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There have been 7 comment(s) made on this document:
  • Christopher Szymanski commented on 2021-10-29 12:40:25.296:
    Please see attached comments from Broadcom Inc. View attachment associated with this comment
  • Mark Briggs commented on 2021-10-20 11:59:27.07:
    For question 11 in the draft D03: If we are listing a channel that crosses both UNII 3 and UNII 4 do we need to list that channel twice - one listing the EIRP value for the entire channel (which needs to meet UNII 4 limits) and the conducted power for either the whole channel or the part of the channel falling in UNII 3?
  • Mark Briggs commented on 2021-10-20 11:15:05.916:
    The rules state: Power spectral density measurement: The maximum power spectral density is measured as a conducted emission by direct connection of a calibrated test instrument to the equipment under test. If the device cannot be connected directly, alternative techniques acceptable to the Commission may be used. Measurements in the 5.725-5.895 GHz band are made over a reference bandwidth of 500 kHz or the 26 dB emission bandwidth of the device, whichever is less. Measurements in all other bands are made over a bandwidth of 1 MHz or the 26 dB emission bandwidth of the device, whichever is less. A narrower resolution bandwidth can be used, provided that the measured power is integrated over the full reference bandwidth. This does not seem to be consistent with the requirements because the requirements for 5.725 - 5.850 GHz are based on a PSD per 500kHz but the 5.850 -5.895 GHz are based on PSD per 1MHz. In Q&A 13 it is stated that psd for 5.850 -5.895 GHz should be based on 1MHz which is consistent with the limits in Part 15E but not the measurement method in 15E (15.407 a 12). Could you confirm in the final KDB that the 500 kHz specified in the rules is not to be used or explain how to compare the measured value using 500kHz to the limit expressed per 1 MHz.
  • Mark Hill commented on 2021-10-01 11:09:40.103:
    Follow on to Collin Wilson's comment of 9/23 - 291074 D01 Section 10 states that only devices that were labeled with with "FCC regulations restrict the operation of the device to indoor use only." can be field upgraded. This label isn't currently required for 5GHz UNII devices, therefore it is very unlikely that any currently deployed devices will have the required label. It would be preferable to allow this statement to be added to the user's manual as part of the C2PC.
  • Jody House commented on 2021-09-30 12:43:23.826:
    Please review the content of the example at the bottom of the table in Section 2. U-NII BANDS (OVERVIEW). The channel frequency ranges are listed in MHz, but labelled as GHz. In addition, Channel 171 is defined as 5825 - 5885 GHz (MHz). This is an unexpected 60 MHz span, and could instead be defined as 5815 - 5895 MHz. In the question and answer section, response A6 regarding the determination of whether or not an enclosure is weatherized requires both test labs and TCBs to review the user manual and other documentation. Please consider adding guidance specific to test labs for the deliverable in this regard. For example, are the results of the test lab review of the enclosure to be documented in the test report?
  • Colin Wilson commented on 2021-09-23 16:36:24.863:
    Space on the label is often an issue and adding the reference to FCC regulation in the warning statement on the label seems unnecessary. This should be restricted to inclusion in the user’s manual. The KDB 987594 D01, recently released for 6GHz, differentiated between the product label and the user manual requirement. I suggest changing section 3(a) para 4 to: Indoor access point devices must bear a statement in a conspicuous location on the device and user’s manual to indicate the restriction for indoor use only. Then section 4(a) (2) should be changed to say: • Indoor use only Section 4(b) would remain unchanged and includes the reference to the FCC restrictions This would be more aligned with KDB 987594 D01 section II(A) paragraphs 6 and 7
  • Colin Wilson commented on 2021-09-23 16:35:37.443:
    Space on the label is often an issue and adding the reference to FCC regulation in the warning statement on the label seems unnecessary. This should be restricted to inclusion in the user’s manual. The KDB 987594 D01, recently released for 6GHz, differentiated between the product label and the user manual requirement. I suggest changing section 3(a) para 4 to: Indoor access point devices must bear a statement in a conspicuous location on the device and user’s manual to indicate the restriction for indoor use only. Then section 4(a) (2) should be changed to say: • Indoor use only Section 4(b) would remain unchanged and includes the reference to the FCC restrictions This would be more aligned with KDB 987594 D01 section II(A) paragraphs 6 and 7

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.