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There have been 11 comment(s) made on this document:
  • Brian Scarpelli commented on 2012-06-29 16:41:25.52:
    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 941225 (What are the current SAR test procedures for 3G devices?) (“KDB 941225”). Specifically, TIA submits the following input for OET’s consideration: • In KDB 941225, the SAR reduction threshold to 1.2W/kg will drive additional and unnecessary testing of devices. TIA fears that the reduction of this threshold will drive significant additional cost and time into programs without any tangible benefit. For example, LTE SAR values may trigger many extra measurements for many designs crafted for maximum SAR around 1.2mW/g (e.g. tablets). 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 941225, and urge the Commission to act consistent with the above. View attachment associated with this comment
  • Brian Scarpelli commented on 2012-06-29 16:40:33.72:
    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 941225 (What are the current SAR test procedures for 3G devices?) (“KDB 941225”). Specifically, TIA submits the following input for OET’s consideration: • In KDB 941225, the SAR reduction threshold to 1.2W/kg will drive additional and unnecessary testing of devices. TIA fears that the reduction of this threshold will drive significant additional cost and time into programs without any tangible benefit. For example, LTE SAR values may trigger many extra measurements for many designs crafted for maximum SAR around 1.2mW/g (e.g. tablets). 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 941225, and urge the Commission to act consistent with the above. View attachment associated with this comment
  • John Lewczak commented on 2012-06-29 15:59:57.163:

    Motorola Mobility - Comments regarding draft KDB 941225 (duplicate posting, this time with the Attachments). 

    Comment 1:

    In reviewing the test protocol dictated by draft KDB 941225, we have found that evaluation of maximum average power for the RB configurations in the order noted runs contrary to the MPR schema allowed in the 3GPP standard. For devices implementing any non-zero amount of MPR, the draft test protocol would impose SAR testing first in RB configurations where maximum average power is expected to be lower (100% and 50%), and then require further SAR testing in the expected worst-case power condition (1 RB). As an alternative, it is suggested that the test protocol be rewritten to begin with the 1 RB cases, and then proceed further for 50% and 100% RB cases if those are found to be higher in power. A candidate revision to the test protocol is provided in Attachment 1.

    This approach (examination of higher-power configurations, with test exclusion of other configurations based on power) is supported by the data currently on file with the Commission. As shown in Attachment 2, for devices where MPR is implemented, the worst-case SAR value is typically found in the 1 RB configuration.

    Comment 2:

    We believe the additional requirement per II.I (top of page 5) for spectrum plots is unnecessarily burdensome, provides no additional technical value, and should be removed from list of reporting requirements.

    View attachment associated with this comment
  • John Lewczak commented on 2012-06-29 15:54:12.58:

    Motorola Mobility - Comments regarding draft KDB 941225

    Comment 1:

    In reviewing the test protocol dictated by draft KDB 941225, we have found that evaluation of maximum average power for the RB configurations in the order noted runs contrary to the MPR schema allowed in the 3GPP standard. For devices implementing any non-zero amount of MPR, the draft test protocol would impose SAR testing first in RB configurations where maximum average power is expected to be lower (100% and 50%), and then require further SAR testing in the expected worst-case power condition (1 RB). As an alternative, it is suggested that the test protocol be rewritten to begin with the 1 RB cases, and then proceed further for 50% and 100% RB cases if those are found to be higher in power. A candidate revision to the test protocol is provided in Attachment 1.

    This approach (examination of higher-power configurations, with test exclusion of other configurations based on power) is supported by the data currently on file with the Commission. As shown in Attachment 2, for devices where MPR is implemented, the worst-case SAR value is typically found in the 1 RB configuration.

    Comment 2:

    We believe the additional requirement per II.I (top of page 5) for spectrum plots is unnecessarily burdensome, provides no additional technical value, and should be removed from list of reporting requirements.

  • Todd Gallagher commented on 2012-06-27 13:04:56.083:
    The changes in KDB 941225 D05 will drive a significant amount of testing that does not add substantial value for the effort being proposed. Based on our evaluations the additional tests cases could add many days to the test cycle depending on the number of bandwidths and increasing again if more than one side exceeds the 1.2W/Kg threshold. We question the benefit of the extra test data to support RF Exposure compliance. A high degree of confidence can be achieved through limited but focused test cases. By analyzing the conducted powers there can be conclusions drawn for the highest power and stability of the radio in that band. Test strategies that represent the worst case operation of the modem can then be determined based on power and bandwidth functionality without evaluating everything over 1.2W/Kg. In our opinion the collection of the extra data is redundant and does not provide any value to the manufacturer or the reviewer.
  • John Forrester (Qualcomm) commented on 2012-06-27 02:15:11.51:
    Please see attached file. View attachment associated with this comment
  • Steve Liu commented on 2012-06-26 10:44:53.5:
    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
  • Kai Niskala commented on 2012-06-25 06:33:32.586:
    941225 D05 SAR for LTE Devices v02 I. Introduction 2nd paragraph: for LTE devices that incorporate power reduction in specific operating modes (e.g. WiFi Hotspot mode), is it mandatory to submit a KDB enquiry irrespective of whether the filing will be made directly to FCC or through a TCB? III.B. Standalone SAR test requirements General: Should all references to “III.B.(i)”, etc. be to “III.B.3.(i)”, etc.? 3: 3GPP specifications allow up to 1dB MPR for 50% and 100% RB allocations, therefore 1 RB allocations in all offsets will provide the highest time-averaged output powers when this MPR setting is in use. To avoid unnecessary testing of configurations having lower conducted power and SAR, we would prefer to see the initial testing based on 1 RB allocations with subsequent testing in 50% and 100% RB allocations only required if their powers are close to those of the 1 RB allocations. For example, a rule such as ‘if their time-averaged output powers are within 0.25dB their equivalents with 1 RB allocation, then testing is required in these modes’. To formulate this as a more generic rule, we suggest that testing should always be started with the RB allocations having the highest conducted average powers, following up with other RB configuration tests only if their relative power levels meet the criteria set. Our justification for this approach is based on experience showing that conducted powers and SAR results match very well in LTE SAR testing; hence we believe that ultimately testing should be necessary only for the RB allocations having maximum conducted power. For clarity, it would be appreciated if a term such as ‘full SAR testing’ or ‘all test configurations’ were used to indicate when more than one test configuration is required. As background, Nokia has found that a single SAR test for each RB allocation and offset using a single test configuration (e.g. Left Cheek in Head SAR testing) is sufficient for determining the RB allocation and offset giving the highest SAR and that full testing (e.g. Left Tilt, Right Cheek & Right Tilt) can then be limited to the identified mode only, without any sacrifice in accuracy or ability to detect the maximum SAR value; in this sense, repeated testing of the ‘unnecessary’ test configurations in the lower power modes is an inefficient use of test resources. Furthermore, provided that the device and exposure configurations, as well as the transmission modes, are the same for the other use conditions (i.e. Body-worn and WiFi Hotspot) and there are no changes in power settings in these modes, Nokia has found that the highest SAR mode identified during Head SAR testing can be read-across to both Body-worn and WiFi Hotspot SAR testing, offering further testing economies/minimisation with no loss either of accuracy or of rigour in finding the maximum SAR values in these usage modes. 3.(iv): the text in the paragraph currently states: “ ... measure SAR only when .....or the SAR measured in III.B.(i), III.B.(ii) and III.B.(iii) is > 1.2W/kg.”. Is the word ‘and’ correct here? 4.(i).(a): the text in the paragraph currently states: “ only measure SAR when .....or the SAR measured in III.B.(i), III.B.(ii) and III.B.(iii) is > 1.2W/kg.”. Again, is the word ‘and’ correct here? Trigger level 1.2 W/kg could be lifted to 1.45 W/kg without compromising rigour in finding the maximum SAR, especially if the other changes proposed here are taken into account.
  • Ying Wang commented on 2012-06-15 20:23:44.913:
    Measurement of conducted output power is much more accurate and repetitive, comparing to SAR evaluation, which often has a measurement uncertainty of about 20%. Instead of performing SAR measurement using various LTE signal configurations (with different bandwidths, RB sizes, RB offsets, modulations, etc.), I propose the following SAR evaluation procedures: 1.) Perform conducted output power measurement in each frequency band using various LTE signal configurations and identify the configuration which transmits the highest time-averaged conducted power. 2.) Perform SAR evaluation for different test positions/orientation while having the EUT transmit in the configuration identified in Step 1. The proposed procedure would significantly reduce the SAR test time without compromising the RF exposure compliance. The SAR evaluation can be further simplified by allowing the use of CW signal in a test mode of the same power level as identified in Step 1. This would also minimize SAR measurement error due to higher peak-to-average power (PAR) ratios inherent in high-order modulations such as the ones used in LTE.
  • Mark Briggs commented on 2012-06-14 14:45:08.853:
    PLease refer to attached document for comments. Thanks. View attachment associated with this comment
  • Jay Moulton commented on 2012-05-10 14:50:35.38:
    I have attached a pdf document with my comment. View attachment associated with this comment

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.