• Mark Briggs commented on 2012-05-31 14:34:06.63:
  Steve, Just adding in comments we dicussed via email. I think you have addressed these already but here they are for the record: 1) I am still not sure I fully understand why a device that operates across the 5725 MHz boundary has to be considered as either UNII or DTS, but not both. Is it not possible for the device to be granted under both NII and DTS rules – example: • 20MHz operating mode is approved under NII for channels 100 – 140/144 (5500 MHz – 5700/5720 MHz) and DTS for channels 149 - 165 (5745 – 5825). Alternatively approve 20MHz mode as NII from 5500 through 5805 MHz and DTS for that one channel at 5825 MHz. • 40MHz, 60MHz and 80 MHz modes could be approved under NII for all operating channels. As the device cannot operate simultaneously under both NII and DTS grant conditions (it is either one or the other, not both) I would think the 15.215(c) requirement is still met. Example, in 20MHz mode the device is either operating under the NII grant code or under DTS grant code … there is no channel that would be operating under both. I recognize that devices capable of operating with mutliple transmitters (e.g. collocated, independent 802.11 radios) would need special consideration to determine the aggregate power in the 5725-5825/5850 MHz band when they could be operating under both NII and DTS rule parts simultaneously. Example grant conditions (or, perhaps considering separate line items for each operating mode) would help clearly show how the power listings reflect actual usage. 2) Why does the total power across an entire emission need to comply with the highest single band limit and the partial band limits? There are devices already approved containing multiple individual transmitters (admittedly, each transmitter is operating independently in these devices) that can operate in individual bands simultaneously and for these devices the only limitation is only total power within a band meeting the limits. I would think that provided the total power within each band complies with the power and PSD limits for that band the only purpose for measuring the total power across the entire signal bandwidth would be for rf exposure purposes

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• Bill Graff commented on 2012-05-18 19:45:44.403:
  Gentlemen, It would probably be worth-while reminding test laboratories that compliance with the provisions of 15.215 is expected and required. I would expect that applicants in the rush to place 802.11ac devices into the marketplace will initially seek NII certification in the 5150-5250 MHz band as well as the 5GHz DTS band. Only later will they use the PCII route to add the DFS bands. Meeting the 20dBc and/or the 15.209 limits exactly at 5250 MHz could be challenging for a maturing technology. Therefore, it should be necessary for developers and laboratories to be diligent when measuring an 80MHz wide channel centered within a 100MHz wide band.

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• David Case commented on 2012-04-30 11:00:15.913:
  In regards to the discussion at the recent TCB conference, an idea was floated to allow the grantee to possibly apply Part 15.407 U-NII band requirements in the entire band of 5725 - 5850 MHz instead of 5725 -5825 MHz only. This would allow a manufacturer to choose between either getting approval to Part 15.247 opr Part 15.407 in the upper vand which would not only streamline the 802.11ac testing in the upper band but also make the test procedures and testing results possibly more accurate. Further by allowing Part 15.407 to be utilized for the upper 25MHz, would remove any ambiguity in differences between the two rule parts when operating in this band.

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• Mark Hill commented on 2012-04-26 12:24:28.016:
  See attachment. Thanks - Mark View attachment associated with this comment

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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.