• Mike Zhou commented on 2016-09-14 08:45:20.03:
  Dear FCC, Our SAR and RF lab have some comments, please see the attachment. Thank you ~ Sincerely Mike View attachment associated with this comment

---

• Mike Zhou commented on 2016-09-14 08:43:52.336:
  Dear FCC, Our RF&SAR lab have some comments. Details please see the attachments. Thank you~ Sincerely Mike View attachment associated with this comment

---

• Praveen Rao commented on 2016-09-13 02:56:48.26:
  LTE technology shows an added complexity over previously available radio schemes. In order to configure and test LTE devices, many signal parameters have to be taken into account: frequency band, channel bandwidth (from 1.4 to 20 MHz), modulation (QPSK and 16-QAM), and number of resource blocks allocated, offset of the resource blocks within the channel bandwidth as well as MPR. The combinations of parameters in a given frequency band can result in hundreds of LTE Modes and SAR test configurations. In order to address this a specific protocol is necessary for SAR assessment of LTE devices. The main purpose of this protocol is to support demonstration of DUT compliance with applicable limits based on a reasonable number of SAR evaluations. Conducted power of the LTE module may be used to screen and filter a number of SAR test configurations. This approach has been proposed and agreed by IEC. Reference: Draft IEC PAS 106/377/PAS

---

• Per Nielsen commented on 2016-09-07 06:13:03.873:
  Dear Sir/Mrs A lot of product in the Internet of Things philosofy includes all kinds of radio devices and multiple radios as well. A test reduction should be possible not only on module basis as a lot of manufactures avoid getting module approval if the antenna is not included in the module. Based on the output power of such low power devices it should be possible to get a module listed with/without internal antenna. Especially in the 915 Mhz, Bluetooth, Wifi, etc. you see this divergense that you can only buy a certified module if it includes an antenna, even though it is obvious that the design has soldering pads for a connector to an external antenna. The TCB's should suggest to list both variants on the certificates/grants. Example: LM Technologies WiFi module. The LM820 is FCC certified (Internal antenna), but the LM821 is not FCC certified (External antenna connector). The module are identical except for antenna connection. This means complete re-testing if you integrate LM821 which should not be the case. It works well within the celluar module industry, but not in the low power device industry. Secondly I think you besides modules should list the chipsets used in FCC approvals i.e. previously approved chipset reference list. If the chipset previously have been used then test reduction on all conducted test in e.g FCC part 15.247 or 249 should be eliminated. Then manuafctures can concentrate on tests that creates value like emissions, harmonics, cable interfaces etc. Second reduction should be given if identical designs are present in various PCB layout to create multiple product form factors, but parts list are identical for the radio parts. I probabely would like to add a gain report for modules/devices to select worst case channels etc. for emission testing. I normally find it very helpful. Best regards Per Nielsen

---

• Ferdinand Custodio commented on 2016-08-23 16:46:22.373:
  Suggestion to further streamline establishing worst case mode. If the modes are sequential then this suggestion applies. For example using 802.11, 802.11b is manageable using only 1,2,5.5 and 11 Mbps, 802.11g on the other hand could be streamlined to 6, 18, 36 and 54 Mbps. The same is true for 802.11n, we can just use MCS 0,2,4 and 7. the same principle applies for 802.11ac and other technologies for that matter.

---

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.