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There have been 12 comment(s) made on this document:
  • John Lewczak commented on 2013-05-17 20:35:49.193:
    Section 6: The second sentence of Section 6 introduces the concept of duty cycle changes as a means for controlling time averaged power for SAR compliance. Therefore, we believe the word "power" in the last sentence of that same section should be taken to mean the time averaged power, whether reduction was achieved by power level reduction, duty cycle manipulation, or a combination of both. Is this interpretation correct?
  • John Lewczak commented on 2013-05-17 20:34:09.163:
    Section 2.2: Verbiage suggestion (indicated by CAPS): UNLESS THERE IS CLEAR GUIDANCE FROM THE MANUFACTURER REGARDING INTENDED USER POSITION, for handsets that do not operate with a traditional earpiece where the ear reference point (ERP) can become undefined, a KDB inquiry describing the audio transmission technology and use conditions is required to determine acceptable SARtest configurations."
  • John Forrester commented on 2013-05-17 15:40:51.656:
    Section 4: For RevB testing, can the FCC consider specifying that test code can be used to configure the transmitter for SAR testing. The values used for testing must then be consistent with declared values and/or conducted measurement completed using a call box(s).
  • Brian Scarpelli commented on 2013-05-17 14:21:05.426:
    The Telecommunications Industry Association (“TIA”) submits this comment to the Federal Communications Commission’s (“FCC”) Office of Engineering and Technology (“OET”) regarding draft Knowledge Database (“KDB”) publication 648474. TIA has reviewed the language and notes that the burden for testing falls on the third party accessory provider and not the phone manufacturer (“OEM”). TIA agrees that this distinction must be made given that OEMs are independent of such third parties and should not be compelled to enter into relationships with them. Indeed, it is not possible for OEMs even to keep track of the third party accessory marketplace. Additional obligations, therefore, would be completely impracticable and should not be imposed. Given the foregoing, TIA understands that there are no direct obligations imposed on OEMs by the additional language unless the OEM voluntarily elects to undertake such a relationship and file a Class II permissive change if one is appropriate. Accordingly, TIA understands that the new language requires the third party accessory provider to conduct the required SAR testing and, if a Class II is not agreed upon with the OEM, to complete a separate filing under a new FCC ID, provided the accessory is an active device. Due to the importance of the distinction between active and passive devices to the FCC’s jurisdiction over third party accessory manufacturers, TIA urges FCC to clearly specify that this new language applies only to active devices – i.e., devices that separately transmit a signal. TIA requests that FCC confirm the above understanding and, if correct, that FCC revise the language to make clear that there is a separate filing required by the third party, where appropriate. Respectfully submitted, TELECOMMUNICATIONS INDUSTRY ASSOCIATION By: /s/ Brian Scarpelli Brian Scarpelli Senior Manager, Government Affairs TELECOMMUNICATIONS INDUSTRY ASSOCIATION 1320 North Courthouse Road Suite 200 Arlington, VA 22201 703.907.7714 View attachment associated with this comment
  • Brian Scarpelli commented on 2013-05-17 14:18:05.216:
    The Telecommunications Industry Association (“TIA”) submits this comment to the Federal Communications Commission’s (“FCC”) Office of Engineering and Technology (“OET”) regarding draft Knowledge Database (“KDB”) publication 648474. TIA has reviewed the language and notes that the burden for testing falls on the third party accessory provider and not the phone manufacturer (“OEM”). TIA agrees that this distinction must be made given that OEMs are independent of such third parties and should not be compelled to enter into relationships with them. Indeed, it is not possible for OEMs even to keep track of the third party accessory marketplace. Additional obligations, therefore, would be completely impracticable and should not be imposed. Given the foregoing, TIA understands that there are no direct obligations imposed on OEMs by the additional language unless the OEM voluntarily elects to undertake such a relationship and file a Class II permissive change if one is appropriate. Accordingly, TIA understands that the new language requires the third party accessory provider to conduct the required Specific Absoprtion Rate (“SAR”) testing and, if a Class II is not agreed upon with the OEM, to complete a separate filing under a new FCC ID, provided the accessory is an active device. Due to the importance of the distinction between active and passive devices to the FCC’s jurisdiction over third party accessory manufacturers, TIA urges FCC to clearly specify that this new language applies only to active devices – i.e., devices that separately transmit a signal. TIA requests that FCC confirm the above understanding and, if correct, that FCC revise the language to make clear that there is a separate filing required by the third party, where appropriate. View attachment associated with this comment
  • Shigeru Iwasaki commented on 2013-05-17 12:06:13.51:
    Is 10g-SAR required for Phablet for the purpose of hand (extremity) exposure? If so, please clarify the FCC limit value (i.e. 4 W/kg 10g SAR according to rule part 2.1093(d)(2) for example). Additionally, It is not defined tissue dielectric parameters for extremity on OET65C. Please clarify extremity tissue parameters before enforcement.
  • Shigeru Iwasaki commented on 2013-05-17 12:04:00.1:
    Regarding Section 2.5 Phablet SAR test considerations item 2, we consider that the Hand SAR test of LCD surface is not needed because user does not use Phablet with holding the LCD surface.
  • Shigeru Iwasaki commented on 2013-05-16 15:33:45.286:
    Please specify a transition period for the products already under developing by manufacturers before April 8, 2013. We request a transition period so we can prepare for the new requirements from the new SAR testing requirements at 0mm 10g. Thank you
  • Steve Liu commented on 2013-05-09 16:14:32.353:
    Please mention the applicability of Estimated SAR when SAR test exclusion is applied based on Page 8 in the first paragraph.
  • Steve Liu commented on 2013-05-09 16:14:11.743:
    Please clarify Footnote 14 about devices that have larger than 20 cm diagonal. It is somewhat unclear.
  • Steve Liu commented on 2013-05-09 16:13:42.636:
    Section 4.3 first paragraph states SAR evaluation for tablet front screen surfaces are generally not necessary, “except when continuous operations with the hand(s) next to the antenna(s) are required.” Please provide an example, and clarify whther antennas located on edges of the tablet fall under this category (or what does).
  • FCC (Kwok Chan) commented on 2013-04-10 18:53:33.986:
    Hotspot mode was overlooked in the phablet procedures. This will be considered in the final release of this document. Item 2 of the phablet procedures will be revised according to text shown in [ ... ] below. 2. The UMPC mini-tablet procedures must also be applied to test the SAR of all surfaces and edges with an antenna closer than 25 mm from that surface or edge, in direct contact with the phantom, for 10-g SAR. The UMPC mini-tablet 1-g SAR at 5 mm is not required. [When hotspot mode applies, 10-g SAR is required only for the surfaces and edges with hotspot mode 1-g SAR > 1.2 W/kg.] The normal tablet procedures in KDB 616217 are required when the over diagonal dimension of the device is > 20.0 cm. [Hotspot mode SAR is not required when normal tablet procedures are applied. The more conservative tablet SAR can be used to support body-worn accessory SAR compliance for a surface requiring the same wireless configuration for both voice and data mode transmission; for example, in UMTS.]

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.