• Randy Clark commented on 2011-10-20 16:11:05.866:
  Several comments are provided in the attached PDF. View attachment associated with this comment

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• David Case commented on 2011-10-18 14:38:30.023:
  In reviewing the proposed changes, Cisco supports the proposal to allow conducted measurements for restricted band emissions from the antenna port and then requiring case radiation scan. We have always advocated consideration of this procedure and believe it will bring the process in line with testing requirements of other rule parts. We like to see this proposal if adopted expanded to include testing for U-NII devices operating under Part 15.407 of the rules as well.

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• William Graff commented on 2011-10-07 13:01:17.646:
  Gentlemen, I would like to comment on the proposed radiated-to-conducted RF Pout procedure. For devices which are used exclusively in an RF category “Mobile” or “Fixed” environment, the proposed method for working backwards from radiated values and using the manufacturers claimed antenna gain should be satisfactory. However, for any RF power measurements with RF category “Portable” devices, this method is insufficiently precise. In general, RF power measurements when SAR measurements may also be required would need a consistent accuracy of less that 10% (linear). But even if the antenna gain claims could be trusted, OATS site-to-site inaccuracy could never assure this required accuracy. As an alternative, I would like to propose that the antenna substitution method identified in TIA/EIA 603 be utilized for making better EIRP assumptions before subtracting antenna gain. Performed properly, and accounting for all VSWR errors, substitution will negate site-to-site errors, making this method an extremely valuable tool. In fact, I would strongly encourage the substitution technique to be used for all “Portable” devices which may require SAR testing. In addition, please add some notes specifying that RF power must be checked across all data rates. Variations of 4dB in power on 802.11b/g devices between low and high data rates are not uncommon. Best Regards, Bill Graff

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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.