the RF current distribution and energy coupling conditions that can influence the SAR.
3. Even for the same type of antenna with the same gain, if there are certain design or construction variations that could change the RF current distribution and energy coupling conditions, certain SAR changes might be expected. It is a matter of how to estimate the SAR impact with respect to the original SAR data to determine if there is a need to re-evaluate the SAR.
========================================================================
Mike Kuo / CCS
Question #1:Based upon the description in KDB 447498, Netbook/notebook/laptop is defined as same platform. PDA and tablet PC are defined as separate platform. Please help to confirm this understanding.
Question #2: Page 2, third paragraph, " Antenna gain is a far field parameter. It is generally not directly related to near-field exposure conditions, which can be highly dependent on the RF current distribution characteristics of the individual transmitter, antennas and host configurations. Without taking into consideration the near field exposure characteristics and parameters it would be inappropriate to assume that lower gain antennas always result in lower SAR; therefore, antenna gain is generally not used to assess the SAR evaluation requirements of devices operating at close proximity to users."
I have difficulties in understanding above paragraph. Since antenna gain is far field parameter which is not directly related to near-field exposure conditions, why " would be inappropriate to assume that lower gain antenna always result in lower SAR"? What are consideration shall be taken to assess near field exposure characteristic and parameter?
Based upon SAR evaluation experiences, if the same antenna type is used, the antenna gain has no direct impact on SAR measurement. However, the antenna cable routing path within the host sometime will contribute un-expected SAR values increase.
Best Regards
Mike Kuo / CCS
- Kwok Chan commented on 2009-11-04 15:38:12.95:
In response to comments at the end:
As discussed in the October 2009 TCB workshop, the supplemental laptop/netbook/netbook procedures to KDB 616217 should minimize 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 can be included as an Appendix to this supplemental document to KDB 616217.
We are unable to provide specific case-by-case guidance on procedures a test lab may provide or recommend to its clients. There are also a number of items that are outside the scope of this supplemental draft document; therefore, it would be inappropriate to address those here.
Please note that the OEM integration and installation instructions and applicable grant conditions must agree with the device test configruations and be supported by the test results without any conflict. Certain generic instructions and grant comments often need review and examination to suit individual approval. These should be addressed through KDB inquiries, as necessary, for the specific equipment certificaion application.
For SAR test requirements relating to lower gain antennas of the same type, please see KDB 178919 (Permissive Change), section 5 b)iii)3 for additional guidance
Mike Kuo commented on Oct 16 2009 5:40PM:
As informed by FCC during Oct. 2009 TCBC workshop, modular manufacturers and host integrators should consider the published KDB 616217 and KDB 447498 to minimize number of Class II permissive change and change in identification filings.
CCS is submitting attached document to explain the concerns by the module manufacturers and host integrator. Informative procedure is also included based upon current published KDB 616217 and KDB 447498.
- John Forrester commented on 2009-11-04 10:13:33.906:
There are numerous references to SAR evaluation. It sometimes unclear what is meant by evaluation as it has different meaning for the certifications is evaluation is a SAR measurement vs. paper summation analysis.
Recommendation: When evaluation is a measurement, clarify that SAR evaluation is an actual measurement. As an example, section 7 and 8 would change to SAR measurements or other wording. This would avoid any confusion with TCBs and manufactures between completing an actual measurement vs. doing a paper analysis of existing data.
- Mike Kuo commented on 2009-11-03 17:01:22.636:
SAR Evaluation Considerations for Notebook/Netbook and Laptop Computers
Supplement to KDB 616217
1. This supplement applies to transmitters and antennas incorporated in notebook/Netbook and laptop computers for use in laptop or tablet modes, including those with display screens less than 12.1
a. Comments: Based upon above statement, supplement to KDB 616217 procedure can be used for tablet computer as well. Please help to confirm.
2. If antennas are incorporated in the display only and providing more than 5 cm separation from users, the procedures in KDB 616217 may continue to be applied.
a. Comments: Below is my understanding:
i. For screen size greater than 12 inches and antenna-to-antenna separation distance is > 5 cm, KDB 616217 shall be used to assess test configuration and simultaneous transmission requirements.
ii. For screen size greater than 12 inches and antenna-to-antenna separation distance is less than 5 cm, supplement to KDB 616217 shall be used to assess simultaneous transmission requirements.
iii. For screen size less than 12 inches and antenna-to-antenna separation distance is either > 5 cm or < 5 cm, supplement to KDB 616217 shall be used to assess simultaneous transmission requirements.
3. However, it is unacceptable to mix the simultaneous transmission procedures in this supplement with those in KDB 616217.
a. Comments: Do not understand the concerns here. It will be very helpful if FCC can provide an example and RF exposure concerns for above statement. If there are no significant RF exposure concerns, it is suggested to harmonize simultaneous transmission consideration for KDB 616217 and supplemental KDB 616217 with same requirements. Section 4)a) and section 4)b) calculation are easy to understand and suggest to use the calculation provided in supplemental KDB 616217 for all notebook/Netbook/laptop/tablet computers regardless screen size and antenna-to-antenna distance.
4. Transmitters/antennas operating from external card slots and or connectors of the hosts must be more than 5 cm from any simultaneous transmitting antennas to ensure possible combined exposures due to user installed transmitters, such as Card Bus and USB devices, are insignificant.
a. Comments: Since Card Bus and USB devices are after the market devices purchased by the end user. It is not possible for module or host integrator manufacturers to assess RF exposure consideration for these devices. For CardBus and USB devices manufacturers, it is difficult for them to anticipate the host configurations that these devices will be used with. In case of tablet computer with PCMCIA slots or USB connectors, there is great possibilities the user installed Cardbus and USB device will be within 5 cm to the installed transmitting antenna(s). Additional guideline may be needed to determine the responsible party to address RF exposure compliance issues.
Mike Kuo/ CCS
- Mike Kuo commented on 2009-10-16 17:40:08.966:
As informed by FCC during Oct. 2009 TCBC workshop, modular manufacturers and host integrators should consider the published KDB 616217 and KDB 447498 to minimize number of Class II permissive change and change in identification filings.
CCS is submitting attached document to explain the concerns by the module manufacturers and host integrator. Informative procedure is also included based upon current published KDB 616217 and KDB 447498.
Best Regards
Mike Kuo / CCS
View attachment associated with this comment
- Mike Kuo commented on 2009-10-13 16:13:03.033:
Dear FCC:
Question #1:Based upon the description in KDB 447498, Netbook/notebook/laptop is defined as same platform. PDA and tablet PC are defined as separate platform. Please help to confirm this understanding.
Question #2: Page 2, third paragraph, " Antenna gain is a far field parameter. It is generally not directly related to near-field exposure conditions, which can be highly dependent on the RF current distribution characteristics of the individual transmitter, antennas and host configurations. Without taking into consideration the near field exposure characteristics and parameters it would be inappropriate to assume that lower gain antennas always result in lower SAR; therefore, antenna gain is generally not used to assess the SAR evaluation requirements of devices operating at close proximity to users."
I have difficulties in understanding above paragraph. Since antenna gain is far field parameter which is not directly related to near-field exposure conditions, why " would be inappropriate to assume that lower gain antenna always result in lower SAR"? What are consideration shall be taken to assess near field exposure characteristic and parameter?
Based upon SAR evaluation experiences, if the same antenna type is used, the antenna gain has no direct impact on SAR measurement. However, the antenna cable routing path within the host sometime will contribute un-expected SAR values increase.
Best Regards
Mike Kuo / CCS
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