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There have been 13 comment(s) made on this document:
  • Chuck Powers commented on 2012-10-16 16:11:18.486:
    Comments from Motorola Solutions inc. (MSI) on Draft KDB 865664 SAR Measurement Requirements for 100 MHz to 6 GHz Section 2.8.1 - SAR Measurement Variability and Uncertainty: MSI requests that the FCC Lab reconsider the need for additional testing based on the SAR limits as prescribed on page 14 of Draft KDB 865664. MSI is proposing the following: For Step 2 please change 0.8 to 1.2 W/kg. This request is consistent with what we requested in earlier comments for mobile radio testing. For Step 3 please simplify the statement by only mentioning 1.45 W/kg threshold since it is consistent with the 20% increase criterion after the suggested threshold change from 0.8. to 1.2 is effected. Section 2.4 - Tissue Dielectric Parameter Requirements and Section 2.6 - SAR Measurement Requirements: MSI requests that the FCC maintain the 10% tolerance for the tissue dielectric parameters (dielectric constant and conductivity) because the tissue-equivalent liquid formulas are not yet available for frequencies above 3 GHz.
  • Fin Bomholt commented on 2012-10-16 10:20:08.003:
    Request for modification in 3.3.2 (see attachment) View attachment associated with this comment
  • Fin Bomholt commented on 2012-10-16 10:17:59.76:
    Request for modification in 3.3.1 (see attachment) View attachment associated with this comment
  • Fin Bomholt commented on 2012-10-16 10:13:36.58:
    Request for modification in 3.2.2 (see attachment) View attachment associated with this comment
  • Om Gandhi commented on 2012-10-15 18:14:52.973:
    Comments on OET Document 865664 DR02-4116 " SAR Measurement 100 MHz to 6GHz" SECTION 2.2 " SAR Probes"-- It is incorrect to state that the tip diameter of early generation SAR Probes was about " 6mm to 7 mm". NARDA Model 8021 Miniature Broadband Electric Field Probes used by the University of Utah SAR Compliance Testing Laboratory have a tip diameter of 3.5 mm, which is certainly much smaller than " 6 mm to 7mm ". In fact I still have two of these probes in my possession for SAR measurements. SECTION 2.5" Phantom Requirements"The SAM Phantom with a tapered 5 mm to 10 mm thick plastic spacer at the location of the ear has been shown to underestimate the 1-g SAR by a factor of two or more times smaller than for anatomically based models. Furthermore SAM dimensions correspond to the heads of the 90 th percentile 1989 U.S. Army Recruits and are therefore not representative of today's users of cell phones i.e. women and children with smaller heads and thinner ears that results in the cell phones placed closer to the human tissues including the brains of the users. Last and most importantly the SAR Testing does not take into account realistic placement of telephones against the body e. g. in the pocket, in the waist bands etc. This has also been the recommendation of the recent GAO Report that " the FCC test telephones the way that they are being used".For a radiating telephone held in the pocket it has been shown that the peak 1- and 10-g SARs are considerably higher ( by a factor of 2-7 times*) as compared to the SAR obtained using a 6 mm thick plastic ear head model such as SAM. ____________________________________________ * G. Kang and O.P. Gandhi, " SARs for pocket-mounted mobile telephones at 835 and 1900 MHz", Physics in Medicine and Biology vol. 47, pp. 4301-4313, 2002.
  • John Lewczak commented on 2012-10-06 17:10:01.26:
    D02 - Section: 2.3 - Information for SAR reports. There appears to be some disagreement (with KDB 865664 D01, Section 3.3.1) concerning the validation evidence required in reporting: Per 865664 D01 Section 3.3.1: “The detailed system validation results are maintained by each test laboratory, which are normally not required for equipment approval.” Per 865664 D02 Section 2.3.1a: “System validation status should be documented according to the validation date(s), measurement frequencies, SAR probes and tissue dielectric parameters. … System validation status should be documented in a tabulated summary.” We request that the requirements of these two documents be harmonized.
  • John Lewczak commented on 2012-10-06 17:09:24.246:
    D02 - Section: 2.1, Paragraph 3 - Information for all test reports. “The information and test data required to demonstrate compliance for FCC equipment authorization must be included in the test report. Information and test results that are not relevant to the equipment approval, when included should have prior FCC confirmation to avoid issues and must be clearly identified at the beginning of the test report as inapplicable for FCC equipment approval.” We would like confirmation that this implies that a test report may include data relevant to other regulatory approvals (e.g. Asia or EU specific) along side of the data required for FCC equipment authorization. So a test report might contain all capable transmit bands (e.g. GSM 850, GSM 900, GSM 1800, GSM1900, etc.) on the product as long as appropriate declarations are included
  • John Lewczak commented on 2012-10-06 17:08:46.79:
    D01 - Section: 3.3 - SAR System Validation. The SAR system validation requirements as written would create a huge and unreasonable burden on testing laboratories. Based on current standard calibration points used for cellular devices Head and Body tissues (at 750, 835, 1810, 1950, 2450, 2600, 5200, 5300, 5600, and 5800 MHz), the combination of CW and modulated validation requirements adds up to 378 validations (approx 126+ hours of robot time, in addition to engineering evaluation time). To require this body of work after each probe calibration, after each data acquisition electronics calibration, and following each software update will significantly impede test lab operations. Furthermore - the identification and management of specific linearity range(s) within each probe calibration point and/or DAE that requires device testing at a lower power (with subsequent scaling to maximum power) creates numerous opportunities for errors and misuse, without providing an obvious advantage or achieving an obvious goal. Any testing laboratory with more than one SAR test system will have tremendous difficulty managing all the probe calibration points / DAE / device / power combinations. We sincerely request a discussion among the FCC, SAR test equipment manufacturers, test labs, and manufacturer test labs to better understand the FCC's motivation behind these requirements of this section, and perhaps jointly develop more workable solutions.
  • John Lewczak commented on 2012-10-06 17:08:07.683:
    D01 - Section: 2.8.1 - SAR measurement variability and uncertainty – SAR measurement variability. Motorola Mobility continues to have substantial concerns about the proposed testing requirements. We understand that the intent is to provide additional validation of the submitted SAR values. Given the existing procedures to verify accuracy, the additional testing will not add appreciable validation. It, however, will add to test time and complexity. Equally important, it has a serious potential to create confusion from the multiple test results and SAR values. For the foregoing reason, Motorola Mobility requests that the Lab reconsider the need for such additional tests. In the event that the Lab nevertheless moves forward with the plan to require multiple tests for validation, additional direction will be essential. It is Motorola Mobility’s understanding that additional validation tests are intended to support – not supplant – existing test results. Therefore, the following should be followed: • Where multiple test results are consistent (i.e., within 20% of the initial figure) it is the initial test and not the supporting tests that provide the basis for the grant. • In the event a supporting test result is outside the 20% range, the submitted figure would be the test result closest to the new mean value, as calculated using the supporting test figures.
  • John Lewczak commented on 2012-10-06 17:07:03.91:
    D01 - Section: 2.7.4 - SAR scan procedures – SAR Measurement Drifts. “When the drift is more than 5%, a KDB inquiry should be submitted to determine how to address the output power stability issues to ensure the SAR results are acceptable. If the drift is inherent to the design of the device, the power drift should be characterized to determine if the measured SAR results must be scaled with respect to a nominal time averaged power level.” Question: Is this applicable to a “positive” drift (second measurement point at end of zoom scan is higher than first measurement point before area scan)? Or only in the case of a “negative” drift, when the end SAR point measurement is lower than that at the start? Also, for a typical cellular device, if SAR results are scaled for negative drift, is a KDB inquiry still required?
  • John Lewczak commented on 2012-10-06 17:06:21.58:
    D01 - Section: 2.7.2 - SAR scan procedures – Area Scan (and Table in 2.7.1). The requirement for the area scan measurement resolution to be less than or equal to the corresponding dimensions of the device surface being measured seems unnecessary when a zoom scan is performed. In our lab’s experience, we have never had difficulty in identifying and measuring the peak SAR location in this scenario. In the case of using Area Scan Approximation (fast SAR technique), it does make sense to limit the area scan measurement resolution in this way. However, we recommend that this area scan measurement resolution requirement should only apply to Area Scan Approximations, and should not apply when to a Zoom scan.
  • John Lewczak commented on 2012-10-06 17:05:45.71:
    D01 - Section: 2.4 - Tissue dielectric parameter requirements (DAK Calibration). “The tissue dielectric parameters of tissue-equivalent media used for SAR measurements must be within a temperature range of 18°C to 25°C, measured with calibrated instruments and apparatuses. The temperature of the tissue-equivalent medium used during measurement must also be within 18°C to 25°C and within ± 2°C of the temperature when the tissue parameters are characterized. The dielectric parameters must be measured before the tissue-equivalent medium is used in a series of SAR measurements. The parameters should be re-measured after each 3 – 4 days of use, or earlier if the dielectric parameters can become out of tolerance; for example, when the parameters are marginal at the beginning of the measurement series.” It is understood that the network analyzer and temperature probe must be calibrated. Calibration of the system is performed at least daily (open, load, known reference material) which we believe to be sufficient for this probe. Please clarify what specific additional equipment is expected to have external calibration certificate(s).
  • Bill Graff commented on 2012-10-05 16:32:11.706:
    Section 2.6 I question the wisdom of having two different applicable tolerance conditions for εr and σ for dielectric parameters depending upon if compensated or non-compensated deviations are used. For clarity, I believe it would be better to choose either the 5% or the 10% tolerance values only and not allow for compensated/non-compensated changes

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.