• Brian Scarpelli commented on 2014-05-23 13:33:18.766:
  Please find attached the comments of the Telecommunications Industry Association (TIA) on draft KDB 789033, 'Guidelines for Compliance Testing of Unlicensed National information Infrastructure (U-NII) Devices PART 15, SUBPART E'. Brian Scarpelli Director, 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

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• William Graff commented on 2014-05-12 19:56:21.606:
  I applaud the revised UNII test procedures and am very happy to see the elimination of the peak excursion test. Thanks. I also applaud the Section H measurement section referencing the use of antenna pattern measurement to assure compliance with the max 125mW EIRP at elevation angles above 30 degrees. I would prefer to see a specific IEEE (or other) reference to a specific antenna pattern measurement standard, but this is a good start. There are no specific details on antenna/EUT grounding, reference plane(s), transmission line SWR, etc. - all which could potentially create a great deal of measurement error. I also would like to see the same measurement standard applied to antenna specifications received from the manufacturer/applicant - getting good and reliable non-fiction pattern measurements can be challenging. In addition, the document OET 13TR1003 Directional Gain of 802 11 MIMO with CDD 04 05 2013 appears to conclude that array gain currently modeled using the formula 10 log10(NANT) may overestimate total gain. Therefore, the case for making formal measurements instead of relying on an antenna supplier's specifications increases. Best Regards, Bill Graff

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• Dave Case commented on 2014-05-09 10:19:50.32:
  As Cisco has commented and discussed this KDB numerous times with FCC, we are only commenting on the changes in regards to security of the software uploads. We support the changes in regards to this section as there are in line with the SDR guidelines for software and in fact clarify the requirements better. As such the only change we make is that it be noted that this information as presented here must be held long term confidential.

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• Mark Arthurs commented on 2014-05-08 18:52:30.24:
  The transition dates for permissive changes. The text in the KDB addresses the permissive change in two places. The first reference allows the use of the old rules for one year. The second reference restricts the use of the old rules after two years. • New devices or permissive changes on previously approved devices will be permitted under the previous rules (rules prior to the effective date of FCC 14-30) for one year after June 2, 2014. • After June 2, 2016, no permissive changes will be permitted for devices approved under the previous rules unless they meet the requirements of the new rules. The presentation at the October 2014 TCB meeting by the FCC also indicted that Class II permissive changes would be allowed for two years. Oct 2014 TCB FCC Presentation: U-NII First R&O(¶ 126-134) Transition Periods Grandfathering- Existing devices will be grandfathered for the life of the equipment. Applies to devices which are operating in field, do not cause interference, and are not modified. 12 month transition – applications for certification of U-NII devices must meet the new and modified rules after 12 months. 24 month transition – the manufacture, marketing, sale and importation of non-compliant devices must cease after 2 years. Class II permissive change – allowed for old equipment for up to 2 years under the old rules. Class II permissive change – allowed indefinitely if such changes would result in compliance with the new or modified rules. It seems that Class II Permissive changes are allowed on devices that are compliant with the old rules for two years (June 2, 2016) but might be misunderstood with the current text.

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• David Case commented on 2014-05-01 09:15:46.373:
  In regards to the intro of this document and dates of effectiveness, it was our understanding that the date as established for final date of products for sale only pertained to devices operating in the 5725-5850 MHz and approved as DTS under Part 15.247 . As stated in the intro of this document one could read it as to applying for devices approved per the first version of the DFS test procedure. Please clarify this in next version

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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.