• Kaitlin O'Keefe commented on 2014-11-21 00:57:55.393:
  1. We would like to request that thresholds address 10g Extremity SAR testing since Phablets requiring 10g Extremity for some WIFI bands are very common. 2. We would like to request to re-consider section 3.3 about aggregating 2C and 3, since target powers may differ and also correlation with the EMC parts of the filing may cause confusion. 3. Section 4 step 3) and 4) clarifications noted due to the data rate variations across modes of different bandwidth 4. Section 5.1 should include addressing test positions for tablets as outlined in KDB 616217 in Sub-bullet 2) 5. Generally, harmonizing the language of "position" and 802.11 "configuration" should be applied throughout. An example is Footnote 17, "configurations" is used interchangeably and will cause confusion. 6. Section 5.4.1 does not consider that some bands may not support the same capabilities as other bands (i.e. WIFI hotspot in NII1 and NII 2A) 7. Please clarify "identical configurations" in Table C.3 given variation in lowest data rate across 802.11 technologies 8. Some potential errors in Table C.5 example for "subsequent" channel 9. It would help to clarify section 5.4.2 with the 3rd bullet mentioned in Table C.5 10. The channel selection criteria outlined in Section 5.1 is not very clear in regards to which channels to consider and when the actual measured powers should be used. We suggest that further explanation be added to this section to clarify and to harmonize with the examples in Appendix C. The decision of when to consider output powers across multiple test channels "the same" (within 0.25 dB) is also not clear in the text of the KDB or the examples provided. Other editorial/technical clarifications are noted on the marked up attachment with select pages from the draft KDB. Thank you very much for working on this for all of us. View attachment associated with this comment

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• Kaitlin O'Keefe commented on 2014-11-21 00:48:51.173:
  1. We would like to request that thresholds address 10g Extremity SAR testing since Phablets requiring 10g Extremity for some WIFI bands are very common. 2. We would like to request to re-consider section 3.3 about aggregating 2C and 3, since target powers may differ and also correlation with the EMC parts of the filing may cause confusion. 3. Section 4 step 3) and 4) clarifications noted due to the data rate variations across modes of different bandwidth 4. Section 5.1 should include addressing test positions for tablets as outlined in KDB 616217 in Sub-bullet 2) 5. Generally, harmonizing the language of "position" and 802.11 "configuration" should be applied throughout. An example is Footnote 17, "configurations" is used interchangeably and will cause confusion. 6. Section 5.4.1 does not consider that some bands may not support the same capabilities as other bands (i.e. WIFI hotspot in NII1 and NII 2A) 7. Please clarify "identical configurations" in Table C.3 given variation in lowest data rate across 802.11 technologies 8. Some potential errors in Table C.5 example for "subsequent" channel 9. It would help to clarify section 5.4.2 with the 3rd bullet mentioned in Table C.5 10. The channel selection criteria outlined in Section 5.1 is not very clear in regards to which channels to consider and when the actual measured powers should be used. We suggest that further explanation be added to this section to clarify and to harmonize with the examples in Appendix C. The decision of when to consider output powers across multiple test channels "the same" (within 0.25 dB) is also not clear in the text of the KDB or the examples provided. Other editorial/technical clarifications are noted on the marked up attachment with select pages from the draft KDB. Thank you very much for working on this for all of us.

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• David Case commented on 2014-11-13 15:22:57.143:
  This draft has taken into consideration, earlier discussions on SAR testing 802.11 radios. The discussion on duty cycle and correction is in line with the paper I presented back in 2008 to the IEEE 1528 workgroup. As the 2013 version of the IEEE 1528 does address testing above 3GHz and does allow for SAR testing of 802.11 devices, and since it is not adopted yet, this document is a good interim to address some of the unique issues of testing 802.11 products using OFDM.

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• Mark Briggs commented on 2014-11-06 21:07:07.683:
  Many thanks for progressing this along. A couple of comments: 1) Would it be possible to consider aggregating the upper section of Band 2C (5650-5725 MHz) with Band 3 (5725 - 5850MHz) regardless of whether or not the device operates in the band gap on channel 144? Currently the procedure only allows the two bands to be aggregated if the band gap channel is supported, but since that channel is not one of the channels that would be tested (not center of aggregated band or at either end of the band) it is not clear why operation on the channel is the gating factor. 2) Please check your wording in section VII C (1) (a) (ii) (1) where you discuss test reduction for the 5GHz OFDM modes. I think "... for channels that overlap in the initial test configuration and subsequent test position due to differences ..." should be "... for channels that overlap in the initial test configuration and subsequent test configuration due to differences ...".

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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.