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There have been 25 comment(s) made on this document:
  • James Kippola commented on 2022-10-21 23:45:19.59:
    Clarification is requested on applicable exemption criteria for specialized medical devices (e.g. 15.103(e) “… generally used at the direction of or under the supervision of a licensed health care practitioner, whether used in a patient's home or a health care facility”), specifically concerning assessment of unintentional radiator source (URS) exposure. Appendix F.1(b)(ii) references Part 15.3(n), concerning incidental radiators, but is silent on Part 15.103 unintentional radiator exemption from FCC equipment authorization. Both incidental and unintentional radiator exemption from authorization are discussed in KDB Publication Number:772105 (PART 15 EQUIPMENT AUTHORIZATION EXEMPTIONS). Clarification is necessary to confirm exclusion of incidental and/or unintentional radiator emissions generated as a byproduct of specialized medical device function (e.g. conducted current/electrical stimulation of biological tissue) when performing Appendix E.3.2 URS Characterization.
  • Kaitlin O'Keefe commented on 2022-10-21 18:52:41.493:
    Hello, Thank you for your efforts on this draft! Please see attached comments. Thank you! View attachment associated with this comment
  • Mark Settle commented on 2022-10-21 15:48:24.67:
    Please see the comments in the attached PDF file. View attachment associated with this comment
  • Jeremiah Darden commented on 2022-10-21 13:18:58.806:
    1. Under Annex Section E.3.4.2 for electric field, it states "The electric field needs to be measured in conditions of free-space propagation...". Is it possible to add an exemption method for conditions that are partially free space for manufacturer flexibility? For example, using 30-1000MHz unintentional field radiation data measured in a Volumetric NSA C63.4 site or equivalent 2. For E.3.4.2, instead of a measurement, could we also use a validated model simulation in free space?
  • David Wright commented on 2022-10-21 13:06:06.913:
    Hewlett Packard Enterprise (“HPE”) expresses our full support for the comments of the TCB Council (submitted by Mark Briggs on 12 October 2022 and Chris Harvey on 14 October 2022). HPE also fully agrees with and supports the comments of the Mobile & Wireless Forum (submitted by Chuck Eger on 13 October 2022).
  • Mark Douglas commented on 2022-10-21 10:35:38.876:
    Schmid & Partner Engineering AG (SPEAG) has read and reviewed the revised KDB 447498 D01 and has comments for technical and editorial improvements that are described in the attachment. View attachment associated with this comment
  • Stephanie Barrett commented on 2022-10-20 14:23:49.833:
    The Information Technology Industry Council (ITI) submits full support for comments of The Mobile & Wireless Forum submitted to this proceeding by Chuck Eger on October 13, 2022. Further, ITI notes that most unintentional radiators are inherently compliant as shown by the TCB Council report “Demonstrating Exemption from Routine Evaluation for Unintentional Radiators Operating under Part 15 Subpart B and/or Part 18 of FCC Rules” (as submitted by Mark Briggs to this proceeding on October 12, 2022).
  • Mark Arthurs commented on 2022-10-20 12:50:39.743:
    Please see the attached editorial and general comments on 447498 D01 General RF Exposure Guidance for Equipment Authorization DR05-44791. Thank you. View attachment associated with this comment
  • Dan Pino commented on 2022-10-19 16:07:33.143:
    Small Dipole approximation only works when the structure is < Lambda/10. But how would one know what structure acts as an antenna at a particular frequency? For example, maybe an URS 100 MHz may be emitted on a Cellular antenna or a trace on a PCB or wire that resonates at 100 MHz… Similar to the short dipole method shortcomings, "geometric features of the radiating device" are not necessarily known unless we consider worst-case and assume the whole EUT is the "radiating feature"
  • Kaitlin O'Keefe commented on 2022-10-19 16:04:11.74:
    Suggest to put E.3.4.3 into its own section E.4. Additionally suggest to reword first sentences: "When URS testing is performed, (for example, when URS does not qualify for a test exemption or when calculation is undesirable), the contribution to the total RF exposure needs to be evaluated.." Also In April 2022 TCB Workshop slides, guidance was given that the URS exposure only needs to be added to the total TER if the URS contribution is > 10% of the limit. Suggest for 2nd para first sentence "For simultaneous emissions from different sources, the URS contributions shall be included in the TER Formula (2.1) if URS > 10% of the RF Exposure FCC limit."
  • Steve Liu commented on 2022-10-19 16:03:23.61:
    E. 3.4.2 Radiated Power Estimate for URS Exemptions: Need to clarify the "conditions" in the 2nd last para. Fully anechoic required? Semi-anechoic? A 3 meter chamber dimension is much smaller than the 100 MHz wavelength, for example and those measurements typically need extrapolation. Therefore, this needs clarification what qualifies as sufficient "conditions of free-space propagation".
  • Kaitlin O'Keefe commented on 2022-10-19 16:00:50.193:
    E. 4.3.1 "1mW Exemption": The paragraph leveraging the 1mW exemption in conjunction with "as well as in simultaneous transmissions" contradicts earlier statements that the 1 mW exemption cannot be used together with other higher power transmitters. Perhaps to keep it as a URS standalone condition and remove "as well as in simultaneous transmissions (where the TER formula apples)."?
  • Steve Liu commented on 2022-10-19 15:59:13.356:
    Section E.3.1 first Paragrah. The guidance makes sense at a high level, but test labs and manfuacturers need practical guidance how to identify "all URS" sufficiently to satisfy the FCC filing. And what qualifies as URS. And "how" a TCB can determine if all URS have been identified. Does a mfg need to declare? Does TCB need to scan through key words like "CPU" "Clock" etc? Additionally, guidance would need to be given on how to assess the location of the URS, as this may not be clear as any wire, trace, etc could radiate as part of the URS.
  • Kaitlin O'Keefe commented on 2022-10-19 15:57:30.206:
    In Section E3.3 More clarification is needed about how to assess " the position of closest approach to both sources" when 2 sources are active. It sounds like a Probe measurement is needed above both the intentional radiator and the URS. Does this mean an additional intentional measurement is needed at the URS location? For example, if an intentional radiator peak is at the bottom of the device, but the URS is at the top, what do we do? Does the intentional SAR still cover the URS?
  • Steve Liu commented on 2022-10-19 15:55:12.21:
    On Section E 3.3.: "Some URS may operate in the same frequency range" and "the use of a sufficiently wide band detector" needs more definition of applicability, since many SAR probes capture (and are calibrated) widely only within their hardware limitations. It might be cleaner to define "same frequency range" as that defined as the lowest frequency per the Probe Spec sheet. Suggestion of revision: "Some URS may operate in the same probe validity range of (at least one) intentional radiator, and operate at the same time (e.g., because the URS provide essential functions for the operation of the intentional radiator, and they are automatically energized when the intentional radiator is transmitting).... ...For example, a digital logic clock operates at 100 MHz, and simultaneously with a 900 MHz transmitter that requires SAR evaluation. The contribution of the URS is then considered as implicitly being part of the SAR evaluation conducted for the 900 MHz transmitter (assuming 100 MHz is within the SAR probe specification range, and the 900 MHz SAR probe conversion factors are conservative with respect to 100 MHz). No further evaluation of that particular URS is then required."
  • Chris Harvey commented on 2022-10-14 11:27:28.026:
    This is posted on behalf of TCB Council. The Rules & Policies committee met several times to discuss the content of the Draft KDB. We have attached a PDF copy of a marked-up version of 47498 D01 General RF Exposure Guidance for Equipment Authorization DR05-44791. Please reference the previous comments submitted by Mark Briggs discussing general exemption for all URS. A Word version of this attachment will be provided directly to the FCC for reference. View attachment associated with this comment
  • Chuck Eger commented on 2022-10-13 14:46:31.48:
    The Mobile & Wireless Forum, in the attached document, sets out our concerns about the proposed testing procedures for URS devices. The document sets out our reasons for why the proposal is not needed or, at best, is premature. For example, MWF has presented research by Dr. Vitas Anderson that demonstrates the inherent compliance of a broad category of URS. Before they are put into place, the MWF urges the FCC to identify examples of cases where such testing would be useful and allow the manufacturers to study them in order to find reasonable ways to circumscribe the issue without engaging in unneeded testing. In addition, MWF has identified specific areas where changes in the language of the KDB would be useful for clarification. View attachment associated with this comment
  • Mark Briggs commented on 2022-10-12 14:17:57.406:
    This is posted on behalf of TCBC. Discusses general exemption for all URS and will provide some context to future response from TCBC. View attachment associated with this comment
  • Robert Huang commented on 2022-09-29 02:40:48.526:
    Could clear to indicate what values/unit can be used in E.3.4.2 Power Estimate Based on Electric Field Strength Measurements formula? For example, Q1: E = maximum amplitude of the sinusoidal wave, 1. is it an Electric field strength value? 2. is it possible to use dBuV/m convert to V/m? 3. what kind of dBuV/m values can be use to convert to V/m? QP or PEAK or.... for both below and above 1GHz frequencies? Q2: r = the distance of the measurement point in the far field from to the center of symmetry of the URS radiating structure r is the centimeter or meter or.........?
  • Robert Huang commented on 2022-09-28 23:55:39.363:
    The formula in table B.1 & Errata document used in calculating the frequency above 75 MHz (f <= 100 MHz, dmm<=50), the results are not the same as the values shown in the associated exemption power threshold tables.
  • Frank He commented on 2022-09-28 01:21:33.423:
    How to evaluate simulataneous transmition with SAR and PD when SPLSR is applied. For example, Tx1 2.4G reported SAR 1.2W/kg; Tx2 5GHz reported SAR 0.8W/kg, Tx3 6GHz reported PD 0.4mW/cm2?Tx1, Tx2 and Tx3 can transmit simulataneously,when the SPLSR is applied, for example SPLSR of Tx1 and Tx2 is 0.01. Could we use the SPLSR radio of Tx1 and Tx2 for simulataneous evaluation? (0.01/0.04+0.4/1≤1)
  • Dao Kang commented on 2022-09-22 05:34:18.276:
    1?Clause 2.1.4: According to CFR Title 47, Part1.1307(b)(3)(i)(B), single RF sources with a separation distance between 0.5cm and 40cm, the exemption power can be based on available maximum time-averaged power or effective radiated power (ERP), whichever is greater, however, according to 447498 clause 2.1.4, for Portable Devices, to Consider near-field effects the determination of test exemption conditions was defined based on conducted power thresholds, please make it clear which requirements will be followed. 2?Clause E3.3: When URS Included in the Intentional Radiator Evaluation, SAR evaluation equipment should include the URS frequency range, however due to the different dielectric properties of tissue-equivalent liquid and frequency range limit of probe, currently in the single SAR test the frequencies mentioned in the example(100MHz, 900MHz) cannot be covered at the same time. If 100MHz URS and 900MHz transmitter all need to be considered, it needs to be measured twice. This is inconsistent with the requirement of "URS Evaluation is not Required "in Figure E.1. Please clarify the measurement details with considering the capabilities of SAR test system(e.g. DASY) 3?Clause E3.4.2: Please clarify how to measure "equivalent dipole length L". Example for a CPU, is diagonal size of CPU equal to “equivalent dipole length l? 4?Clause E.3: With the increasing complexity and integration of intelligent hardware, there are many types of self-integrated URS devices, including the use of VCO, resulting in more types of self-generated frequencies. Is it possible to evaluate and consider major frequency devices by defining a list of key components? In this way, it is not necessary for the manufacturer to list all URS devices on the device one by one, only the key components that have major impact (CPU, GPU...) need perform assessments to help save valuable measurement time. 5?Clause E.3: When a device has two modes, one is complete URS as E3.4 state, the other is URS included in the Intentional Radiator as E3.3 state, (Example, There are two modes for handset, one is traffic mode(E3.3) and the other is flight mode(E3.4)), then, does it mean that both modes need to be evaluated or only mode of URS included in the Intentional Radiator need be done. Thanks a lot!
  • Kirby Munroe commented on 2022-09-21 09:02:52.956:
    Exemption power thresholds for P7X between 100 MHz and 300 MHz in Table B.2 (tabular data) is valid only for P100, P300 for d <= 50. Using P100 and P300 for distances > 50mm provide different results than shown in the associated exemption threshold tables.
  • Frank He commented on 2022-09-13 04:20:12.83:
    1. Clause E.3.3 URS Included in the Intentional Radiator Evaluation(447498 D01 General RF Exposure Guidance DR05-44791) shows URS exempt when simulataneously with intentional radiator. We see the example is a 100MHz clock URS and 900MHz SAR. So we can test the SAR to verified the URS with intentional radiator. But when we evaluate AP which is far away from people. Is it possible we use EIRP/ERP result for URS included in the intentional raidator evaluation? For example, an AP with 2.4GHz Wi-Fi and 100MHz clock, could we consider that the 2.4GHz EIRP/ERP result had included URS if they transmit simulataneously. If this is acceptable, does conducted method for EIRP/ERP is OK. 2. Is it possible to define a loose power exemption limit for URS. Thank you.
  • tianyu chang commented on 2022-08-30 21:09:38.073:
    Dear FCC "447498 D01 General RF Exposure Guidance for Equipment Authorization DR05-44791"Figure B3.1 - Plots for the smoothing functions Sf is not precisely right on page 44. the detla f here shall be 100MHz, but it seems that 50MHz for drawing this plot. it's better to clearfy the detla f and detla d in order to avoid ambiguity. BR, View attachment associated with this comment

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.