• Megan McConnell commented on 2016-03-25 11:08:02.243:
  Please see the attached 1 page document with 5 comments on this draft KDB. View attachment associated with this comment

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• John Smith commented on 2016-03-24 09:35:04.556:
  Accrediting bodies will generally accredit what a test lab has proven that they can do, and not what they will be able to do in the future. Requiring scope of accreditation to include the test program in full prior to submission to a TCB therefor appears to set up a "chicken and egg" problem of which comes first. Very few test laboratories will want to incur the necessary expense of equipment, training, and perform the necessary filing to be accredited for chance of potential work that may not occur. Test labs are also not a cable of predicting what future work may be requested from their clients. Also, requiring an immediate scope expansion prior to submission may cause delays, causing the loss of a potential client and revenue. Requiring scope to include the specific test program prior to submission to a TCB therefor represents a new and unreasonable burden on test labs. However, it is not altogether unreasonable for a test lab to be required to be ISO/IEC 17025 accredited in general and that the test program be pending the acceptance scope of accreditation update prior to submission to a TCB. In such case, it is not altogether unreasonable for the TCB to withhold issuance of grant until such time as the laboratory has achieved the applicable scope of accreditation to cover the specific test program submitted, however in this case it is noted the testing was still performed outside of scope accreditation at the time of testing. Also, in terms of partial recognition, the FCC presents no valid reason to not recognize a full test program that was performed under valid scope(s) of accreditation or pending scope expansion. Requiring additional scope of accreditation beyond that of the immediate specific applicable test program being submitted presents further unsubstantiated and unreasonable burden. Test laboratories should also be able to subcontract portions of their test program to other accredited facilities, and it should be the TCB's responsibility to ensure the entire test program was successfully performed under scope of accreditation, or pending scope expansion. The FCC presents no valid argument that testing performed under scope of accreditation should not be accepted because unrelated tests that were not required were not covered under scope of accreditation. Additionally, in order to prevent what would appear to be an obvious "conflict of interest", the decision of requiring ISO/IEC 17025 accredited testing, and what specific scope requirements will be required, it is recommended the decision by the FCC not be significantly biased by those with significant relationships to ISO/IEC 17025 accredited facilities.

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• Benny Lau commented on 2016-03-22 04:47:38.836:
  TABLE 1: Scope of Accreditation for testing performed in support of DoC and Certification: Equipment subject to Part 15 Subpart C is divided into two scopes listed in Table 1. One is Part 15 Intentional Radiators below 26.5GHz except UPCS and U-NII with DFS. The other one is Part 15 Intentional Radiators above 26.5GHz. This will kill many testing laboratories! Because testing of intentional radiators operate at frequency above 6GHz is rare to many testing laboratories. They would not have measuring equipment ready for testing of such transmitters. For example, transmitter operates at or above 10GHz requires measuring the radiated emission up to 100GHz. I think very few laboratories will spend money to buy a measuring antenna and spectrum analyzer for radiated emission measurement up to 100GHz, if they know the demand for such testing is rare. Therefore, it is very hard for the testing laboratory to obtain the 17025 accreditation covering the test of all intentional radiators operating at or below 26.5GHz before July 13, 2016. Since FCC will not recognize partial scopes, these testing laboratories can no longer test FCC part 15 devices even though it is capable to perform testing of many transmitters such as Bluetooth, WIFI device, 27/ 49/ 433 MHz remote controller, 13MHz RFID…etc. I think it is not fair. I think FCC shall consider re-defining the scope for part 15 subpart C devices, such as to draw the line at 5.8GHz instead of 26.5GHz.

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• Paul Darragh commented on 2016-03-16 17:55:57.31:
  See attached View attachment associated with this comment

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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.