• George Kizer commented on 2020-09-25 17:23:12.833:
  Attached are the comments of CSI Telecommunications, Inc. View attachment associated with this comment

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• Tim Harrington commented on 2020-09-04 10:22:10.2:
  The UWB Alliance commends the Commission for initiating discussion of the required certification criteria for U-NII 6 GHz devices operating in the 5.925-7.125 GHz band. However, we are surprised to see a test for a contention based protocol in this draft. The R&O clearly states that this contention based protocol should be defined by a multi-stakeholder group, which has only just begun its work. We note that the proposed protocol in the KDB has not been discussed with the incumbents it needs to protect and therefore its performance for protecting incumbents is unknown and unverified. Additionally, the contention based protocol is not currently one of the workstreams in the multi-stakeholder group organized by WinForum. The UWB Alliance is working cooperatively with licensed incumbents to draft a proposal to add it as a fourth workstream. We request that the FCC and OET support this effort. This work is critically important when it comes to LPI and VLP operation since the R&O correctly states that the contention based protocol is the primary way to ensure protection of incumbents for these modes of operation. Hence, we don't agree with the two-phase approach proposed and urge the Commission to refrain from publishing this KDB until the multi-stakeholder group has concluded its tasks, including the definition of the contention based protocol.

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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.