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There have been 11 comment(s) made on this document:
  • Brian Scarpelli commented on 2012-06-29 16:29:31.516:
    The Telecommunications Industry Association (“TIA”) hereby submits input to the Federal Communications Commission’s (“FCC”) Office of Engineering and Technology (“OET”) on draft Laboratory Division Knowledge Database (“KDB”) publication 388624 (“KDB 388624”). Specifically, TIA submits the following input for OET’s consideration: • Because there has been several versions of KDB 388624 on software defined radios (“SDRs”) and the Telecommunications Certification Bodies (“TCBs”) have had ample time to understand the related guidance in these KDBs, SDRs should be removed from the Permit But Ask (“PBA”) process. • For modules and peripherals we do not see the rational for requiring a PBA if the SAR level is >1.2. As indicated above we don’t see the benefit of asking for a PBA unless the test conditions require a deviation from the existing test procedures. TIA has previously requested an extension of the due date for comments on draft KDBs as critical to industry’s ability to provide thoughtful comments. In order to facilitate review of industry’s concerns, TIA may submit comments to selected KDBs, subject to supplementation, after June 30, 2012. We therefore respectfully submit this comment to draft KDB 388624, and urge the Commission to adopt policies consistent with the above. View attachment associated with this comment
  • Todd Gallagher commented on 2012-06-27 13:16:57.92:
    PBA request – Dynamic tuning antenna - There should be some consideration to further define this PBA. Tunable antennas are characterize as having the ability to maximize gain in specific bands of operation. As the antennas will have a maximum gain number associated with each band how is this different than a static gain antenna? If the antenna is being used to support a module integration the maximum gain information on the grant still needs to be respected. The worst case gains are still being considered in the Class I or Class II permissive change. In the event of an accidental band selection the antenna would have a gain that is less than the reported maximum.
  • Todd Gallagher commented on 2012-06-27 13:15:47.77:
    PBA request – Dynamic tuning antenna - There should be some consideration to further define this PBA. Tunable antennas are characterize as having the ability to maximize gain in specific bands of operation. As the antennas will have a maximum gain number associated with each band how is this different than a static gain antenna? If the antenna is being used to support a module integration the maximum gain information on the grant still needs to be respected. The worst case gains are still being considered in the Class I or Class II permissive change. In the event of an accidental band selection the antenna would have a gain that is less than the reported maximum.
  • Steve Liu commented on 2012-06-26 11:05:11.216:
    Could FCC inform labs and TCBs when they expect this PBA list to be effective/published? We understand that last date for comments are June 30. However it was not announced when the final PBA list would be published. Thank you.
  • John Lewczak commented on 2012-06-25 09:12:13.55:

    [PBA List; Section B-21]: Wireless Charging Applications - Is there any reason to exclude devices with integral inductive charging circuitry, as opposed to an accessory battery door? Recommend extending exception to all clients otherwise meeting  KDB 648474 D03 requirements.

  • John Lewczak commented on 2012-06-25 09:10:34.08:
    [PBA List; Section B-15]: Dymanic Antenna Tuning - Dynamic antenna tuning may be used to allow an antenna to more effectively cover multiple frequency bands. In this case, the antenna tuning parameters could be static within any given band of operation, and thus indistinguishable from more traditional fixed component tuning. In this scenario, it is not clear why a PBA should be necessary. Perhaps the PBA requirement should be limited to schemes that vary tuning within a given band of operation, or dynamically during operation?
  • John Lewczak commented on 2012-06-25 09:04:59.38:

    [PBA List: Section B-16]: Power Reduction - When discussed at the recent TCB Workshop, the concern was over some of the more complicated/dynamic power reduction schemes that may have been submitted to date, or that the FCC anticipates will be submitted soon. However, the FCC should be able to tailor this PBA requirement to these complicated scenarios. Would the FCC consider allowing simple, static, state-based (i.e. lookup table)  power reduction schemes without a PBA? This would streamline much of the application process, and free OET resources to focus on the more complicated schemes.

  • David Case commented on 2012-06-25 08:22:43.316:
    In reviewing the PBA list, Cisco would like to propose that the FCC lab consider adding reviews of master products operating in the DFS bands to the PBA list. Given the basic radio requirements are the same as for client units operating in the 5250 -5350 MHz and 5470-5725MHz , a TCB should be able to complete a review of the non DFS test portion of device and the actual DFS test be reviewed as some SAR testing is under PBA process. The FCC would still do the audit of the DFS functionality but the overall process would still be streamlined since a TCB could review the complete report which also reduces time and cost to manufacturers who must draft 2 reports to file , one with TCB and one with FCC. Ths would further reduce the workload on the FCC lab and allow a more thorough review of the DFS capabilities of the system.
  • Cetecom ICT Services GmbH Schmidt commented on 2012-06-21 05:30:41.92:
    Item B(2) (ii) would also exclude DC-HSPA+ in rel. 8. Since dual carrier operation is limited to downlink operation only (DC-HSDPA only , DC-HSUPA is subject to rel 9) and the uplink is the same as rel 7 it should be allowed for TCB to approve the user devices without PBA. (when QPSK is used only) Item B (Headline) Not only SAR but also MPE is affected now. I guess that the MPE PBA is needed only for portable configurations where no standard SAR considerations are possible (outside 300 MHz - 6 GHz). If so the text should be adjusted accordingly. If not, please consider: - Typically MPE estimations as mentioned in OET Bulletin 65 overestimate the real situation and cover the worse case scenarios. Therefore MPE consideration for mobile and fixed applications should not be subject to PBA. - With special look to cellular base station in 3GPP Rel. 7 or higher, it should be allowed for TCB to proceed without PBA at least when the RF exposure compliance is addressed at the time of licensing.
  • Mark Briggs commented on 2012-06-14 12:36:29.136:
    Draft KDB 388624, Permit but Ask List – Comments Submitted by UL Section B, 6: Modules and peripheral transmitters with SAR greater than or equal to 1.2 W/kg subject to the “RF Exposure evaluation guidance for modules and peripheral transmitters” section of KDB Publication 447498. Comment: As told by FCC previously, this item is limited to user plug-in peripheral (USB Dongle or PCMCIA). In KDB 447498 for RF exposure evaluation guidance for modules and peripheral transmitters section, many devices configuration are covered in this section. Request to provide a more precise device configuration to item 6. Section B, 14.When SAR test guidance is unavailable for uplink MIMO and other transmit antenna diversity configurations. Comment: Since FCC has not yet published SAR test guidance for uplink MIMO devices, by adding this line item, many MIMO (2Tx2R; 3Tx3R, 4Tx4R) will be subject to PBA procedure. Before this draft KDB, FCC only required 3Tx3R or above MIMO portable device to apply PBA procedure. We would like to suggest FCC limit the PBA to MIMO portable devicse which meet the following criteria: 1. TX-to-TX antenna physical separation distance is less than 5mm, and 2. The highest individual TX SAR value is >= 1.2 W/kg.
  • David Case commented on 2012-05-31 16:03:02.31:
    Cisco supports a view that since there has been several versions of the KDB on SDR and that the TCB's have had ample time to learn the requirements that SDR be removed from the PBA process.

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.