Comments on OET Lab Policy Document

There have been 20 comment(s) made on this document:

Brian Scarpelli commented on 2014-02-21 14:06:22.54:
The Telecommunications Industry Association (TIA) submits the attached input to draft KDB 594280, Guidance on Software or Network Configuration of Non-SDR Devices to Ensure Compliance. We urge you to contact us with any questions or concerns, using the below information. Thank you, Brian Scarpelli Sr. Manager, Government Affairs Telecommunications Industry Association (TIA) d: 703.907.7714| m: 517.507.1446 BScarpelli@tiaonline.org | tiaonline.org View attachment associated with this comment

Mats Hansson commented on 2014-02-21 11:04:55.49:
Our comments are submitted in the attached pdf file View attachment associated with this comment

Mike Zhou commented on 2014-02-21 05:22:48.333:
Huawei have some comments as below: 1) About section 4)b)i): If our product sold on US market, the default mode is compliant with the US requirement, and the operation mode couldnt be changed on the user, whether supplemental information such as geo-location data still must have? 2) About section 4)b)ii): The client device dont have effective way to make sure that the Master device is indoor. 3) About section 4)c)i): The device must check the country and network codes at least once every hour and anytime the device operation is reset or when a connection is initiated or changed.--------May only check once? 4) We need time to check whether our product fulfill the final KDB 594280, and we need more time to fix it if any problems were found, minimum 9 months are needed. Thank you~

Wi-Fi Alliance commented on 2014-02-19 10:46:23.23:
Please see attached letter. View attachment associated with this comment

Mark Arthurs commented on 2014-02-13 14:02:56.57:
Effective Date Sony is requesting that the FCC extend the effective date by nine months to one year (December 31, 2014 to March 31, 2015) for this KDB. This is to allow time for the modification or new design schedule of module vendors and the time necessary to modify our host devices based on the modification of module to ensure compliance. B ii. Wi-Fi Devices operating in 5.1 GHz band The KDB requires that the client device operating under the control of a master must ensure that the master device is operating indoors. If this requirement is implemented, it may make it impossible to tether. Sony is requesting that this requirement be removed. It should be sufficient for the master devices to ensure that the client devices are indoors. It would be difficult for the client device to ensure that the master device is indoors. It would be acceptable to require a caution to the user to ensure indoor use.

FCC Laboratory commented on 2014-02-05 12:30:25.986:
Special FCC comment: In September 2013, FCC had informed all parties that Wi-Fi client devices operating on Channels 12 and 13 in the U.S. and relying only on passive scanning must ensure compliance with all the emission requirements specified in the FCC rules. At that time the FCC indicated that this requirement will apply to all new approvals starting March 2014. Based on the additional information provided by many parties and comments to draft KDB Publication 594280, the FCC has decided to allow extend the time to September 1, 2014.

David Case commented on 2014-02-04 13:49:16.706:
In regards to the referenced KDB, Cisco suggests that in regards to the section on hosts and modules that support DFS , that this information either be removed from here and placed in the KDB on modules or that the text also be copied (when finally agreed) to the module KDB. However at this time since there is an open rulemaking in regards to 5GHz and DFS, Cisco asks that solution on this issue be postponed until such time as the 5GHz technical (read compliance) issues are resolved. The current guidance in regards to DFS and modules should be sufficient to address present issues. The same goes for the discussion on indoor and outdoor use which is also part of the 5GHz discussion. Cisco further encourages the FCC to consider holding a session on this proposal at the next TCB training to allow industry to have an open discussion on issues raised in this proposed KDB.

Jack Parmentier commented on 2014-01-30 15:10:59.586:
Lenovo is requesting that the FCC extend the effective date of issue by 120 days for this KDB. The module vendors that we use are still developing & evaluating the methods used to be able to comply with Ch 12/13 under section 15.247 of the draft KDB. In addition, it will take some time for the module vendors to validate the changes required once the have been created. Please extend the time for implementation of this rule so that our product shipments are not delayed. Thank you.

William Wei commented on 2014-01-28 05:23:16.046:
Acer would like to request FCC to extend the effective date 6 months from the date of issue of the final KDB or March 31, 2014. Currently our module makers are still developing the method to comply with Ch 12&13 of 2.4GHz bands under section 15.247 based on the draft KDB. And that will take some period of time for the module makers to implement and validate the modules. Of course there is another option which is disabled Ch 12&13, but this also requires reengineering, validation, and regulatory testing. The production line will be disrupted dramatically due to the complexity of the entrie supply chain process. Therefore it would be great that FCC can extend the effective date, and that will provide us reasonable transition time to overcome this compliance and also it can prevent the shipment impacts to USA.

Ariel Liu commented on 2014-01-26 19:50:51.093:
Request the extension of the cut in date. To have the HW change will impact current material plan. It's reasonable to have 6 month transition time. The sea shipment take 3~4 weeks that can not meet the Mar/31st date already not even mention the line shutdown due to the CNY in Asia. There are still some WIFI makers haven't provide enough transition information for OEM to start the validation yet. Pls extend the date for 6 monthes to prevent the shipment impact to USA.

Ariel Liu commented on 2014-01-26 19:46:15.463:
Request the extension of the cut in date. To have the HW change will impact current material plan. It's reasonable to have 6 month transition time. The sea shipment take 3~4 weeks that can not meet the Mar/31st date already not even mention the line shutdown due to the CNY in Asia. There are still some WIFI makers haven't provide enough transition information for OEM to start the validation yet. Pls extend the date for 6 monthes to prevent the shipment impact to USA.

Thanh Nguyen commented on 2014-01-23 15:49:47.143:
Request for Extension of Wi-Fi Devices Operating in Channels 12 and 13 The draft KDB provides manufacturers of the modular transmitters and host platforms several methods to comply with Channel 12 & 13 of 2.4 GHz band under Section 15.247 rules via geo-locating features in the module and/or from the host. This will enable the manufacturers the ability to use a single worldwide client device (module) model. However, the methods are complex and required development, reengineering, validation, regulatory testing, change to manufacturing process, host platform integration and FCC PBA approval. Another option the manufacturer can take is to introduce new module for USA market only with Channels 12 & 13 disabled. This also requires reengineering, validation, regulatory testing, and change to manufacturing process. This will disrupt the entire supply chain process of the module to the host platform manufacturer and add complexity to the ordering and fulfillment of these products to customers. Considering the aforementioned activities/impacts, it is not feasible for manufacturers of modules and host platforms to implement any one of above solutions by March 31, 2014. Therefore, Dell would like to request the FCC to extend the effective date 6 months from the date of issue of the final KDB or March 31, 2014, this is to allow reasonable transition time. We also believe the numbers of Access Points (master devices) that have been approved to transmit on channels 12/13 are very low, and thus the 6 month extension poses very low risk of possible interference issues.

Steve Hackett commented on 2014-01-21 18:31:25.406:
1. Extension: The draft KDB provides manufacturers of the modular & device transmitters some good options to provide geo-locating features for enabling the ability for on-going shipment of a single worldwide client device model. However, the options are somewhat complex by requiring development/validation, regulatory testing, engineering change to manufacturing, FCC PBA approval, and customer integration. Taking the sum of these activities into consideration it is not feasible to consider for manufacturers of client devices to implement any one or more of the methods for geo-location by the date of issue of the final KDB or March 31, 2014. In addition, without reasonable extension of the effectivity date many device manufacturers and integrators will be forced to create interim solutions (ex: separate FCC models) which is both costly and disruptive to the entire supply chain process. Consequently, it is requested that the effectivity date be set for 120 days from the date of issue of the final KDB to allow a reasonable transition time. We believe with the very small number of master devices that have been approved to transmit on channels 12/13 the requested extension poses very low risk of possible interference issues. 2. Use of 802.11d information: It is our understanding the FCCs position is that a Wi-Fi client device cannot rely on 802.11d information from an AP to establish country location. From the draft KDB: A Wi-Fi client device that relies on a network access point to determine if it can operate on channels 12 and 13 must still ensure that its transmission will comply with the rules when operating in the U.S.5 5 Typically this is done by passive scanning. In this case the device scans to determine the channels used by an access point for communications to establish a network connection. This seems to mean that 802.11d is not allowed for determining geo location; however it may not be interpreted the same way by all parties. If this is the FCCs position then it is recommended that the FCC specify 802.11d information from a network access point (AP) is not acceptable for geo location so it is clear for all manufacturers and avoids any misinterpretations. 3. Use of 802.11d information from Multiple APS: We understand that 802.11d information from a single AP may not be able to be used because of user ability to adjust settings incorrectly. However, it is common in many commercial environments that multiple APs are located in range of a client device where it could be possible for the client device to obtain 802.11d location information from multiple APs. The risk for incorrect user country setting should be very low in this scenario. Therefore we are requesting your consideration for an additional geo-locating option where the 802.11d information received from multiple APs could be allowed to confirm the validity of country code. Caveats: 802.11d information must be received from multiple AP > 3 with country code agreement If more than three APs are used, there must be a majority agreement of country codes Test and verification required: Client device must initially start and remain in default (FCC Compliant) until valid location information received. Three or more APs must be used for validation test. If < 3 APs provide different country codes then the client device must remain in default If 3 or majority of > 3 APs show the same country code then the client device may switch to that country code. 4. Comments for draft KDB part 5(a)(i) Wi-Fi Transmitter operating in Channels 12 and 13: a. One of the geo-locating options allows MCC and MNC received by a network carrier directly by a receiver on the host. If it is acceptable to use MCC and MNC from a receiver directly on the host it also would appear reasonable to permit the secure transfer of the MCC and MNC country code setting if received from a mobile phone that has a secure radio link (e.g., BT, Wi-Fi, NFC) or directly connected (USB) with the host device? Please confirm this method of geo-locating may also be considered. b. Another of the geo locating options for host platforms providing supplemental information states: Other suitable geo-location data based on the IP addresses provided by an entity approved by the grantee of modular transmitter. Geo-locating information provided by such entities is not always based on IP addresses (ex: specific entity mapping applications). Therefore, we recommend amending the KDB statement as follows: Other suitable geo-location data based on the IP addresses or other reliable source (e.g., specific entity mapping applications) provided by an entity approved by the grantee of the modular transmitter. The same should be specified for non-modular approved devices

John Lewczak commented on 2014-01-17 11:37:17.686:
For CMRS devices using MCC/MNC to ensure compliance: the statement on Page 6 requires a failsafe mechanism to address conflicting MCC codes received within the US. It isn't clear how this can be accomplished without the use of another geolocation technique (GNSS). If the MCC information cannot be counted upon in the US, then perhaps it shouldn't be used at all. Better still, the FCC should require carriers to send correct information, and take appropriate enforcement actions as needed.

John Lewczak commented on 2014-01-17 11:27:30.786:
Wi-Fi devices operating in the 5.1 GHz band: client devices operating under the control of a master device must ensure that the master is operating indoors. How would this be accomplished? How would the client know that the master is connected to the AC Mains?

John Lewczak commented on 2014-01-17 11:25:09.08:
Applications for Wi-Fi devices employing GNSS techniques to ensure US-compliant operation will require data in the test report showing that these techniques work properly. What sort of data would appear in a test report? If using GNSS, would it be necessary to simulate the receipt of locations within the US and without? How many such locations? Would all US territories need to be considered? What would be needed to demonstrate the effectiveness of MCC techniques? All existing codes, even unassigned ones?

John Lewczak commented on 2014-01-17 11:21:14.403:
When discussing the use of Mobile Country Codes (both in the Part 15/Wi-Fi and CMRS sections), the requirement that Mobile Network Codes be considered as well appears to be unnecessary. All that is required to ensure compliant operation in the US is to see the MCC, no?

David Case commented on 2014-01-17 10:29:56.43:
In regards to client cards and ad-hoc mode operation in bands requiring specific mitigation techniques (DFS , TPC, database or other methods) , there is a concern on allowing device to operate as ad-hoc networks without being required to deploy such features and rely on a loose association to an AP the ad-hoc networks sees. First there is an assumption that by just hearing an AP would allow a client to initiate a transmission on a DFS band with another client. Even if some limited access to connect to it and then allow that client to connect to an unknown client not under the network control, both from a regulatory as well as a security view this would be a problem. Thus the device would likely be treated as rouge and it would be forced off the network or denied access to it. Further what are the implementations if this ad-hoc peer to peer network does not fully operate in compliance with the rules while associated with an AP? Will additional testing be required of master devices for DFS to determine how they provide associated ad-ho peer to peer networks operating in their band to see if the AP sends out proper instructions to the ad-hoc P2P networks in regard to channel move time, or quiet period for in service monitoring. Will an operator of a Wi-Fi network have to provide connectivity to those wanting the regulatory info (radar detect and move channel) to ad-hoc P2P networks operating in the same frequency band their network is on? In regards to the draft, first the actual test procedure does address client cards that operate as masters devices so there is already a process to address this. Second given in the past, it has been stated by the FCC that each device operating as a master must do their own DFS detection, thus for networks with multiple APs such as an office building we have never been allowed to use on central source for DFs detection and the other APs as slaves if they could each could start a transmission to clients not directly associated with the master AP. Is the FCC proposing to extend this view to state only one AP in a network no matter how many other devices can operate as masters if they can hear the master AP?

Gerald Schmidt commented on 2014-01-16 06:51:49.883:
WIFI Cannels 1-11: (maybe also some 5 GHz bands) Suggestion: WIFI Master devices should have the possibility to use different power levels settings. Conditions should be similar as for channel 12-13 (default power setting must complies, + MCC or geo location data) Reason: For several portable products (USB Stick, mobile phones,..) the max US power setting results of 1-g SAR limitation. Because same products will be sold to 10-g SAR countries too, a higher power would be possible. From US point of view the compliance can be assumed, because the default mode can be left only if a valid MCC or valid geo-location data are available. WIFI devices operating in the 5.1 GHz band: Suggestion. To confirm the common practice this KDB should explicit allow that client with passive scanning are considered as acceptable to fulfill the indoor requirements. Reason: WIFI Access Points (Master) that are capable of allowing the client device to operate in 5150 - 5250 MHz band are optimized for indoor use only. All WIFI networks operating in this mode are restricted for indoors use only. Therefore a client with passive scanning cannot violate the indoor requirements.

Tim Johnson commented on 2014-01-15 16:51:03.52:
Regarding page 2, that cites: "For professionally installed equipment or modular transmitters, properly authorized installers and integrators may adjust the output power, as long as the radiated power is within the range authorized in the grant, for the antenna used in a specific installation" 1) Regarding modules and integrators, further detail may be necessary. For instance, does the control of the power need to be integrated on the module. For instance we know of a manufacturer who by design the control of the power is in files that the OEM integrates into their device. Different antennas also have different powers - all within what was approved. However the control and implementation of these is up to the integrator, under the instruction of the applicant. While the OEM integrates the software, the user will not have access to it. It is not clear if such a situation is covered or not. It appears this may be allowed, but I would request further clarification or maybe an example be given to clarify this.

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.

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