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There have been 7 comment(s) made on this document:
  • Mark Briggs commented on 2014-05-23 14:03:27.26:
    Please refer to attachment - thanks! View attachment associated with this comment
  • Brian Scarpelli commented on 2014-05-23 13:31:48.766:
    Please find attached the comments of the Telecommunications Industry Association (TIA) on draft KDB 594280, 'Software Security and Configuration Control Requirements for Non-SDR Devices'. 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
  • David Case commented on 2014-05-21 14:11:36.033:
    Additional comments View attachment associated with this comment
  • Daniel Pino commented on 2014-05-19 17:16:45.48:
    Section 3)d) discusses band edge measurements using the marker-delta method and the integration method. The first paragraph states that either of these methods can only be used when the 99% occupied bandwidth edge of the signal falls within 2MHz of the band edge. In recent KDB inquiry to the FCC, it was determined that this 2MHz requirement is only for the marker-delta method and not for the integration method. Please update the text in this section to state the the integration method is not subject to the "2MHz" rule.
  • David Case commented on 2014-05-09 10:18:46.656:
    Cisco Comments on FCC KDB Testing of U-NII devices In regards to Transmitter power output testing, it seems the FCC made it over complicated with multiple choices , therefore Cisco recommends the use of the transmitter power output tests as specified in C 63.10 (13) or C 63.10 (09) . Further we recommend the use of conducted testing verse radiated testing unless the antenna is non removable. In regards to the PSD for the 5725-5850 MHz band, Cisco recommends that the testing be done using 1`MHz bandwidth and that the industry be allowed to demonstrate compliance based on limits of 38dBm/1MHz. As spectrum analyzers such as the Agilent N9030A have a 1MHz RBW / VBW setting, It should be noted that it has a 510kHz not 500KHz BW setting , thus the bandwidth selection causes a problem and we either must use the 510kHz setting or default to a more accurate 1MHz setting . Note over 1MHz span we get a more accurate Maximum Power Spectral Density as we be measuring over the actual bandwidth of the emission needed and not one wider then needed possibly adding measurement error to the reading. In regards to section H addressing the Antenna masks issue. First the current FCC rules allow the use of family type antennas with similar characteristics of equal or lesser gain to be substituted for the original antenna approved with the device. As such the new requirements for antenna pattern will require not only verifying the antenna pattern , but now require a review of the antenna mask as well as determining if the antenna is similar. The information on the mount is not routinely placed in the manual and only general antenna information is provided with the devices. As such the new requirements places the burden on either the manufacturer reviewing all the 3rd party antennas for a customer (something most manufactures do not have time to do) or to provide a specific guidance document on antenna specifications to the installer. As such clarification on what info we must provide to the professional installer needs to be included in this KDB. Cisco supports method #1a as providing the most accurate method to verify antenna mask. Whether developed in house or by a 3rd party the antenna patterns and information should e available as part of verifying the antenna characteristics. If it is not available for any reason Cisco recommends when using method 1b that the testing be done in accordance with C 63.10 (2013) specifically section 6.3 Radiated emission testing and sections 6.3.1 and 6.6.3.1 which addresses radiated emission testing above 1GHz and specify that the antenna be mounted or device placed on a table top height of 1.5 meters made of material as specified in the standard. This would allow testing in a more realistic “free space”: environment and better simulate outdoor systems mounted on antenna towers and rooftops and reduce false reading from the ground plane of the test facility. As an alternative the use of a full anechoic room could be used In regards to Section 1b, Cisco has some concerns on the requirements in 1b as they are not specific enough and will not yield uniform results across labs or manufacturers. .Cisco believes that this discussion needs to be brought to the testing experts in C 63 to help address in the future to tighten up this requirement. Until then Cisco suggests that the test lab be allowed to use C 63.10 (2013) Radiated measurement portion to help qualify antennas.
  • Mark Arthurs commented on 2014-05-08 18:51:32.906:
    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.
  • Zhang Weimin commented on 2014-05-07 02:57:11.21:
    The new rule 15.407(e) require the 6dB bandwidth, while the KDB do not give the detailed test method. Maybe the test method for 26dB emission bandwidth (clause II.C of this KDB) used?

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.