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There have been 4 comment(s) made on this document:
  • Brian Scarpelli commented on 2012-06-29 16:37:39.12:
    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 648474 (What are the test procedures for Specific Absorption Rate [“SAR”] evaluation for handsets that contain multiple transmitters and antennas or wireless charging battery covers?) (“KDB 648474”). Specifically, TIA submits the following input for OET’s consideration: • In Section G (page 6), Specific Anthropomorphic Mannequin (“SAM”) limitations are provided. TIA believes that, with respect to SAR probe access, these limitations should apply to all SAR testing and not just multiple transmitters. Therefore, TIA proposes that this section be relocated to the more general KDB 865664. Given the potential impact of the proposed KDBs on test time, lab capacity, and even product design, we request that OET determine and announce a reasonable transition period for implementation of the KDBs once finalized. TIA members recommend that a transition period of at least ninety days in order to mitigate the impact that such extensive changes to testing protocols will have. 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 648474, and urge the Commission to act consistent with the above. View attachment associated with this comment
  • Steve Liu commented on 2012-06-26 10:53:57.006:
    Thank you for your work in updating these KDBs. PCTEST submits comments regarding this draft publication in the attached file. Thank you. View attachment associated with this comment
  • John Lewczak commented on 2012-06-25 09:30:30.606:

    [KDB 648474, SAR Evaluation Considerations for Handsets with Multiple Transmitters and Antennas; Section G]: SAM Phantom Limitations - This issue is not solely limited to products with multiple transmitters and antennas. The difficulties of measuring SAR in the tight areas of the SAM phantom head is common to all SAR testing. Please consider moving this section to KDB 865664 so that it is clearly applicable to all SAR testing.

  • Kai Niskala commented on 2012-06-25 06:20:10.64:
    KDB 648474 SAR Handsets Multi Xmiter and Ant: II. SAR Evaluation Considerations: D. Power reduction: The second paragraph appears to require that every product with power reduction implemented must be submitted for a KDB enquiry prior to filing. This ‘blanket’ rule appears far too onerous for a number of standard products e.g. power reduction in multi-slot GPRS/EGPRS modes or in Wireless Router applications. Is this FCC’s intention?

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.