• John Forrester commented on 2013-05-24 16:57:13.813:
  Slide 11: Qualcomm agrees with FCC’s proposal. We would look for guidance from FCC how this behavior would be evaluated by a TCB or test methodology to be used for conformance testing if that is what FCC requires. Slide 12: Before restricting hotspot operations, the FCC should consider the comments and reply comments to be filed on the pending 5GHz NPRM by the wireless industry, which likely will address issues relating to harmonization of the FCC's U-NII regulations, such as power levels and usage restrictions. The FCC’s other proposals here warrant further discussion also (e.g. state of the art concerning auto detection of indoor location or detection by a client of the AC power status of an associated infrastructure device.

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• David Case commented on 2013-05-09 10:23:24.253:
  In regards to discussion on indoor use or determiing how to detect indoor use, Cisco has several comments. First , the proposal includes references to define a device connected to an AC outlet is or could be considered indoor use, however given that AC power outlets can easily be installed outdoors, this is not proof of indoor use. Second and more importantly, in regards to earlier discussions on KDB 443999 on DFS operation, there were lengthy discussions on how to define indoor or outdoor use. Given this discussion has now or could be rolled over to the open NPRM on 5GHz in regards to DFS and operation in the 5GHz band , we feel at this time that this discussion should not be part of the this KDB nor should the FCC lab be trying to define what is indoor operation at this time.

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• Dennis Ward commented on 2013-05-01 15:02:31.383:
  When reviewing the presentation the definition of client and master, and the determination of indoor use in the 5.15GHz UNII band, page 10 and 12 of the presentation bring some immediate concerns that are not answered. For example, page 10 the presentation states "Clients must be truly passive and must wait for an “enabling” signal which permits transmission on that frequency..." Page 12 then lists some 'methods' for applying indoor use. Many devices, mobile phones for example, use UNII band 1 but also use active scanning in that band. As Active Scanning sends an uninitiated probe request whenever it jumps to a new channel, it would seem that this would force the device implementing active scanning to fit the FCC definition of a master, regardless if the manufacturer calls is a client device or not. NOTE: FCC defines master as a device that has the capability to transmit without receiving an enabling signal. Generally, a mobile device has the potential of operating in other than an indoor only location. This means that any mobile phone or other mobile device using active scan technology, could send probe requests while outdoors in UNII band 1, thus violating the indoor use only rule as well as not meeting any of the compliance criterion on page 12 of the presentation. As there are literally hundreds and hundreds of these mobile devices that have been and continue to be certified with no adverse comment or consideration by the FCC, this new presentation should provide a more adequate explanation in order to address this specific situation; or the FCC should make a clear statement to the affect that any mobile device using Active Scanning techniques in UNII band 1 are Master devices and must provide clear operational descriptions as to how indoor use requriements in UNII 1 are met; or make a clear statement that this does not apply to mobile phones or other mobile devices that only use Active Scanning but are otherwise client devices for other transmissions. If the FCC does not make a clear and non-ambiguous statement about this issue, manufacturers and possibly TCBs would probably ignore this situation and continue granting mobile active scanning devices possibly used outdoors while in the UNII band 1 as presently accepted by the FCC.

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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.