• John Lewczak commented on 2013-05-17 20:37:08.073:
  Section 4.3.4: The 4th bullet item is counter-productive in that all testing could be completed with area scans, and then the 0.1W/kg criteria becomes a problem only at the very end when a Zoom is performed. > Is it really a problem if the zoom is more than 0.1W/kg BELOW the fastSAR value? We suggest that an over-estimation by the fastSAR should not be a concern. > The KDB does not clearly state what to do if the 0.1W/kg threshold is not met(either higher or lower). Do all fastSAR tests within that band then require re-testing with zooms?

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• Mark Briggs commented on 2013-05-17 19:40:18.19:
  In section 4.1, item (5) starts with the comment: The test separation distances required for a device to demonstrate SAR or MPE compliance must be sufficiently conservative to support the operational separation distances required by the device and its antennas and radiating structures. The last sentence of the section seems to contradict this requirement: However, for incorporation into different host products the operational separation distance with respect to the outer housing or antenna, according to the above, must not exceed the test separation distance. Should this not state that the test separation distance must not exceed the operational separation distance? I may be missing something, but for modular devices the KDB requires a test distance of <5mm to cover installation into portable hosts. If the test distance is Xmm, where X < 5mm, what is the requirement for antenna location in the host device for body-worn devices where the operational separation distance is the enclosure-to-user distance and that distance will likely be 0mm.

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• Steve Liu commented on 2013-05-09 16:19:13.576:
  Since 10g SAR will be more common with Phablet SAR testing, please clarify in 4) that simultaneous 10g SAR will not be considered at this time, and requires standalone Hand SAR evaluations only at this time (if this is acceptable)

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• Steve Liu commented on 2013-05-09 16:16:34.286:
  Please verify tabulated results in Appendix B table according to “equation and thresholds in section 4.3.1”. The results do not appear to be correct.

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• Steve Liu commented on 2013-05-09 16:15:57.666:
  For 8) c), can this 1dB variation condition be clarified to apply only for licensed devices? Unclicensed devices will vary more than 1 dB with higher order modulations/data rates and does not seem to be subject to this condition.

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• John Bellairs commented on 2013-05-02 05:15:12.0:
  Re Section 7.2 final para - An explaination is given to what is required for a mixed portable/mobile condition when the test exclusion criteria are not met. Suggest adding a further explantion to explain what MPE test is required when the exclusion criteria are not met for mobile conditions.

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• FCC (Kwok Chan) commented on 2013-04-25 16:42:47.833:
  In section 4.3.4 of KDB 447487 for Area Scan Based 1-g SAR Estimation , each exposure positon is indicated in the third and fourth bullets (pages 14 and 15). For head exposure where multiple test positions are required (left, right, touch and tilt etc.), it is not clear if each test position should be considered an exposure condition or if all test positions should be considered as a single exposure condition. This will be address in the final release of this document according to the following: When the estimated 1-g SAR (fast SAR) of all test positions required for head SAR measurements (left, right, touch and tilt etc.) are all less than 0.8 W/kg, all the test positions can be considered as a single exposure condition. A zoom scan is required only for the highest fast SAR configuration among all the test positions. When the estimated 1-g SAR (fast SAR) of a test position is greater than or equal to 0.8 W/kg, that test position should be considered as a separate exposure condition. A zoom scan is required for the highest fast SAR measured for that test position. If the SAR for the remaining test positions are all less than 0.8 W/kg, these other test positions can be group together and considered as an exposure position. A zoom scan is required for the highest fast SAR measured among these test positions.

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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.