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There have been 10 comment(s) made on this document:
  • Steve Liu commented on 2014-05-05 19:27:52.75:
    We propose several sample flow charts to help understand the decision making process for a technician to decide on NII band, 802.11 configuration, SAR test position, and channel. Sample charts are provided to begin the conversation... View attachment associated with this comment
  • Steve Liu commented on 2014-05-05 18:22:00.39:
    When excluded NII bands/positions are allowed, there should be some guidance about how to handle simultaneous SAR (whether to treat the excluded configurations as 0 W/kg or use the highest SAR out of all within the configuration, or other).
  • Steve Liu commented on 2014-05-05 18:21:32.123:
    For some laptops, it may be obvious to determine the antenna-phantom coupling distance. However for phones or small form factors, it is not obvious that this KDB's antenna distance coupling approach will be difficult to justify and implement (i.e. How do you know Left Tilt will be higher than Right tilt? How do you know if Rear surface is higher than Left edge when the antenna is near the left edge?). Since test reduction may be highly desired, a note should be made to prioritize the test positions, or alternatively provide a more rigorous means for a lab to conclusively determine one test position for the initial test position.
  • Steve Liu commented on 2014-05-05 18:18:31.166:
    We suggest providing the WIFI channel plan in a table format for clarity as opposed to the low-resolution 3-D diagram in the Appendix. Also it could be made clearer by the old tabular format (*)'s what is "mid", "low" and "high", for clarity. A suggested table format is provided.. Thank you. View attachment associated with this comment
  • Steve Liu commented on 2014-05-05 18:11:54.81:
    We suggest providing some practical examples to walk through the flow of choosing NII bands, 802.11 configurations, and SAR test positions. Tables with target powers and measured conducted powers will help the reader understand when to use which.
  • Steve Liu commented on 2014-05-05 18:10:31.343:
    We suggest that for subsequent configurations after the initial test configuration that a more practical criteria should be applied to exclude a configuration with a significantly lower power.
  • Steve Liu commented on 2014-05-05 18:02:24.146:
    We suggest to include a flow chart explaining the conceptual change of approach for 802.11 devices, to help everyone transition from the old 2008 approach where the decisions were made based on "802.11x" to the new "test configurations" that are more bandwidth and data rate based. We have been studying the new draft and found that educating the lab or TCB with this KDB needs some adjustment to the existing flow of text to help test personnel get the answers they need about the practical aspects of testing. We expect this KDB to be a work-in-progress, and recommend a transition period for all. Thank you. View attachment associated with this comment
  • Mark Briggs commented on 2014-05-04 21:59:37.243:
    KDB states that when power within a specific data rate/modulation/bandwidth is not the same across a band KDB is required; at the same time it acknowledges that it expects channels 1 and 11 (maybe 12/13 too) to operate at lower power than the other channels and it is assumed that in this case KDB is not required. Would they consider extending this allowance to the low/high channels in any band where power is reduced to comply with EMC band edge requirements. Please explain how simultaneous SAR should be addressed when SAR testing for 802.11 for a particular edge or position (tilt/touch) has been excluded when that position or edge has been tested for collocated WWAN transmitter. When the KDB states that simultaneous transmission can be ignored when SAR does not overlap is this limited to evaluating MIMO operations for coherent transmissions, or does it also exclude the need for a sum-SAR or SPLSR evaluation for MIMO? If the latter, does this extend to the evaluation of simultaneous transmissions for collocated transmitters? Finally is there a definition of "overlap" such as the SAR values for each transmitter must be reduced from the peak value by at least 10dB?
  • David Case commented on 2014-05-01 09:41:44.24:
    Wi-Fi Direct issues. We are assuming that in regard to Wi-Fi Direct, that as a stated this mode is not needed to test in the light of test reduction as SAR would already be covered by Infrastructure mode. However would this apply if the Wi-Fi Direct modes transmit power is higher than in standard client mode? Further Cisco suggest adding wording to clarify that Wi-Fi Direct mode must be capable of passing SAR testing . Section IV (A) less than 5150-5250 MHz, the transmitter power limits have changed -needs to be updated to reflect changes. In regards to the 5470-5725MHz band the 5600-5650 MHz is now allowed again -
  • Kai Niskala commented on 2014-04-30 02:30:27.24:
    - Flow charts could be added to clarify the test flows (e.g. IV B. 1)-3), VI A. 1)-3) etc.) - IV C): Actual test requirements could be clarified - V A): It should be clarified what is actual maximum duty cycle achievable with 802.11 protocol, even when using internal test SW. It may not be exactly 100%, but more near 98% or so. As this duty cycle is maximum achievable, it should conservatively assess real-life exposure scenarios without scaling to 100%. - V B): It should be noted that adjusting to new calibration requirements may take some time, both from test equipment manufacturers and test houses. Transition period should be allowed. - Could it be clarified that initial test position can be chosen also based on RD/fast SAR (including probe arrays) data. This would be more rigour than basing selection only in distance and coupling. - As overall comment, this KDB changes current test flows not only for SAR but also sample preparations including conducted power measurement automation etc. Reasonable transition period should be allowed to adjust processes accordingly.

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.