• Clem Fisher commented on 2012-07-17 10:29:59.36:
  Hi In this current draft, there is an allowance for measuring maximum conducted output power in the case where the equipment cannot be set to >98% Tx ratio - see para 8.2.4 Para 9 covers Power Spectral density requirements and says you should use the same rule (peak or RMS) for Power and PSD. However, there is no equivalent to Para 8.2.4 under Para 9 and therefore no apparent allowance for testing PSD to RMS limits unless the product can achieve > 98% Please add sub para to Para 9 to correct this anomaly and allow an equivalent to para 8.2.4 Regards

---

• Clem Fisher commented on 2012-07-12 11:36:18.05:
  We have one minor comment and one major one. Please see attachment View attachment associated with this comment

---

• Zhang Weimin commented on 2012-07-02 22:46:01.053:
  The "10.2.7 Band-Edge Measurements" in this DR02 draft version adopts the general marker-delta method as described in KDB 913591 and in C63.10, while gives up the channel integration method in the V01 drfat version. The KDB 913591, STEP 2 requires the spectrum analyzer span to encompasses both the peak of the fundamental emission and the band edge emission under investigation. If the signal has wider channel bandwith, the whole span may reach to a larger value (e.g. 55 MHz), and the RBW would be at least e.g. 550 kHz (1% of span). For some analyzers, the RBW will be adjusted to a larger supported value e.g. 1 MHz. So, the marker-delta method will be of no use. The channel integration method in the V01 drfat version is a good method for this case, it is necessary to be accepted as an alternative for the Band-Edge measurements.

---

• Bill Graff commented on 2012-06-29 19:02:07.746:
  I would like the FCC to clarify the reporting requirements for spurious emissions. Currently the Rules specify that measurements must be made to the 10th harmonic, but there is no guidance on the number of emissions that must be listed within the report. By default, many labs will only show the six highest radiated emissions as specified by ANSI C63.4. Often times it means laboratories will only show just three emissions each for V and H planes. This is not enough to assure compliance to all the 15.205 restricted bands to the 10th harmonic. I would like to see that all harmonically related emissions be shown to the 10th harmonic. This is the only way it would be possible to know if the radiated measurement system can truly see down to 500 uV at 3M when looking at 18GHz and above. On the other hand, if you are really going to allow for conducted testing results to be applied to 15.205 radiated emissions limits, you should al least insist on always seeing to the 10th harmonic in very clear language.

---

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.